Businesses issuing e-wallets that are neither banking and financial institutions nor licensed payment service institutions should act now. In its Notification No. 14.026.1075 on the Obligations of Business Owners Issuing Electronic Money (E-Wallet Accounts) for Payment for Products or Services Within a Single Network, dated 6 August 2026 (the “Notification“), the National Bank of Cambodia (the “NBC“) requires each affected issuer to file a written notification with the NBC within 90 days, i.e, by 4 November 2026. Failure to notify exposes issuers to enforcement action, including sanctions under the Law on Banking and Financial Institutions of 1999 (the “LBFI“).
Background and legal basis
The Notification is directed at non-financial businesses (for example, coffee shops, restaurants, gyms, transport operators, entertainment centres and fuel stations) that let customers open e-wallet accounts through a mobile application (a “Mobile App“) or a membership card and load monetary balances redeemable only for goods or services within the issuer’s own network. The NBC refers to this as “Single-Purpose E-Money“.
Two provisions of Cambodian law underpin the Notification. First, under the LBFI, providing means of payment to customers forms part of the operations of banking and financial institutions and requires an NBC licence. Second, Article 20, paragraph 1 of the Prakas on the Management of Payment Service Institutions of 2017 (the “PSI Prakas“) prohibits any legal person, other than a banking and financial institution or a licensed payment service institution, from issuing electronic money. A related but distinct provision, Article 4, paragraph 2 of the same PSI Prakas, excludes from the Prakas’s scope payment instruments that can be used only in the premises of the issuing institution or within a limited network. Issuers should keep this scope-exclusion conceptually separate from the Article 20(2) notification exemption on which the Notification is centred.
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