On 25 May 2026, the Royal Government of Cambodia has issued Sub-Decree No. 102 on Penalties for Violations of the Law on Accounting and Auditing (the “Sub-Decree 102”), introducing a comprehensive framework for non-compliance with accounting and auditing obligations. It is designed to strengthen enforcement of the governing law by clearly defining offences and corresponding fines, while also establishing the relevant authorities, measures, and procedures for the imposition and administration of penalties.
Key features:
Broad scope of application
Sub-Decree 102 applies to audited and non-audited enterprises, non-profit organizations, and licensed accountants and auditors operating in Cambodia.
Defined violations and compliance obligations
Sub-Decree 102 sets out various violations, including failure to maintain proper accounting records, failure to submit annual financial statements to the Accounting and Auditing Regulator (“ACAR”), and intentional misreporting of financial information.
Significant financial penalties
Sub-Decree imposes substantial fines for non-compliance. Notably:
- Audited enterprises may be subject to fines of up to KHR 60 million for failure to submit annual financial statements to ACAR.
- Non-audited enterprises may face fines of up to KHR 50 million for similar violations.
Additional penalties apply for non-compliance with accounting standards, improper record keeping, and failure to comply with language and currency requirements.
For further information, please visit DFDL.
