| Draft Law on Personal Data ProtectionMPTC-led draft | DraftMPTC announced it on 19 Feb 202112. A draft was released on 23 Jul 202513, reviewed with French advisers on 20 Apr 202615 and validated at a workshop on 5 Aug 202614. No adoption date. | As drafted in Jul 2025: every controller and processor appoints a certified DPO and reports it to MPTC within 30 working days; breach notice to the regulator and data subjects; foreign entities targeting Cambodia appoint a local representative; fines up to KHR 600 million (≈ US$150k) or 10% of annual turnover; a two-year transition after promulgation13. Details may change. | Implication: once adopted, every customer needs a DPO and a breach process. Response: a draft-PDP gap assessment as the door-opener, then vDPO as a Service and DLP. |
| Current data rules (patchwork)Constitution, Civil Code 2007, Criminal Code 2009, E-Commerce Law, Banking Law, Sub-decree 252 | In forceSummarised by DLA Piper, last modified 13 Feb 202612. | Privacy rights in broad terms. Security duties for e-commerce data (Art. 32). Bank secrecy (Banking Law Art. 47). Sub-decree 252 (22 Dec 2021) covers ID data held by the Ministry of Interior only. No data-protection regulator, no general breach-notice duty, and no general localisation or transfer restriction outside NBC rules12. | Implication: today, non-bank data may be processed from Mumbai under contract. Response: processor terms in every contract, and a design that can move into a Phnom Penh DC if the PDP law changes the rules. |
| Draft Law on CybersecurityMPTC-led draft | DraftListed as a draft at the start of 202617. MPTC and the Ministry of Justice reviewed its inspection and penalty chapters on 8 Jul 2026, with a follow-up set for 14 Jul16. | We did not review the current draft text, so its obligations are not re-verified. The Jul 2026 meeting focused on inspection and penalties16. | Implication: likely audit and incident duties for important operators. Response: build incident-reporting runbooks on our managed SOC and audit readiness now. |
| Draft Law on CybercrimeSeparate draft | DraftListed as a draft in the Q4 2025 round-up (2 Feb 2026)17. | No current text reviewed: not re-verified. It is separate from the Online Scams Law below. | Response: track it with counsel; no product change yet. |
| Law on Combating Online ScamsPromulgated by royal decree | In forceSenate approval 3 Apr 2026, promulgated and in force 6 Apr 20261819. | Criminal penalties for technology-enabled scams, scam-centre operation, recruitment and identity-document misuse. Legal entities face fines of KHR 1–30 billion or the value of the proceeds. Courts may order closure of bank accounts and online platforms used in scams18. | Implication: banks, platforms and telcos tighten fraud and identity controls. Response: digital risk monitoring, DMARC, MFA and awareness training. |
| Law on Electronic CommerceWith the Consumer Protection Law | In forceEnacted 2 Nov 201920. | An e-commerce licence (companies and branches) or permit (individuals) from the Ministry of Commerce, plus an MPTC online permit and domain registration. Small sellers under US$62,500 a year are exempt from the permit. Operators carry the duty to protect electronic data, without technical standards20. | Implication: online sellers need security they can show. Response: Retail Cloud, WAAP and certificate automation. |
| NBC Technology and Cyber Risk Management Guidelines (TCRMG)For banks and financial institutions | IssuedA 2025 version replaces the 2019 Technology Risk Management Guidelines11. NBC presented it to the sector in 202610. Exact effective date: not re-verified. | Applies to all licensed banks and financial institutions, in proportion to risk. Inventory of cloud-hosted systems, MFA for users who configure cloud, HSM key control kept in a higher control environment, logical segregation at outsourcers and data destruction at exit11. NBC rules restrict international data transfers for these institutions12. | Implication: bank workloads stay in Cambodia; outsourcers face due diligence. Response: BFSI Cloud in a Phnom Penh partner DC, HSM services, and a TCRMG gap-assessment pack. |
| Bakong, KHQR and CamDXNBC payment system · national data exchange | OperatingBakong launched in Oct 20209. UPI acceptance at KHQR merchants went live on 2 Jun 202640. | Bakong handled 1.325 billion transactions in 20258. CamDX processed more than 21.7 million e-KYC transactions by end-2024, linking 60 financial institutions, as reported by Mordor2. | Implication: identity and signing keys behind payments need strong protection. Response: Managed PKI, HSM and PQC readiness. Certified e-signature rules: not re-verified. |
| Law on TelecommunicationsRoyal Kram NS/RKM/1215/017 | In forcePromulgated 17 Dec 201521. | Only persons authorised by the TRC, by permission letter, certificate or licence, may provide telecom operator services. MPTC is responsible for networks and infrastructure21. | Implication: connectivity comes from licensed operators. Response: buy links from licensed Cambodian operators; sell SD-WAN on top. |
| Cloud-service licensing (MPTC)Consulting and Technical Service Certification Licence | OperatingHuawei became the first licensed cloud provider in 20217. Current terms: not re-verified. | MPTC issued the licence through an online system and said any company could apply7. | Implication: selling cloud in our own name likely needs this licence. Response: sell through licensed partners first, then apply with the local company. |
| Sub-decree 23 on the National Internet GatewayMPTC / TRC | Issued · status unclearIssued 16 Feb 202122. Plans to implement it were reported in 202523. Current status: not re-verified. | As issued: operators connect to a domestic internet exchange run by NIG operators, and gateway operators report traffic to MPTC and TRC22. | Implication: possible routing and latency changes for cross-border links. Response: keep latency-sensitive workloads in Phnom Penh. |
| Draft National AI Strategy 2025–2030MPTC · Digital Government Committee | DraftConsultation drafts in 2025; MPTC launched an AI readiness report on 2 Jul 202526. OECD.AI lists it as proposed (updated 9 Jun 2026)25. | A policy, not a law. Six priorities: human resources; data, infrastructure and key technologies; AI in digital government; sector adoption; ethical and responsible AI; and collaboration and R&D. Achievement reports are planned for 2026 and 202825. We found no AI law. | Implication: public demand for AI skills and responsible-AI practice. Response: AI training, vCAIO advisory and ISO/IEC 42001. |
| Digital policy frameworkDESPF 2021–2035 · Digital Government Policy 2022–2035 · draft laws | PolicyThe Digital Economy and Society Policy Framework was adopted in 2021; the Digital Government Policy was approved on 28 Jan 202224. Draft ICT and Digital Government laws were in consultation on 20 Apr 202615. | Long-term plans for digital infrastructure, digital government and skills. The draft laws' contents are not re-verified. | Response: serve public bodies through Cambodian primes and development-partner programmes, with Government Cloud patterns. |
| Entity, investment & taxCo., Ltd. · QIP · CIT · VAT · withholding tax | CurrentPwC Tax Summaries reviewed 2 Apr 202627; Law on Investment promulgated 15 Oct 202130. | CIT 20%, VAT 10%. A final 14% withholding tax on Cambodian-source payments to non-residents, including service and technical fees27. Sub-decree 65 (8 Apr 2021): non-resident digital sellers register for VAT on B2C sales; B2B buyers reverse-charge 10%28. No India–Cambodia tax treaty appears in Cambodia's treaty list29. QIP status can give a 3–9 year income-tax exemption; digital industries are encouraged30. Foreign-ownership limits per activity: not re-verified. | Response: see pricing & tax. Get Cambodian tax advice for each contract structure. |