Mandatory annual audit in Cambodia
Cambodia statutory audit — meet 2 of 3 thresholds (turnover KHR 4bn, assets KHR 3bn, 100 staff), QIPs always audited, ACAR filing, penalties.
- Duration
- Annual — audited financial statements filed with ACAR (~6 months after year-end)
- Difficulty
- Moderate
- Reading
- 7 min
TL;DR
- A statutory annual audit is mandatory for enterprises that meet at least 2 of 3 thresholds: turnover > KHR 4 billion, total assets ≥ KHR 3 billion, more than 100 employees ( Prakas No. 563 MEF.Prk dated 10 July 2020).
- QIP projects, public enterprises and public-interest entities are always audited, regardless of size.
- The audit must be performed by a firm licensed by ACAR (a KICPAA member); audited financial statements are filed with ACAR (~6 months after year-end). Failure to audit exposes you to fines.
Who must have their accounts audited
The Law on Accounting and Auditing (Article 18) provides that financial statements “can be required to be submitted for audit according to conditions set out by Prakas of the Minister of Economy and Finance.” Those conditions are set by Prakas No. 563 MEF.Prk dated 10 July 2020.
Enterprises subject to the 3-threshold test
A private enterprise must have its annual financial statements audited if it crosses at least 2 of the 3 thresholds below at the financial year-end:
| Criterion | Threshold | ≈ USD |
|---|---|---|
| Annual turnover | > KHR 4,000,000,000 | ~ USD 976,000 |
| Total assets | ≥ KHR 3,000,000,000 | ~ USD 732,000 |
| Headcount | > 100 employees | — |
Source: Prakas No. 563 MEF.Prk dated 10 July 2020, “Obligation to Submit Financial Statements for Independent Audit.”
Entities always audited (regardless of size)
Independently of the thresholds, an annual audit is automatic for:
- public enterprises (public capital);
- public-interest entities (banks, microfinance, insurers, listed companies and other “publicly accountable” entities);
- QIP projects (Qualified Investment Projects) registered with the CDC — see the company structures guide.
Not-for-profit organisations
NGOs / associations must have their accounts audited when they exceed both of the following: annual expenses > KHR 2,000,000,000 (~ USD 488,000) and more than 20 employees.
The auditor must be ACAR-licensed
A statutory audit is only valid if performed by a registered and licensed professional. The law is explicit:
- Article 27: only natural persons or legal entities registered on the roll of the accounting and auditing professional body may act as auditors.
- Article 29: practising audit requires being a member of the body (KICPAA, Kampuchea Institute of Certified Public Accountants and Auditors) and holding a licence issued via the NAC (National Accounting Council) / ACAR.
ACAR (Accounting and Auditing Regulator), under the MEF , sets the standards (CIFRS, CISA), issues and withdraws licences, and oversees audit quality through the Audit Quality Monitoring Committee.
Timeline and ACAR filing
- Accounting period: by default 1 January to 31 December (law, Article 21).
- Preparation of financial statements: within 3 months of year-end (law, Article 17).
- Filing with ACAR: audited financial statements are filed via the efiling.acar.gov.kh portal, in practice around 6 months after year-end (mid-to-late July for a 31 December year-end). Exact dates are published each year by ACAR notification — check them for the current year.
- Retention: financial statements and accounting records 10 years (Article 23); audit evidence 10 years (Article 26).
Language and currency of the financial statements
- By default, accounts and financial statements are kept in Khmer and in riels ( KHR ), law Article 22.
- Enterprises that regularly transact with foreign entities may, under the conditions of an MEF Prakas, keep their accounts in English and use a foreign currency (USD) to accompany the Khmer/riel version.
- The audit report is drawn up in Khmer; English may accompany it (law Article 25).
Penalties for non-compliance
Penalties are set in Chapter 11 of the law (amounts in riels):
| Breach | Penalty (Law on Accounting and Auditing) |
|---|---|
| Practising accounting / audit without a licence (Art. 33) | 6 months to 1 year imprisonment + fine KHR 2,000,000 to 8,000,000 (~ USD 490 – 1,950) |
| Liable legal entity (Art. 34) | fine KHR 5,000,000 to 20,000,000 (~ USD 1,220 – 4,880) + additional penalties (dissolution, court surveillance, activity ban…) |
| Auditor issuing a fake report (Art. 35) | 2 to 5 years imprisonment + fine KHR 8,000,000 to 20,000,000 (~ USD 1,950 – 4,880) |
Common pitfalls
FAQ
My company crosses only one threshold — must I have an audit?
Not in principle. A statutory audit is triggered by crossing at least 2 of the 3 thresholds (turnover > KHR 4bn, assets ≥ KHR 3bn, > 100 employees). One threshold alone is not enough — unless you are otherwise a QIP, a public-interest entity or a public enterprise, in which case the audit is automatic.
Does a small Co. Ltd. still have to file accounts with ACAR?
Yes. Even when not subject to audit, an enterprise files its (unaudited) financial statements with ACAR via the e-Filing portal, on the deadline applicable to non-audited entities. The audit is only an additional requirement for entities that exceed the thresholds.
Who can sign a statutory audit in Cambodia?
Only a licensed audit firm: a KICPAA member holding an audit licence issued via the NAC / ACAR (law, Articles 27 and 29). Verify the licence number on the official register of firms before signing the engagement letter.
What does a company risk if it fails to audit accounts it should?
Beyond the risk of having its accounts rejected by banks and the GDT, the law provides for fines (KHR 5,000,000 to 20,000,000 for a legal entity, Art. 34) and additional penalties. Failure to file with ACAR also exposes you to the regulator’s own administrative penalties.
In which currency must my audited financial statements be prepared?
In Khmer and riels by default (law, Article 22). If you regularly deal with foreign entities, an MEF Prakas allows accounts to be kept in English and USD to accompany the Khmer/riel version. The audit report is in Khmer, with English optionally accompanying it (Article 25).
Sources (3)
Every fact in this guide comes from official documents or government sites. An access date is recorded for each source.