Cambodia introduces limited-time ADCE penalty waiver for non-compliant companies.

Cambodia’s Ministry of Commerce (MoC) has introduced a temporary penalty-waiver measure allowing companies that have failed to file their Annual Declaration of Commercial Enterprise (ADCE) to regularise their status at significantly reduced cost.

Under Notification No. 0051, accumulated historical penalties are waived, provided eligible companies settle the penalty for the most recent year of non-compliance only. The measure is intended to enhance administrative efficiency and encourage timely corporate compliance.

One-year penalty in place of multiple years

Under the standard framework, companies that fail to submit their ADCE are subject to a penalty of KHR 2,000,000 per year of non-compliance. For entities that have missed multiple years, these amounts can accumulate quickly.

The new policy limits the payable penalty to a single year only, with all prior years waived. This creates a limited window for companies to bring their commercial registration records up to date without bearing the full burden of historical fines.

Eligibility conditions and deadline

To benefit from the waiver, companies must satisfy both of the following requirements:

• Settlement within 60 working days – The penalty for the most recent year must be fully paid within 60 working days from 8 January 2026. Failure to settle within this period will result in the loss of eligibility for the waiver.
• Mandatory AML/CFT shareholder screening – Companies must complete a shareholder background check in line with Cambodia’s Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT) framework. This screening is now a prerequisite for benefiting from the penalty-waiver policy and forms part of the government’s broader compliance enhancement measures.

Consequences of non-compliance

Companies that do not settle the single-year penalty and complete the required AML/CFT screening within the prescribed timeframe may face administrative restrictions, including:

• Classification as an inactive company in the MoC registry
• Inability to update corporate records or renew licences
• Limitations on exercising certain legal and commercial rights

Inactive status may also create practical challenges for banking, licensing and contractual arrangements.

What companies should consider

The penalty-waiver initiative provides an opportunity for companies with outstanding ADCE filings to regularise their position before accumulated penalties are reinstated. Given the fixed timeline and additional compliance requirement, early action is advisable to ensure all conditions are satisfied.

Businesses should review their ADCE filing history, confirm outstanding years (if any) and prepare the required documentation for both penalty settlement and shareholder background verification.