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Accounting and Auditing Alert
ACAR Alert 2025
08 Sep 2026 4 min read
On 18 August 2026, the Accounting and Auditing Regulator (ACAR) issued Prakas No. 063, introducing new requirements for the submission of annual financial statements and independent audits. This Prakas replaces Prakas No. 563 dated 10 July 2020.
The Prakas prescribes the filing obligations for annual financial statements, establishes the criteria for mandatory independent audits, and introduces administrative sanctions for non-compliance.
Key Highlights
1. Filing requirements
Entities not subject to an independent audit must file annual financial statements with ACAR within 3 months and 20 days after the financial year-end.
Entities subject to an independent audit must file their audited financial statements, together with the independent auditor's report, within 6 months and 20 days after the financial year-end.
2. Criteria for independent audit
Enterprises that are subject to a mandatory independent audit:
Public enterprises;
Publicly accountable enterprises;
Qualified Investment Projects (QIPs);
Branches of foreign companies;
Casino operators; and
Certain licensed real estate and construction development businesses.
In addition, enterprises meeting at least two (2) of the following criteria are subject to an independent audit:
Annual turnover exceeding sector-specific thresholds;
Total assets of KHR 10 billion or more; and
Average workforce of 100 employees or more.
3-year transition rule: enterprises that no longer meet the independent audit criteria under the updated thresholds must continue to fulfill their independent audit obligations for a transitional period of three (3) consecutive years if their annual turnover remains at or above KHR 5 billion.
3. Administrative penalties
Late filing may result in penalties amounting to:
Enterprises: KHR 2,000,000 per month of delay.
Not-for-profit entities: KHR 1,200,000 per month of delay
The aggregate penalty shall not exceed the following amounts:
Enterprises: KHR 12,000,000.
Not-for-profit entities: KHR 7,200,000
4. Effective date
The filing requirements remain applicable from the effective date of the Prakas. The revised independent audit obligations prescribed under Articles 8 to 11 shall apply commencing from the 2026 accounting period onwards.
Our recommendation
Prakas No. 063 introduces a revised regulatory framework governing both the filing of annual financial statements and the determination of entities subject to mandatory independent audit requirements. Enterprises and not-for-profit entities should assess their compliance status in a timely manner to ensure adherence to the applicable filing deadlines, audit obligations, and reporting requirements imposed by ACAR.
Should you need our assistance in assessing your compliance status when preparing your financial statements for submission, please feel free to contact us.
On 23 December 2025, the Accounting and Auditing Regulator (“ACAR”) issued a notification to remind all enterprises regarding the obligation to submit annual financial statements for the year 2025 to ACAR in line with the Law on Accounting and Auditing 2016 and related regulations. The notification contained the following key points:
1. For those enterprises and non-profit organisations that are not subject to have financial statements audited shall submit their annual financial reports by 20th April 2026. For the entities that have the approval to have their account closing period different from 31st December, shall submit their annual financial reports no later than 3 months and 20 days from the date of account closing.
2. For those enterprises and non-profit organisation that are subject to have financial statements audited shall submit audit report by 20th July 2026. For the entities that have the approval to have their accounting closing period different from 31st December, shall submit their audit report no later than 6 months and 20 days from the date of account closing.
The notification further provides the following instructions:
All entities shall properly prepare accounting records.
Shall prepare financial reports no later than 3 months from the date of account closing by following the prescribed accounting standards.
In order to promote compliance and provide convenience for submission of the financial statements in E-filing system, those entities who are not subject to audit shall prepare the financial statements using the reduced disclosure framework, the digital financial platform, and the prescribed chart of account.
Shall finish the audit and issue the audit report no later than 6 months from the date of accounting closing for those who fall under the threshold of audit requirement.
For entities that do not have a FIN number with ACAR shall register the FIN number by following the E-filling procedure.
For entities that change status from audit to non-audit, shall request to change FIN number with ACAR before 60 days from the deadline to submit the financial statements.
All entities can use any licensed accounting firm as the representative to assist with the compliance obligation. The accounting firms shall have the authorisation letter from the owners/directors of the entities to perform the work. The owners/directors of the entities must hold responsibility for all the actions of the representative.
All entities shall pay the government fee for maintaining the financial statements with ACAR based on Prakas 002 dated 15 January 2025.