Cambodia

Listed Companies

Companies listed on the “main board” (Listed Companies) of the Cambodia Securities Exchange (CSX) are subject to certain ESG-related disclosure obligations. The requirements are described in section A.2 below.

Non-Listed Companies

To the best of our knowledge, there is presently no specific mandatory legislation or regulation focusing on ESG / sustainability disclosures for non-listed companies.

Legislative requirements on ESG disclosure in Cambodia are limited, and the understanding of ESG and its focus are varied, but there are various voluntary initiatives and significant upcoming developments for Listed Companies with the adoption of the Prakas on ESG Disclosure outlined in section A.2(b) below.

In addition, there are some regulatory frameworks that can be considered as supporting various aspects of ESG practices as described in section A.2 below for enterprises generally and for the securities and banking sectors.

Cambodia does not currently have a unified ESG code. Instead, the applicable regulations are fragmented and spread across various legislative instruments. This fragmented regulatory landscape can be synthesised as follows:

From a corporate governance perspective

1. For all enterprises, regardless of sector:
   
   All commercial enterprises incorporated in Cambodia are required to file public Annual Declarations of Commercial Enterprise (ADCE) pursuant to the Prakas on ADCE^[1] to inform the Ministry of Commerce, among other things, of any changes to their management, directors and shareholding.
2. For the securities sector:
   
   (i) Corporate governance-related disclosure requirements apply to public limited companies and permitted entities (being a legal entity, other than a public limited company, incorporated in Cambodia, that is permitted in accordance with the provisions of the Law on the Issuance and Trading of Non-Government Securities (Securities Law) and other regulations to offer and issue securities to members of the public in Cambodia) which are or have been approved as an issuer or a listed company.
   
   (ii) Listed companies are also required to notify investors of any changes to directors or key management of the company and to publish information on corporate governance.
   
   Under the recently adopted Prakas on ESG Disclosure^[2], Listed Companies of the CSX will be required to make ESG disclosures, effective from 10 May 2026 (being 24 months after the adoption of such Prakas). Voluntary submission is encouraged during this interim period. The Prakas outlines two disclosure elements. Table A sets out mandatory disclosures on the “environmental and social risks and impacts” faced by and attributable to Listed Companies, such as the key corporate social, environmental, and climate risks they have identified, as well as their strategy for addressing them, including key metrics and targets. The mandatory disclosures also include corporate social impacts (e.g. policies on forced labour and collaboration with local communities), environmental impacts (e.g. water use), and climate impacts (e.g. Scope 1 and Scope 2 GHG). Table B presents optional disclosures. Listed Companies may provide supplementary disclosures in Table B as deemed necessary.
   
   These disclosures must be made publicly accessible and incorporated into the company’s annual report in 2027, covering its key activities and targets and metrics of 2026. Where the Listed Company prepares and discloses sustainability reports based on internationally recognised frameworks and standards, these reports shall be considered compliant with the reporting template prescribed by this Prakas. The Listed Company can choose to attach the whole sustainability report, or include a statement providing a link to the sustainability report in their annual report.
   
   (iii) The Securities Exchange Regulator of Cambodia (SERC), formerly the Security and Exchange Commission of Cambodia, has issued the Detailed Guidance for Issuing Green Bonds in Cambodia and Guidance on the Issuance of Green Bonds, Social Bonds, and Sustainability Bonds, under which an issuer of green bonds is expected to report and provide updates regarding the allocation of bond proceeds on green assets and projects, as well as the performance and implementation of such green assets and projects. However, the guidance is of a non-legally binding nature and is pending implementing regulations.
   
   (iv) Cambodia has taken significant steps towards aligning with international ESG reporting standards by adopting IFRS S1 and IFRS S2. Both instruments have been fully adopted by the Accounting and Auditing Regulator in Cambodia, without modification, and are effective for annual reporting periods after 1 January 2024. It is worth noting that despite the effective date, the scope of application depends on how the regulators implement the adoption. Based on our observations on their implementation, as of now, they apply on a voluntary basis and are intended to assist Listed Companies, significant banks, and entities required by law to produce CIFRS (Cambodian International Financial Reporting Standards) compliant annual financial statements, as well as major exporting manufacturers that have tailored their compliance specifically for exporting countries. It is planned that the full implementation of IFRS S1 and IFRS S2 will commence in 2030 or later, depending on the types of entities.
   
   The adoption of IFRS S1 and IFRS S2 provides flexibility to companies that are subject to the Prakas on ESG Disclosure. Specifically, it allows them to prepare and present their sustainability reports by reference to IFRS S1 and IFRS S2 as a means of meeting the disclosure requirements outlined in the Prakas on ESG Disclosure, thus integrating their sustainability reporting into their annual reports. See also our response to section A.5 below.
3. For the banking sector:
   
   (i) The corporate governance requirements for banks and financial institutions are set out in the Prakas on Governance in Banks and Financial Institutions, Prakas on Fit and Proper Regulatory Requirements for Applying Entities and Licensed Banks and Financial Institutions, and Prakas on the Internal Control of Bank and Financial Institutions.
   
   (ii) Any changes to the corporate governance (i.e., shareholders, directors, senior management etc.) of a bank or financial institution are subject to approval from or notification to the National Bank of Cambodia (which is not a disclosure to the public, unless they are listed companies as discussed in item (b) above).
   
   (iii) The Association of Banks in Cambodia, the official organization representing the country’s private banking sector, has developed the Cambodian Sustainable Finance Initiative (CSFI) with support from the National Bank of Cambodia and the United States Agency for International Development. Currently, there are 47 private banks and financial institutions which have voluntarily adopted the CSFI and have pledged to abide by the CSFI Implementation Guidelines, which cover environmental and social (E&S) reporting (internal and external) that may include reporting on E&S performance of business activities and operations (including climate reporting), the implementation of relevant standards, and the fulfilment of other E&S objectives/commitments as stated in the member’s E&S policies.
   
   From a social perspective
4. For all enterprises, regardless of sector:
   
   (i) Under the Prakas on Labor Self Inspection, ^[3] enterprises registered with the Ministry of Labor and Vocational Training must make a self-declaration twice a year to inform the ministry of, among other things, the working conditions and benefits provided to employees, the occupational health and safety framework in place, and the social security registration of the employees.
   
   (ii) See also the social impact assessment for certain development projects as mentioned in section A.2(e) below.
   
   From an environmental perspective
5. For development projects, regardless of sector, which involve pollution sources, industrial zones, or natural resource development activities, e.g. mining, petroleum treatment, fuel storage, cement factory, battery manufacturing, and landfill:
   
   (i) Environmental and social impact reporting requirements apply to an owner or person in charge of such projects, including periodic update reports to the Ministry of Environment (MOE).
   
   (ii) An initial or full environmental and social impact assessment of the project also has to be conducted and submitted as a report to the MOE for projects falling under certain categories and thresholds^[4], e.g. projects developed in a tourism area of more than fifty hectares.
   
   These reports must address not only the environmental impacts but also social impacts, including but not limited to impacts on livelihoods of communities (that are dependent on natural resources), land use changes, as well as labour and working conditions.
6. Requirements under the Code on Environment and Natural Resources^[5]:
   
   (i) Certain reporting and disclosure requirements in respect of a full or initial environmental impact assessment report:

• • The MOE must ensure that information on a full or initial environmental impact assessment report is made public and that affected stakeholders and local communities can obtain sufficient and clear information.
  • The project owners must publish at least one copy of the full or initial environmental impact assessment report as well as mitigation measures for the project.
  • There are public participation and access to information rights on the project implementation, except for confidential information.

(ii) Climate change reporting requirements for development projects:

• • Under the Code on Environment and Natural Resources, regulations will be developed on how data and information on climate change may be produced and managed, one of which could be data/information on GHG emission reduction by project owners, although the Code on Environment and Natural Resources does not expressly provide for this.
  • Project owners are required to report on “financing used for activities related to climate change” upon request by the MOE.
    
    The Code on Environment and Natural Resources does not define the term “project owner” nor specify any sector, category and/or threshold for the project.

(iii) Environmental disclosures by site owners engaged in production, commercialisation, or services that discharge waste at high risk of environmental pollution:

• • Under the Code on Environment and Natural Resources, site owners engaged in production, commercialisation, or services that discharge waste at high risk of environmental pollution (through hazardous substances and hazardous waste) are required to provide immediate data reports on pollutant release or transfer to the environment. There will be regulation on the types of entities that are subject to this immediate data report obligation.
  • An environment pollution control register will be created by the MOE and be accessible to the public in downloadable form.

All requirements described in section A.2 above are mandatory, except the disclosure requirements under the CSFI Implementation Guidelines and the SERC guidance relating to green bonds, which are non-binding in nature.

The requirements under the Prakas on ESG Disclosure will become mandatory with effect from 10 May 2026.

In light of our answer to section A.2 above:

1. In general, for any sector — the focus is primarily on the disclosure of corporate governance and social aspects.
2. For the securities sector — the focus is on the disclosure of corporate governance, environment risks, and corporate social risks.
3. For the banking sector — the focus is on the disclosure of corporate governance. For banks and financial institutions which are part of the CSFI, the focus is also on environmental and social aspects.
4. For infrastructure projects and businesses with operations that may adversely affect the environment and natural resources — the focus is on the disclosure of environmental and social impact. It is also anticipated that the focus will expand to climate change.

There is no information available to the public to confirm whether any of the requirements mentioned in section A.2 above are based on any international standards.

However, the Prakas on ESG Disclosure stipulates that sustainability reports that are based on “international recognised frameworks and standards” will be considered compliant with the reporting template prescribed under such Prakas. It is understood from the intention of the drafter of the Prakas on ESG Disclosure that the government is receptive to any credible international standard. However, if any required element in Table A of the Prakas on ESG Disclosure is not covered by the chosen standard, companies may be requested to provide additional information to address those gaps.

Listed Companies

Although the Prakas on ESG Disclosure does not explicitly provide any reference to the principle of single or double materiality, the structure and content of the disclosure elements in both Table A and Table B reflect the adoption of a double materiality approach. The disclosure requirements are intended to capture both the financial impact of ESG risks on the Listed Companies, and the broader environmental and social impacts resulting from their operations.

Non-Listed Companies

There is no information available to the public to confirm the materiality approach under the requirements mentioned in section A.2 above.

Listed Companies

Under the Prakas on ESG Disclosure, the disclosure of GHG emissions (Scope 1 and 2) will be mandatory for Listed Companies, while Scope 3 will be supplementary/optional. The legal framework has not, at this stage, set out detailed requirements regarding the methodology for measurement. However as mentioned, sustainability reports that are prepared based on “international recognised frameworks and standards” are considered compliant with the new regime.

Non-Listed Companies

To the best of our knowledge, the current regime, including the Code on Environment and Natural Resources, does not expressly provide for requirements for the disclosure of GHG emissions. However, as mentioned in section A.2(f) above, as part of a climate change reporting requirement, data and information on climate may be further regulated, which could include information on GHG emissions.  

Listed Companies

The Prakas on ESG Disclosure does not require independent assurance of ESG disclosures. The boards of Listed Companies are responsible for ensuring the completeness and accuracy of ESG disclosures; however, an independent third-party may be voluntarily appointed to review the completeness and accuracy of information in the prescribed tables. If an independent third-party is appointed, such appointment and related details of the third-party shall also be disclosed to the public.

Non-Listed Companies

Current laws/regulations do not impose requirements on independent assurance of any ESG disclosure. However, in order to fulfil certain requirements described in section A.2(e) above, an accredited service provider has to be retained, e.g. to conduct “a full environmental and social impact assessment” and prepare a report on such for submission to the MOE.

The Cambodian subsidiaries of a number of multinational companies report on their ESG commitments. Corporates such as Heineken Cambodia and Smart Axiata are at the forefront of implementing a reporting structure based on the GRI Standards.

The ASEAN Taxonomy on Sustainable Finance is a legally non-binding guide developed by the ASEAN Taxonomy Board (ATB), with Cambodia, being an ASEAN member state (AMS), represented on the ATB.

The two core elements of the taxonomy are: 

1. the “foundation framework” (applicable to all AMS) that provides for a qualitative assessment of activities, and the “Plus Standard” with metrics and thresholds to further qualify and benchmark eligible green activities and investments; and
2. the environmental objectives (universal and applicable to all AMS) to be implemented in alignment with national environmental laws, and to include climate change and adaptation, the protection of a healthy ecosystem and biodiversity, and the promotion of resource resilience and transition to a circular economy.
   
   Each AMS is expected to develop its own taxonomy based on the ASEAN Taxonomy on Sustainable Finance, as the aim is to develop a harmonised system and practice of sustainable finance across ASEAN.
   
   As of 2025, Cambodia has not officially adopted a national ESG taxonomy. However, such a national ESG taxonomy has been in the government’s pipeline. The National Bank of Cambodia, in partnership with the International Finance Corporation, has been developing a draft Sustainable Finance Taxonomy, with a public consultation in April 2025. The draft taxonomy serves as a classification system for sustainable economic activities and investments, focusing on three priority sectors: energy, construction, and transport. The adoption timeline for the draft taxonomy remains undisclosed, as it is still under public consultation. Further revisions will be made based on input from relevant stakeholders, including sectoral authorities, financial institutions, associations, and investors.

To the best of our knowledge, we are not aware of any other plans to adopt other international frameworks, except the IFRS S1 and IFRS S2 (which are discussed in section A.2(b)(iv) above).

The government is currently developing the Guideline on ESG Disclosures, following the adoption of the Prakas on ESG Disclosure, as outlined in section A.2(b)(iii).  A public consultation was conducted in July 2025 to gather feedback from key stakeholders, particularly related authorities and Listed Companies. A timeline for finalisation of the guideline has not yet been set, as further technical input is still required from relevant ministries.

To the best of our knowledge, there is currently no proposal to mandate businesses in Cambodia to conduct human rights or environmental due diligence throughout their supply chain. However, Listed Companies will be required to report on their forced labour policies under the Prakas on ESG Disclosure, and certain development projects will trigger the requirement to produce an environmental and social impact assessment for the project (with mitigation measures).