Cambodia

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

To the best of our knowledge, there is presently no specific mandatory legislation or regulation focusing on ESG disclosures for non-listed companies. Legislative requirements on corporate ESG disclosures in Cambodia are limited outside of Listed Companies, and the understanding of ESG and its focus are varied, but there are various mandatory disclosures at the project level as outlined in section A.2 below.

Listed Companies

Under the recently adopted Prakas on ESG Disclosure^[1], Listed Companies are required to make ESG disclosures, effective from 10 May 2026. 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, 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. The first set of such disclosures will be incorporated into Listed Companies’ annual reports in 2027, covering key activities, targets and metrics for 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 its annual report.

Issuers of sustainable finance products

The Securities Exchange Regulator of Cambodia (SERC) 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 to green assets and projects, as well as the performance and implementation of such green assets and projects. However, the guidance is non-legally binding and is pending implementing regulations.

Banking sector

The Association of Banks in Cambodia, the official organisation 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 and commitments as stated in the member’s E&S policies.

Project owners

Environmental and social impact reporting requirements, including periodic update reports to the Ministry of Environment (MOE), apply to an owner or person in charge of development projects, regardless of sector, which involve pollution sources, industrial zones, or natural resource development activities. Examples include mining, petroleum treatment, fuel storage, cement factory, battery manufacturing, and landfill projects.

For projects falling under certain categories and thresholds, an initial or full environmental and social impact assessment of the project must be conducted and submitted as a report (EIA Report) to the MOE.^[2]

EIA Reports must disclose environmental and social impacts, including but not limited to impacts on livelihoods of communities (that are dependent on natural resources), land use changes, and labour and working conditions, as well as mitigation measures.  

Under the Code on Environment and Natural Resources[3], the MOE must ensure that information in a full or initial EIA Report is made public and that affected stakeholders and local communities can obtain sufficient and clear information.

There are public participation and access to information rights regarding project implementation, except for confidential information.

It is envisaged that regulations will be developed requiring the disclosure of climate change-related data and information in respect of development projects.

Waste dischargers

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. A publicly accessible environment pollution control register will be created by the MOE to track pollutant release and transfers.

However, implementation is still in progress and regulations will be developed to specify the types of entities subject to the immediate data report obligation. However, this does not necessarily mean that the obligation is not enforceable in all circumstances, as the MOE may rely on the broader legal basis under the Code to take enforcement action on a case-by-case basis.

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

For Listed Companies, the focus is on the disclosure of corporate environmental and social risks (including climate change).

For banks and financial institutions which are part of the CSFI, the focus is also on environmental and social aspects.

For 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.

The Prakas on ESG Disclosure applicable to Listed Companies stipulates that sustainability reports that are based on “internationally recognised frameworks and standards” will be considered compliant with the reporting template prescribed under such Prakas. It is understood 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.

Although the ISSB Standards do not currently apply on a mandatory basis, they 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. Despite the effective date, based on our observations of their implementation thus far, the standards apply on a voluntary basis and are intended to assist Listed Companies, significant banks, entities required by law to produce annual financial statements compliant with the Cambodian International Financial Reporting Standards, as well as major exporting manufacturers that have tailored their compliance specifically for exporting countries.

The adoption of IFRS S1 and IFRS S2 also provides flexibility to companies that are subject to the Prakas on ESG Disclosure to prepare and present their sustainability reports by reference to IFRS S1 and IFRS S2. However, in practice, given the Prakas on ESG Disclosure adopts a double materiality approach (rather than the single materiality approach of the ISSB Standards), Listed Companies wishing to report in line with the ISSB Standards will likely need to develop a disclosure programme that satisfies both frameworks.

Although there has been no official announcement, it is understood that there are plans for the full implementation of IFRS S1 and IFRS S2 commencing in 2030 or later (depending on the type of entity).

The other requirements mentioned in section A.2 above are not expressly based on international standards.

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

For projects and businesses with operations that may adversely affect the environment and natural resources, the disclosure requirements are by nature designed to report on environmental and social impact.

Listed Companies

Under the Prakas on ESG Disclosure, the disclosure of GHG emissions (Scope 1 and 2) is mandatory for Listed Companies, while Scope 3 is 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 “internationally 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 require the disclosure of GHG emissions. However, as mentioned in section A.2 above, there are plans to develop climate-related reporting requirements for project owners, 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 and regulations do not impose requirements to obtain independent assurance of any ESG disclosure.

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 non-binding guide developed by the ASEAN Taxonomy Board (ATB), with Cambodia, being an ASEAN member state (AMS), represented on the ATB. 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, in April 2026, the National Bank of Cambodia launched the Sustainable Finance Taxonomy for the Cambodian Banking Sector, Version 1, which is Cambodia’s first sector-specific sustainable finance taxonomy. It provides a common classification framework for identifying sustainable economic activities and is intended to support transparency, consistency and credibility in sustainable finance, as well as reduce greenwashing risk in the financial sector.

The taxonomy is currently directed at the banking sector and is intended to help banks classify green or sustainable finance activities. The first version covers energy, transport, and buildings and construction, and does not appear to impose standalone ESG disclosure obligations (e.g. for banks to report on taxonomy-alignment).

Except for IFRS S1 and IFRS S2 (which are discussed in section A.5 above), we are not aware of any other plans to adopt international frameworks.

The government is currently developing the Guideline on ESG Disclosures, following the adoption of the Prakas on ESG Disclosure.  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 required from relevant ministries.

Yes. Cambodia’s Long-Term Strategy for Carbon Neutrality by 2050: A Bold Move Towards Climate Paris Agreement and Sustainable Development (LTS4CN) primarily serves as a roadmap to accomplishing the country's objective of becoming a carbon-neutral economy by 2050, with the Forestry and Other Land Use sector providing a total carbon sink of 50 MtCO2e. This leads to a lower estimate of total GHG emissions, at around 35 MtCO2e less in 2020, compared to Cambodia’s Nationally Determined Contribution.

The collection of baseline emissions information in LTS4CN is based on the following five key sectors (with key mitigation actions for each sector):

1. Agriculture;
2. Forestry and Other Land Use;
3. Energy;
4. Transportation; and
5. Waste.

Sectoral policy instruments also support Cambodia’s carbon-neutrality pathway. In the energy sector, the Power Development Master Plan 2022-2040 seeks to increase clean and renewable energy while strengthening energy security and affordability, and the National Energy Efficiency Policy 2022-2030 sets a national target to reduce total energy consumption by at least 19% by 2030. Cambodia has also adopted updated rules to facilitate rooftop solar deployment.

In the transport sector, Cambodia’s strategy includes electric mobility targets, including the electrification of 70% of motorcycles and 40% of cars and urban buses by 2050. The National Policy on Electric Vehicle Development 2024-2030 and recent customs duty reductions for electric vehicles, chargers, batteries and related components support this transition.

The National REDD+ Strategy 2017-2026 is a key sectoral policy, aiming to reduce deforestation and forest degradation, promote sustainable forest management and conservation, and support local communities. It also targets reducing annual deforestation by half compared with the 2006-2014 Forest Reference Level period by 2026.

The Circular Strategy on Environment 2023-2028 is also relevant. Its “Green” pillar includes expanding forest cover to 60% by 2050, reforestation and restoration, tree plantations in community protected areas, biodiversity conservation, and stronger protected area management. This aligns with the LTS4CN carbon neutrality pathway.

Cambodia does not currently have any mandatory carbon pricing tools, such as carbon taxes or an ETS. Cambodia has a voluntary carbon market where the MOE acts as a seller on behalf of the Royal Government of Cambodia. This market welcomes all sectors to purchase carbon credits from any programme for Reducing Emissions from Deforestation and Forest Degradation (REDD+ programmes), fostering conservation and sustainable management of forests, and enhancing forest carbon stocks in Cambodia. Cambodia has raised USD11.6 million in sale proceeds from three REDD+ programmes in Keo Seima, Southern Cardamom and Prey Lang.

Presently, there are no mandatory requirements for transition plans and/or their disclosure.

However, it is possible that mandatory requirements for transition plans and/or their disclosure may apply to project owners under future regulations of the Code on Environment and Natural Resources.

Presently, there are no mandatory requirements to set, meet and/or disclose climate-related targets.

However, it is possible that such mandatory requirements may apply to project owners under future regulations of the Code on Environment and Natural Resources.

EPR schemes

Cambodia has an EPR regime for e-waste under Prakas No. 2196/0325 dated 18 March 2025.^[1] The regulation requires manufacturers, importers and suppliers of electrical and electronic products to:

1. collect and manage post-consumer e-waste;
2. submit bi-annual reports on products and waste collected;
3. ensure treatment by licensed firms or re-export to the country of origin; and
4. comply with the penalty provisions outlined in the Code on Environment and Natural Resources.

Outside e-waste, broader EPR mechanisms for plastics and packaging waste remain under development. Although strategic environment-related policy frameworks, such as the 2021 National Circular Economy Strategy and Action Plan and the Sustainable Consumption and Production Roadmap 2022-2035, have endorsed the concept of EPR, practical implementation has been limited.

Eco-design / product standards

Cambodia has not adopted any general mandatory eco-design regime. However, it has introduced product-related energy-efficiency requirements for electrical appliances under Sub-Decree No. 254 dated 11 August 2023 on the Management and Improvement of Energy Efficiency of Electrical Appliances. This regime provides for energy-efficiency standards, product registration and energy-efficiency labelling for electrical appliances marketed in Cambodia, whether imported or locally manufactured.

There is currently no mandatory requirement for businesses in Cambodia to conduct human rights or environmental due diligence throughout their operations or supply chain, nor any proposal for such a law.

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 that project (with mitigation measures).   

In addition, the Inter-Ministerial Prakas No. 450 MEF.PrK dated 1 July 2026 (Joint Prakas) established a regulatory framework to prohibit the import, use, circulation and supply of goods linked to forced labour.

Although the Joint Prakas does not establish a due diligence regime, it requires importers to provide detailed information within ten working days of receiving a notification from relevant authorities, which may include information on production processes and compliance audit reports that demonstrate the absence of forced labour. Where goods are determined to be linked to forced labour, authorities may prohibit their importation, use, circulation, and supply in Cambodia, and impose further measures on importers such as suspension of import and export activities and other measures in accordance with applicable laws and regulations.

The effect of the Joint Prakas is therefore to encourage importers, distributors, manufacturers, and businesses operating international supply chains to proactively review their sourcing and supplier due diligence procedures and maintain adequate documentation in order to demonstrate supply chain transparency and the absence of forced labour.

Cambodian exporters and suppliers, particularly in the garment and manufacturing sectors, may also be indirectly affected by foreign mandatory human rights and environmental due diligence laws where they form part of the supply chains of in-scope overseas companies.

Cambodia’s policy support for sustainable finance and investment remains at an early stage but has developed across several areas. These include climate and transition roadmaps, such as the LTS4CN and NDC 3.0; a banking-sector sustainable finance taxonomy; capital-market measures, including mandatory ESG disclosure for listed companies and guidance on green, social and sustainability bonds; voluntary sustainable finance principles for banks; investment incentives for qualified green and climate-related projects; and emerging blended or concessional finance mechanisms, such as the Cambodia Climate Finance Facility.

Cambodia’s NDC 3.0 (launched in 2025) identifies mitigation, adaptation and enabling measures across key sectors and estimates financing needs of approximately USD32.2 billion in Cambodia for 2026–2035.

Following the adoption of the Prakas on EPR for E-Waste, Cambodia has taken steps towards expanding its circular economy regime through stakeholder engagement and pilot programmes. A draft sub-decree on plastic management is currently under review, which is expected to include controls on single-use plastics and EPR components.

In the financial sector, the direction of travel is toward encouraging sustainable and transition finance. Recent developments include the launch of the Sustainable Finance Taxonomy for the Cambodian Banking Sector in April 2026, the coverage of which is expected to expand in future iterations, and continued work to develop Cambodia’s sustainable finance ecosystem through ESG disclosure, sustainable bond guidance and issuer capacity-building.

Cambodia is also showing increased attention toward supply chain issues, particularly through the Joint Prakas on the prohibition of the import, use, circulation and supply of goods linked to forced labour. While this does not establish a general corporate sustainability due diligence regime, it indicates a move toward more targeted supply chain enforcement, particularly for importers and export-oriented businesses.

To the best of our knowledge, we are not aware of any recent examples of legal proceedings, regulatory actions or investigations against or into greenwashing in Cambodia.

There is no law or regulation specifically dealing with greenwashing. As the notion of greenwashing involves false, misleading or deceptive action, there are laws and regulations dealing with this issue such as:

1. Law on Consumer Protection;
2. Criminal Code;
3. Civil Code;
4. Sub-Decree No. 232 on the Management of Commercial Advertising on Products and Services; and
5. for securities traded on a securities market conducted in Cambodia:

(i) knowingly or recklessly conducting acts that create a false or misleading appearance of active trading in securities, or engaging in fictitious or artificial transactions that result in maintaining, inflating, or depressing the price of securities; and^[1]

(ii) making false or materially misleading statements or disseminating information that is false or materially misleading in relation to securities trading in Cambodia including statements or information that could induce people to subscribe to, buy, or sell securities or affect the price of securities trading.^[2]

Greenwashing may be claimed under the following grounds:

1. misrepresentation under the Civil Code;
2. fraud under the Criminal Code;
3. dishonest act under the Law on Consumer Protection;
4. misleading representation under the Law on Consumer Protection; and
5. advertisements which are misleading, deceptive, fraudulent, or likely to create confusion about the quality and safety of goods and services under Sub-Decree No. 232 on the Management of the Commercial Advertisement of Goods and Services.

For securities trading, likely grounds on which proceedings, actions or investigations can be instigated are false trading, market manipulation and false or misleading statements as mentioned in section C.2 above.

With the commencement of the ESG disclosure regime for Listed Companies, scrutiny of corporate sustainability disclosures may be expected to increase.