Reporting obligations of unaudited financial statements
Subject: Accounting

In 2023, Accounting and Auditing Regulator (“ACAR”) has informs businesses and non-profit organisations in Cambodia of their non-compliant status with respect to the submission of their annual unaudited financial statements for the 2021 financial year.

This non-compliant issue was addressed by new Cambodian Prime Minister His Excellency Dr. Hun Manet the Prime Minister of the Kingdom of Cambodia during speech at the 19th Government-Private Sector Forum on 13 November 2023. The main points of Prime Minsiter’s speech on this issue were as follows:

Understanding the challenges of all enterprises in fulfilling their accounting and auditing obligations, the Royal Government has decided to introduce the following measures:

(1) Provide exemptions to enterprises not subject to independent audits that have not yet submitted their financial statements to the Accounting and Auditing Regulator until the end of February 2024;

(2) ACAR must be flexible in implementing the transitional penalties and explore ways to settle the private sector’s complaints or objections;

(3) Amend the Sub-Decree on transitional penalties for violations of the Law on Accounting and Auditing and the ministry order (Prakas) on the obligations to subject financial statements to an independent audit;

(4) Promote the dissemination of relevant laws and regulations and technical training on accounting standards to representatives and accountants of enterprises, general public and relevant public officials;

(5) Promote the preparation of glossary of accounting and auditing terms and the translation of accounting and auditing standards into Khmer, and

(6) Explore the possibility of developing Cambodian simplified accounting standards for small and medium taxpayer enterprises (Cambodian Simplified Accounting Standards) for a transitional period before moving towards implementing the international accounting standards.

Later on 7 November 2023, ACAR issued Notification No.033/23 AAR.N which states enterprises and non-profit organisations that had received transitional penalty letters from ACAR and who had not yet make payment before the date of issuance of this notification, may submit a protest letter to ACAR and attach a document with valid evidence to verify that it has already fulfilled its obligations no later than 31 December 2023. The deadline of 31 December 2023 was extended to 15 February 2024 under the Notification No.004/24 AAR.N issued on the 23 January 2024.