You are using an outdated browser and your browsing experience will not be optimal. Please update to the latest version of Microsoft Edge, Google Chrome or Mozilla Firefox. Install Microsoft Edge

November 14, 2019

Cambodia Enacts a New E-commerce Law and a Consumer Protection Law

Subscribe to Updates

In support of Cambodia’s rapidly growing economy, the Cambodian government enacted the Law on Electronic Commerce (E-commerce Law) and the Law on Consumer Protection (Consumer Protection Law) on November 2, 2019. Both of these new laws change the legal landscape in important ways for businesses under their purview. 

E-commerce Law

The E-commerce Law regulates domestic and cross-border e-commerce activities in Cambodia, establishes legal certainty for electronic transactions, and enacts a number of important protections for consumers.  

The E-commerce Law broadly applies to all commercial and civil acts, documents, and transactions executed via an electronic system, except those that are related to powers of attorney, wills and successions, and real estate. The E-commerce Law grants the Cambodian government the authority to issue further regulations to limit the law’s scope; thus it will be necessary to monitor whether other types of transactions are later excluded from the scope of the law. 

The E-commerce Law has 12 chapters, 67 articles, and one annex. 

  • The first chapter contains general provisions on the aim, purpose, and scope of the law, as briefly described above, and refers to the annex, which contains a glossary of 38 key terms used throughout the law.  
  • The second and third chapters deal with the validity and process of electronic communications, including clarifying the regulatory requirements for recognizing electronic agreements and e-signatures. These chapters also discuss certain technical matters, such as when and where electronic communications are considered sent and received. 
  • The fourth chapter addresses the security of electronic records and e-signatures, and specifically prohibits identity theft. 
  • The fifth chapter is material to electronic-commerce service providers and intermediaries. This chapter covers potential liabilities for third-party content on platforms and content takedown requests. Furthermore, service providers and intermediaries, possibly including foreign entities making their platforms accessible in Cambodia, may be subject to a licensing regime and codes of conduct in Cambodia.
  • The sixth chapter contains legal provisions on consumer protection on e-commerce platforms, including matters on adequate information requirements, scams, malicious codes, and data protection. Interestingly, this chapter specifically requires both domestic and foreign e-commerce businesses, regardless of their places of business, to comply with the legal obligations regarding unsolicited emails. 
  • The seventh chapter governs electronic acts and transactions by the Cambodian government, which may facilitate governmental agencies using online application forms in the future. 
  • The eighth chapter gives legal recognition to the use of evidence in an electronic form in Cambodian legal proceedings.
  • The ninth chapter further regulates electronic fund transfers and payments. Banking and financial institutions should be aware of this chapter as it imposes certain obligations and liabilities on them concerning electronic fund transfers and payments. For instance, when a banking and financial institution has received a customer’s notification that his or her electronic payment instrument has been lost or stolen, banking and financial institutions are now liable for any transactions occurring after the notification.
  • The tenth chapter designates the Ministry of Commerce and the Ministry of Posts and Telecommunications as the competent authorities who may issue warnings and disciplinary sanction decisions on e-commerce matters.
  • The eleventh chapter outlines a number of penalties, such as fines and imprisonments, on persons violating provisions of the E-commerce Law. 
  • The last chapter notes that the E-commerce Law will not be implemented until May 2, 2020, which leaves time for government agencies to prepare any necessary implementing regulations required under the law, and for private companies to prepare for compliance. 

As businesses have almost six months to prepare for the implementation of the E-commerce Law, we recommend that they familiarize themselves with the new requirements of the law and watch out for additional implementing regulations that are likely to be released before the full implementation of the law on May 2, 2020. 

Consumer Protection Law

The Consumer Protection Law establishes rules to guarantee the rights of consumers and to ensure that businesses conduct commercial competition in Cambodia fairly. The Consumer Protection Law applies to any person who conducts any trading activities with consumers in Cambodia, regardless of whether the trading activities are for profit. The law applies to the sale of goods, services, and real rights over immovable property.

The Consumer Protection Law has 11 chapters and 51 articles.

  • The first three chapters touch on introductory and general provisions, and explain the aims and purposes of the law and key definitions. Importantly, these chapters establish the National Committee on Consumer Protection (NCCP) as Cambodia’s competent authority for consumer protection and empower consumers in each industry to form an association to protect their interests.
  • The fourth and fifth chapters regulate unfair trading activities and unfair practices. These deal, for example, with false, misleading, or deceptive advertisements, and business models equivalent to pyramid schemes.
  • The sixth chapter sets out minimum information standards that businesses must meet in connection with consumers, such as labeling requirements. These minimum information standards will be more specifically set by the relevant industry regulators. One notable element of the standards is that all information must be provided in the Khmer language.
  • The seventh to the ninth chapters establish the procedures for the NCCP to receive consumer complaints, carry out investigations, and issue decisions, and the rules for appealing the NCCP’s decisions. 
  • The tenth and eleventh chapters present a number of penalties for non-compliance with the Consumer Protection Law, including disciplinary sanctions, fines, and imprisonment. 

The Consumer Protection Law became effective upon promulgation on November 2, 2019, and prudent businesses should therefore immediately review the law to understand their compliance requirements and prepare accordingly.

For more information, please contact our Phnom Penh office on [email protected] or at +855 23 964 210.

Related Professionals

Industries

Life Sciences

Technology

Practices

Banking and Finance

Regulatory Affairs

Location

RELATED INSIGHTS​ 

June 17, 2026
Thailand’s new labeling requirements for medical devices, which include for the first time a unique device identification (UDI) requirement for software as a medical device (SaMD), take effect on June 20, 2026. The Notification of the Ministry of Public Health regarding Criteria, Methods, and Conditions on Labeling and Instructions for Use for Medical Devices 2025, which replaces a similar notification from 2020, was published in the Government Gazette on December 22, 2025. To ensure clarity, modernity, and patient safety, the regulation requires domestic manufacturers and importers to provide labels and instructions for use (IFU) that are clearly legible, complete, and free of false or misleading claims. It also permits IFU to be provided in electronic format, such as via QR codes, websites, or other digital channels—directly relevant to SaMD, where physical labels are impractical and electronic presentation is the natural medium. The notification distinguishes two categories for labeling language. Home-use medical devices (for lay users outside healthcare facilities) must have labels and IFU in Thai. Professional-use medical devices may display labels and documentation in either Thai or English. This distinction is significant for SaMD developers: software intended for clinical professionals may use English-language interfaces and IFU, while consumer-facing health applications must provide Thai-language content. Labeling and UDI Requirements Labels and IFU must include, at a minimum: Product name and intended purpose Quantity or volume Name and address of domestic manufacturer or importer Thai FDA approval number Lot, version, or serial number Manufacturing date and expiry date For SaMD, the version number requirement is particularly relevant. The regulation also mandates display of a UDI code for SaMD in risk category 2 (moderate-risk), category 3 (moderate- to high-risk), and category 4 (high-risk), according to Thailand’s medical device risk classification system (which complies with the ASEAN Medical Device Directive and the EU
Read More
June 15, 2026
The surge in AI development has led to a desperate demand for large, high-quality training data. However, real-world data can be expensive to collect, difficult to access, and often subject to strict privacy and regulatory constraints. Synthetic data, which consists of artificially generated records that replicate the statistical properties of real-world data without reproducing specific individuals’ information, provides an appealing solution by generating artificial datasets at scale without relying on identifiable personal information. It combines speed, cost efficiency, and regulatory compliance, making it a sensible alternative for organizations seeking to reduce risks while maintaining data utility. When properly anonymized, synthetic datasets may fall outside the scope of laws such as the EU’s General Data Protection Regulation (GDPR) or Thailand’s Personal Data Protection Act (PDPA), reducing compliance burdens while still supporting high-quality model training. However, relying on synthetic data without rigorous legal due diligence could be a strategic mistake. It replaces one set of known risks (scraping, direct privacy liability) with a new set of complex liabilities. The narrative that synthetic data is a “silver bullet” for privacy and IP compliance is dangerous and could be misleading. While synthetic data addresses data scarcity, it also introduces new legal uncertainties. Legal counsel should anticipate downstream risks arising from compromised data sources. Models trained on unlawfully obtained data may need to be decommissioned, even if their outputs appear lawful. What is synthetic data? Synthetic data refers to artificially generated information created using AI techniques such as deep learning and generative models. Instead of copying real records, it reproduces the statistical patterns and relationships found in the original dataset. Synthetic data generally falls into three categories: Fully synthetic data – Entirely new data points generated from learned patterns. The model studies the structure of the original data and produces records that resemble real-world
Read More
June 11, 2026
Thailand’s Electronic Transactions Development Agency (ETDA) has released a revised draft Electronic Transactions Act (ETA) for public hearing from May 12, 2026, to June 15, 2026. This is not merely an amendment to certain provisions of the current ETA, but a comprehensive redrafting of the entire act. The revised draft ETA introduces several significant changes from the current framework, with practical implications for businesses operating in Thailand. Unified Coverage of Public and Private Sectors The current law segregates government transactions into a separate chapter with distinct rules. The draft ETA eliminates this division, defining “transaction” to encompass civil and commercial juristic acts as well as administrative procedures, administrative contracts, and other acts of government agencies. Enhanced E-Signature Definition The definition of “electronic signature” is broadened to expressly include biometric data and refocused on identifying the signatory and demonstrating intent regarding the content of the electronic data. Shift in Burden of Proof When a party challenges the reliability of electronic data created using a “trusted electronic method” or a method prescribed by the ETDA, the burden of proof and the cost of proving unreliability shifts to the challenger. Introduction of New Digital Method Concepts The draft ETA introduces several new digital method concepts that are not currently recognized under the existing ETA framework. These include: Electronic timestamping (e-timestamp) Electronic registered delivery Electronic company seals Electronic stamp duty compliance Electronic identity authentication and verification Electronic transferable records (electronic bills of lading, promissory notes, and similar negotiable instruments) Recognition of Automated Systems and Electronic Contracting The draft ETA expressly recognizes the legal validity and enforceability of contracts formed through automated systems, including contracts concluded entirely between automated systems or between an automated system and a person. A party may not deny the binding effect of such contracts solely because no human review
Read More
June 5, 2026
On May 25, 2026, Vietnam’s Ministry of Health issued Circular No. 16/2026/TT-BYT governing free-of-charge medicine support programs for medical establishments (Circular 16). Circular 16 will take effect on July 10, 2026, replacing Circular No. 31/2018/TT-BYT, which currently regulates the same subject matter. Circular 16 introduces several significant changes compared to the existing legal framework. Removal of Prior Approval Requirement Under the current regulations, free-of-charge medicine support programs are divided into two categories: (1) entirely free-of-charge provision of medicines for all types of drugs and (2) partially free-of-charge provision applicable only to brand-name drugs under patent protection or drugs whose generic products with identical active ingredients and dosage forms are available in Vietnam. Under the current regulations, partially free-of-charge programs are subject to mandatory registration with the competent authority, while entirely free-of-charge programs could be implemented without prior approval. A key reform under Circular 16 is that it stipulates only entirely free-of-charge medicine support programs applicable to all types of medicines, thereby eliminating the partially free-of-charge category. In addition, free-of-charge medicine support programs may be carried out solely based on a written agreement between the pharmaceutical company and the medical establishment, without any requirement for prior approval from competent authorities prior to implementation. Written Agreement Requirements Circular 16 requires the pharmaceutical company and medical establishment to enter into a written agreement in accordance with a prescribed template. This agreement must include the following compulsory information: Information on the supported medicines Form of support (entirely free-of-charge provision to patients) Quantity of medicines provided Target patient groups and applicable indications Duration of the program Rights and obligations of each party Transitional provisions on the protection of patients’ rights upon completion of the program The agreement may contain other contents as agreed by the parties, provided that these do not contradict applicable laws.
Read More