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August 13, 2026

Cambodia Increases Oversight of E-Wallet Customer Programs

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On August 6, 2026, the National Bank of Cambodia (NBC) issued a notice calling on business owners that issue electronic money, such as e-wallet accounts and stored-value membership cards, to notify the central bank within 90 days. The notice targets businesses that are not licensed banking or financial institutions or payment service providers, but have been issuing e-money to facilitate payments within their own networks. Failure to notify the NBC may result in legal action.

Background and Regulatory Basis

The NBC has observed that certain businesses, including cafes, restaurants, transportation companies, entertainment centers, and gas stations, have been issuing e-money through e-wallet accounts in mobile apps or membership cards to facilitate customer payments for products or services within their own networks. Customers create e-wallet accounts and load balances to pay for goods or services at the issuing business. The NBC describes this as “single-purpose e-money.”

Under the 1999 Law on Banking and Financial Institutions, providing payment facilities to customers forms part of the operations of banking and financial institutions and requires an NBC license. In addition, article 20 of the 2017 Prakas on the Management of Payment Service Institutions further prohibits legal entities other than banking and financial institutions and payment service institutions from issuing e-money.

However, article 20 also provides that issuing e-money in certain limited cases does not require a license, but the NBC must be notified in advance in writing. A business may issue single-purpose e-money without a payment service institution license provided it meets all the following conditions and submits written notice to the NBC:

  • The maximum balance per account is KHR 200,000 (approximately USD 50) or equivalent.
  • The total aggregate balance across all accounts does not exceed KHR 800 million (approximately USD 200,000) or equivalent.
  • The e-money is used to pay for products or services provided by a single business owned by a natural person (i.e., not a legal entity), and is only used to pay for that business’ own products or services (i.e., only within the issuer’s own network).
  • Any other conditions set by the NBC.

The NBC has emphasized that businesses operating these programs must submit written notification within 90 days of the NBC’s August 6 announcement. Businesses that exceed any of these thresholds, or that allow their e-money to be used across multiple merchants or networks, do not qualify for the notification-only exemption and may require a payment service institution license or other NBC authorization.

Key Restrictions on Single-Purpose E-Money

In addition to the threshold conditions above, the NBC highlighted the following restrictions:

  • E-wallet accounts created with these businesses are not savings accounts, and the NBC has stated clearly that these balances are not deposits.
  • Businesses are strictly prohibited from paying interest on balances held in e-wallet accounts.
  • Customers should not maintain a balance above the permitted limit, and customers bear the risks arising from opening and using these e-wallet accounts.

The NBC also urged the public to exercise caution when registering for e-wallet accounts through mobile applications operated by businesses that are not licensed banking or financial institutions.

Takeaways for E-Money Operators

Businesses currently operating single-network e-wallets, stored-value membership cards, loyalty balances, or prepaid account systems should take the following steps:

  • Determine whether the program qualifies as single-purpose e-money under the NBC’s criteria—for example, confirm that balances are used only for the issuer’s own products or services and not across third-party merchants.
  • Verify that the per-account balance cap of KHR 200,000 (approximately USD 50) and the aggregate balance cap of KHR 800 million (approximately USD 200,000) are not exceeded.
  • Submit written notification to the NBC within 90 days if the program falls within the exempted conditions.
  • Ensure that no interest is paid or accrued on e-wallet balances and communicate clearly to customers that balances are not deposits and the accounts are not savings accounts.
  • Consider what type of payment service institution license or other NBC authorization may be required if the business model falls outside the exempted conditions—for example, if the e-money can be used across multiple merchants or the balance thresholds are exceeded.

Businesses that have already been operating these programs without prior notification should act promptly to comply within the 90-day window indicated by the NBC to avoid potential legal action.

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