Cambodia

The framework, however, remains incomplete for entities outside the bank and payment-institution channel. Legal entities other than banks and payment institutions that wish to act as a Crypto Asset Service Provider must obtain a separate NBC licence, but the detailed approval procedures for that licence, specified under Clause 20 of the Prakas, are to be set out in a further regulation that had not been published as of this cycle. This is a materially important distinction: the Prakas itself is in force, and the bank/PSP permission it grants is operative now, but the CASP licensing pathway for non-bank, non-PSP entities is enacted in principle but not yet effective in practice, pending the implementing procedures. Any assessment of Cambodia as a market for a standalone crypto exchange, custodian, or other CASP-type business should treat this pathway as currently theoretical rather than operative.

Consistent with this incomplete build-out, market access in practice remains narrow and sandbox-confined. Only two platforms, Royal Group Exchange and Cambodian Network Exchange, currently operate as authorised crypto platforms, and both do so under the NBC's FinTech Regulatory Sandbox rather than under a general licensing regime. This sandbox-scoped market structure indicates Cambodia's crypto-licensing regime today functions more as a controlled pilot than as an open licensing market, notwithstanding the Prakas's broader in-force permission structure for banks and PSPs.

The regulatory direction is assessed as liberalising overall: Cambodia has moved from prohibition to permission for the bank/PSP channel, has established, if not yet operationalised, a CASP licence category for other entities, and has signalled further legislative ambition through the August 2026 Inter-Ministerial Working Group mandate to draft a comprehensive Law on the Management of Virtual Assets/Digital Assets. But the licensing framework's current state is best characterised as transitional and structurally incomplete: a functioning permission channel for banks and PSPs, a named-but-not-yet-operative licence category for other CASPs, and a sandbox-scoped market of exactly two authorised trading platforms. Institutions or entities evaluating Cambodia for crypto-business market entry should size their assessment to which of these three tracks is actually relevant to their intended business model, since the maturity, evidentiary basis, and regulatory certainty differ materially across the three.

From a token-classification-adjacent perspective, though full classification detail sits outside this module's authorised scope this cycle, it is worth noting the licensing framework interacts directly with the Prakas's broader asset taxonomy: bank and PSP permission to provide cryptoasset services is calibrated to which category of asset the service touches, meaning the licensing question and the token-classification question are not fully separable in practice even though they are tracked as distinct modules in this monitor's spine.

Outlook

The single clearest signal that would move Cambodia's crypto-licensing regime from transitional to operative for non-bank entities is publication of the Clause 20 CASP licensing-procedure regulation; until that occurs, the CASP pathway should be treated as enacted but not yet effective rather than as a genuinely available market-entry route. The forthcoming comprehensive Law on the Management of Virtual Assets/Digital Assets, whose drafting process was initiated in August 2026, is the second major item to watch, given the possibility that it supersedes or restructures the current Prakas-based framework entirely; no draft text or implementation timeline has been confirmed, and this is assessed at a multi-year uncertainty band. Whether the current two-platform sandbox model is retained, expanded, or folded into a general licensing regime once Clause 20 procedures are published is a further open question with direct market-structure implications for prospective entrants.