Legal and Tax Updates

Legal Update: New Minimum Capital Requirement for Casino Operations

Issue: No. 034P/21–29 November 2021

In general, any casino operation need to comply with the obligation imposed by Law on Management of Commercial Gambling (“Gambling Law”) and relevant regulations.

Recently, the Royal Government of Cambodia has issued a Sub-Decree No 166 on August 26, which provide a new minimum capital requirement for casino operations. According to the said Sub-Decree, the minimum capital for integrated commercial gambling centers is 800 billion riel (or equivalent to US$ 200 million) and 400 billion (or equivalent to US$ 100 million) for other casinos.

Under the Sub-decree, capital refers to the current assets, which include shareholders’ funds in the company as well as the immovable property of the company, excluding the followings:

  • Non-current assets and pre-paid expenses of the company
  • Unsecured credit and cash advances that are provided by the company and considered as current assets.
  • Amount to be paid by the director, co-ownership, or contributor to the company and considered as current assets.
  • The excessive amount of shares’ value that has been recorded and stored in the company’s account that is based on the market value.
  • Deficit of customer account by deducting uncollectible or difficult to collect debt, provision prepared in a format as determined by the Commercial Gambling Management Commission of Cambodia (“CGMC”).
  • The other components in the calculation of the company’s net capital which will be decided in a separate Prakas issued by the CGMC.

For casino operations that have obtained license before the Gambling Law, the minimum capital shall be increased according to the following schedule:

Phase 1

At Year 1 At least Khmer Riel 50,000,000,000 (US$ 12,500,000)

Phase 2

At Year 4 At least Khmer Riel 100,000,000,000 (US$ 25,000,000)

Phase 3

At Year 7 At least Khmer Riel 200,000,000,000 (US$ 50,000,000)

Phase 4

At Year 11 At least Khmer Riel 300,000,000,000 (US$ 75,000,000)

Phase 5

At Year 15 At least Khmer Riel 400,000,000,000 (US$ 100,000,000)

Please​ noted that any casino that has obtained licensed before the Law, the minimum capital requirement shall be met before applying for license renewal.

We hope that the above legal update is helpful for your investment and help you to invest more confidently.


The article is merely for general information purposes. It does not constitute a legal advice on the subject matter. If you have any question or need any assistance, please feel free to contact us:

SON Sokeng,


Managing Director

+855 12 885 870


Sokeng has more than 8 years of professional experiences in corporate, commercial, investment and capital market sector in Cambodia. He advised and assisted various companies in various legal compliance issues, major investment projects and in conducting legal due diligence for major M&A and IPO projects. He has led many legal counsel teams to advise and assist ACLEDA Bank Plc., Phnom Penh Autonomous Port and other SMEs in the process of listing and proposed listing on the Cambodia Securities Exchange (CSX).
NOEUM Sokvichhai,


Head of Corporate, Commercial and Investment Practice Group

+855 12 826 785


Sokvichhai has more than 6 years of experiences in labour, corporate, commercial and investment advisory in Cambodia. He actively advices and assists various businesses in commercial, tax, and labour registration, business licensing, products registration & distribution, business recapitalization & restructuring, and mergers & acquisitions transaction. He also has particular experiences in advising collective investment fund and trust business, investment incentives & qualified investment project, and labour & employment related issues. Sokvichhai also assists major business in preparing various commercial agreements. Currently, Sokvichhai is also leading Sithisak’s Investigation Team to investigate any labour related misconduct within client’s company.