Requirements for Actual Investment Capital of Manufacturing Qualified Investment Projects

The Council for the Development of Cambodia ("CDC") has issued Instruction No. 1555/26 CIB dated 27 August 2026 to clarify the requirement that manufacturing Qualified Investment Projects ("QIPs") must implement actual investment capital at or above the minimum investment threshold prescribed under the Law on Investment and its implementing regulations.

The Instruction directs relevant departments of the Cambodian Investment Board ("CIB") to strengthen the review and monitoring of manufacturing QIPs to ensure compliance with the minimum investment capital requirement.

For this purpose, investment capital refers to the investment made in the project, excluding land costs and working capital.

1.Manufacturing QIPs must implement actual investment capital (“the Required Investment Capital”) at or above the applicable minimum investment threshold prescribed in the Negative List under Sub-Decree No. 139 on the Implementation of the Law on Investment of Cambodia. This requirement applies to both existing manufacturing QIPs and manufacturing QIPs registered after the issuance of the Instruction as follows:

• For manufacturing QIPs registered before 27 August 2026, the Required Investment Capital must be fully invested within three (3) years from the date of issuance of the Instruction (27 August 2026).
• For manufacturing QIPs registered after 27 August 2026, the Required Investment Capital must be fully invested within three (3) years from the date of issuance of the QIP Registration Certificate.

2.Relevant CIB departments will review and verify compliance with this requirement as part of their ongoing monitoring and administration of manufacturing QIPs.

Failure to comply with the minimum investment capital requirement may result in the withdrawal of the QIP Registration Certificate.

The Instruction reflects the CDC's intention to ensure that manufacturing projects benefiting from QIP incentives have implemented the level of investment approved under the investment framework.

This Instruction signals increased scrutiny by the CDC on whether manufacturing QIPs have fulfilled their approved investment commitments and met the minimum investment capital requirement within the prescribed timeframe.

Investors should review their investment status and maintain adequate records and supporting documentation to demonstrate compliance. Particular attention should be given to ensuring that the actual investment capital, excluding land costs and working capital, meets the required threshold.

KPMG can assist investors in assessing their compliance status, reviewing supporting documentation, and addressing regulatory considerations relating to QIP investment capital requirements and ongoing compliance obligations.