Starting an e-commerce business in Cambodia

TL;DR

• E-commerce in Cambodia is not a legal structure: it is an activity you carry on through an ordinary company (usually a Co. Ltd.), plus an e-commerce permit or licence issued by the MoC under the Law on Electronic Commerce (2019) and its Sub-Decree No. 134.
• A permit is for individuals and sole proprietorships, a licence for legal persons and branch offices of foreign companies; you apply online on the official portal ecommercelicensing.moc.gov.kh. Below the “small taxpayer” threshold (~62,500 USD annual turnover) you are exempt from the permit but must notify the MoC of your activity.
• On tax: 10% VAT on sales in Cambodia, 0% on exports, plus a specific non-resident e-commerce VAT regime for digital goods/services (see the VAT guide). Payment in riel or USD, increasingly via KHQR / Bakong.

Overview

“Doing e-commerce” in Cambodia means two distinct things:

1. A company (the legal shell) that holds the activity, signs contracts, invoices and pays tax.
2. An e-commerce authorisation: the permit or licence from the MoC that specifically allows online selling, required on top of ordinary registration.

So you are not creating an “e-commerce company” as a special corporate form: you create an ordinary trading company whose business object includes online selling, then apply for the e-commerce permit/licence. For the choice of structure itself, see the structures comparison.

Step 1 — Set up the company (foundation)

The vast majority of expat e-commerce operators run through a Private Limited Company (Co. Ltd.): limited liability, 100% foreign capital allowed for trading, minimum capital 4,000,000 KHR (~1,000 USD). Full detail and the 7 setup steps in the Co. Ltd. guide.

The foundation is set up through the CamDX single portal:

1. Registration with the MoC → Certificate of Incorporation, with a business object covering online / distance retail.
2. Tax registration with the GDT → TIN (tax number) and VAT account.
3. Patent tax paid for the year. See the patent tax guide.

At this stage you have a compliant company, but not yet the right to sell online: the e-commerce permit/licence is still missing.

Step 2 — The MoC e-commerce permit / licence

This is the sector licence specific to e-commerce. It stems from the Law on Electronic Commerce, promulgated on 2 November 2019, completed by Sub-Decree No. 134 (27 August 2020) on classification, formalities and issuance procedures, and by MoC Prakas No. 290 (9 October 2020) on the required documents, timelines and renewal.

Who must obtain it

The regime distinguishes two categories:

The obligation covers anyone doing e-commerce in Cambodia, including:

• Cambodian entities selling online overseas from Cambodia;
• foreign entities selling into Cambodia;
• intermediaries (marketplaces, platforms connecting sellers and buyers).

How to apply

The application is filed online on the official portal ecommercelicensing.moc.gov.kh, or on paper at the MoC Department of Business Registration. Prakas No. 290 sets the list of documents, review timelines and renewal procedure.

Step 3 — Consumer protection and online obligations

E-commerce triggers specific obligations under two twin 2019 laws, overseen by the CCF (Consumer Protection, Competition and Fraud Repression Directorate-General of the MoC).

Law on Consumer Protection (2019)

It applies to anyone carrying on trading activities with consumers in Cambodia, for profit or not. For an online shop this means in particular:

• mandatory minimum information about the seller, product, price and conditions;
• use of the Khmer language for consumer information;
• a prohibition on false, misleading or deceptive advertising and pyramid-type schemes.

Law on Electronic Commerce (2019) — information, scams, data

Chapter 6 of the Law on E-Commerce adds platform-specific requirements: adequate information to the customer, action against scams and malicious code, and personal data protection. Any business that electronically stores personal data must take reasonable measures to protect it (loss, unauthorised access, leaks). The rules on unsolicited emails apply to domestic and foreign operators alike, regardless of where they are based.

Recognition of electronic records and signatures

The Law on E-Commerce gives legal recognition to electronic records, contracts and signatures, and admits evidence in electronic form in Cambodian proceedings. In practice: a contract concluded online (click-accepted terms, electronic order form) has legal value, provided the law’s requirements on the security and integrity of electronic records are met.

Step 4 — E-commerce taxation

10% VAT (and 0% on exports)

Standard VAT is 10% on sales of goods and services made in Cambodia, and 0% on exports of goods and services consumed outside Cambodia. A Cambodian shop shipping to customers abroad therefore invoices, in principle, at 0% while still recovering its input VAT. Full mechanism (registration thresholds, monthly filing, credit/refund) in the VAT guide.

Non-resident e-commerce VAT

Since Sub-Decree No. 65 (April 2021) and Prakas No. 542 (September 2021), non-resident suppliers of digital goods and services (SaaS, software, streaming, hosting, online advertising) sold to Cambodian customers are subject to 10% VAT:

• B2C (sale to a consumer): the non-resident supplier collects and remits the VAT, after a simplified registration with the GDT (thresholds: turnover ≥ 250M KHR/year, ~62,500 USD, or ≥ 60M KHR over 3 consecutive months).
• B2B (sale to a registered business in Cambodia): reverse charge — the Cambodian customer declares and pays the VAT.

Detail and consequences (including if you buy foreign SaaS for your shop) in the VAT guide.

GDT registration and collecting payments

• TIN + VAT obtained at the GDT at company formation (see Step 1).
• Monthly VAT return by the 20th of the following month (25th for e-filing), even at zero.
• Collecting payments: more and more shops collect via KHQR, the interoperable payment standard backed by Bakong (the National Bank of Cambodia system), accepted by most Khmer banking apps, in riel and USD, with no card terminal. You can also offer cards (via a payment gateway) and transfers. Receipts remain taxable like any sale: declare the corresponding VAT.

Common pitfalls

FAQ

Do I need a special legal structure to sell online in Cambodia?

No. You use an ordinary trading company (in practice a Co. Ltd.) whose object includes online selling, then apply for the e-commerce permit or licence at the MoC. There is no “e-commerce company” as a distinct corporate form.

What is the difference between an e-commerce permit and licence?

It is the applicant’s status. The permit is for individuals and sole proprietorships (valid 2 years). The licence is for legal persons (Co. Ltd., PLC) and branch offices of foreign companies (valid 3 years). You apply at ecommercelicensing.moc.gov.kh under Sub-Decree No. 134 and Prakas No. 290.

Do I have to apply for a permit if I sell very little?

Below the small-taxpayer threshold (~62,500 USD annual turnover) you are exempt from the permit/licence, but you must notify the MoC of your activity. The exemption does not free you from forming a company and being tax-compliant (TIN, VAT, patent tax) where applicable.

What is the penalty for selling online without a permit?

A fine of 10,000,000 KHR (~2,500 USD) under Joint Prakas No. 316. The MoC has issued official reminders urging e-commerce operators to regularise their situation.

What VAT applies to my online sales?

10% on sales in Cambodia, 0% on exports (goods shipped out of Cambodia, services consumed abroad). If you are a non-resident selling digital products to Cambodian customers, a specific regime applies (10% in B2C, reverse charge in B2B). See the VAT guide.

Does a contract or order placed online have legal value?

Yes. The Law on Electronic Commerce (2019) recognises electronic records, contracts and signatures, and admits electronic evidence before Cambodian courts. Click-accepted terms and an electronic order form legally bind the parties, subject to the law’s requirements.

How do I collect payments from Cambodian customers?

The simplest is KHQR, the interoperable payment QR backed by Bakong (National Bank of Cambodia), accepted by most Khmer banking apps, in riel and USD. You can also offer cards (via a payment gateway) and transfers. Receipts remain taxable like any sale: declare the corresponding VAT.