Briefing Document & Podcast: E-Invoicing and E-Reporting in Cambodia

SUMMARY

Cambodia is implementing a national e-invoicing system, “CamInvoice,” under a phased rollout initiated in late 2024. The system mandates real-time clearance of invoices through the platform. The initial focus is on Business-to-Government (B2G) transactions, with mandatory adoption extending across central government ministries throughout 2025. B2B e-invoicing remains voluntary in 2025 but is slated for a phased mandatory rollout starting in 2026. B2C transactions are currently out of scope, with integration anticipated in later phases. Compliance is enforced through invoice validation and potential rejection for non-compliant invoices, alongside potential tax penalties. The system utilizes UBL XML format, requires specific data elements, and necessitates 10-year electronic archiving. Currently, there are no pre-filled VAT returns generated by the system.

1. Implementation Timeline and Scope:

Soft Launch: December 12, 2024, with voluntary B2G registration for some government suppliers.
- “Soft launch of the Cambodia E-Invoicing System (CamInvoice) for pilot B2G use. Voluntary registration opened for some government suppliers.”
Phase 1 (2025): Mandatory B2GStep 1 (January 2025): Mandatory for Ministry of Economy and Finance (MEF) and Ministry of Environment and their suppliers.
- “Mandatory B2G e-invoicing begins for central government budget units of the Ministry of Economy and Finance (MEF) and the Ministry of Environment, and all their suppliers.”
Step 2 (July 2025): Extended to six additional ministries: Agriculture, Commerce, Industry/Science/Tech., Education, Posts/Telecom, and Civil Service.
- “Mandatory B2G extends to 6 more ministries.”
- “From this point, these ministries only accept e-invoices for public procurement payments.”
Step 3 (November 2025): Expanded to 14 ministries including Rural Development, Mines/Energy, Land Management, Health, Public Works, and Labor, among others.
- “The B2G mandate further expands to additional ministries, ultimately covering 14 ministries by end of 2025.”
Phase 2 (2026): Expansion to B2B and Sub-National GovernmentMandatory B2G for all levels of government (central and sub-national).
- Phased mandatory rollout for B2B transactions, starting with “a defined group of taxpayers,” likely large taxpayers or specific sectors.
- “Crucially, certain businesses in the private sector will be required to use e-invoicing for B2B in 2026. This is expected to start with a “defined group of taxpayers”, likely large taxpayers or specific sectors.”
2027 and Beyond:Wider B2B mandates are expected.
- B2C integration anticipated. The long-term goal is to have “virtually all domestic invoices” processed through the system.
- “By 2027, e-invoicing should be mandatory for all government entities and for a broad set of businesses in B2B, with B2C integration anticipated thereafter.”

2. Transactions in Scope:

The initial mandate focuses on domestic B2G transactions.“In Phase 1 (2024–25), the requirement exclusively covers B2G transactions within Cambodia.”
B2B invoices are currently voluntary (2025) but will become mandatory in phases starting in 2026.“Business-to-business (B2B) invoices between companies in Cambodia are not yet compulsory to route through CamInvoice (though companies may do so voluntarily).”
B2C invoices are currently out of scope.“Consumer (B2C) invoices are out of scope at this stage, as the platform does not yet support B2C use.”
Cross-border invoices (import/export) are not currently mandated.“For import/export transactions, there is no current e-invoice mandate.”
However, it is expected that eventually, all VAT invoices by registered taxpayers, including exports, will need to be reported through the system.

3. Taxable Persons in Scope:

The rules apply to taxable persons established in Cambodia, including companies, enterprises, and VAT-registered individuals engaging in in-scope transactions.
- “The e-invoicing rules apply to taxable persons established in Cambodia (including companies, enterprises, and any VAT-registered person) when they engage in in-scope transactions.”
This includes local subsidiaries/branches of foreign companies registered for tax in Cambodia.
Non-established businesses (foreign companies without local tax registration) are not directly obligated. However, they may be indirectly affected if they supply to the government.
- “In contrast, non-established businesses (foreign companies with no local tax registration) are not directly obligated under the e-invoice mandate…”

4. E-Invoice Format and Data Requirements:

Format: UBL XML (Universal Business Language).
- “The system uses the UBL XML format for all invoice data.”
Types of Invoices: Both “Tax Invoices” and “Commercial Invoices” are supported.
Mandatory Fields:Vendor Information: Name, address, contact, and Tax Identification Number (TIN).
- “Vendor information: Name of the seller company, address, contact, and Tax Identification Number (TIN).”
Buyer Information: Name, address, and TIN (for B2B/B2G).
- “Buyer information: Name and address of the buyer; if the buyer is a business, their TIN (for B2B/B2G).”
Invoice Details: Unique invoice number, issue date, payment due/expiration date (if applicable).
- “Invoice details: Unique invoice number, invoice issue date, and (if applicable) the payment due date or expiration date.”
Line Item Details: Description, quantity, unit price, and total per item.
- “Line item details: Description of goods or services, quantity, unit price, and total per item.”
Tax Details: VAT amount (Cambodian VAT is 10% on taxable supplies), and other applicable taxes.
- “Tax details: The VAT amount and any other taxes applicable must be indicated.”
Total Amounts: Total invoice value (with and without VAT).
- “Total amounts: Total invoice value, with and without VAT, clearly stated.”
QR Code: Generated by CamInvoice after validation. It certifies the invoice’s authenticity and provides a link to the government database.
- “After validation, a QR code is attached to each e-invoice.”

5. E-Reporting and Transmission Timelines:

Clearance Model: Cambodia uses a real-time clearance model.
- “Cambodia employs a clearance model, meaning that qualifying invoices must be transmitted to the tax authorities in real time at the moment of issuance.”
Real-Time Clearance: Invoices must be submitted immediately to CamInvoice upon creation (via online portal or API). Approval by the tax authority is required for legal validity. * “When an in-scope invoice is created, it is submitted immediately to CamInvoice (either via the online portal or via API from an ERP).”
Transmission Method:Direct integration (API/web services) or the CamInvoice portal.
- Validated invoices are returned with a QR code and digital attestation.
- If the buyer is on the system, they receive the invoice automatically; otherwise, the seller must provide a copy.
No Separate E-Reporting for Non-Mandated Invoices: For invoices outside the mandatory scope, the standard VAT filing timeline applies (monthly VAT return by the 20th of the following month).

6. Penalties for Non-Compliance:

No General Grace Period: Compliance is expected from the effective date of the mandate for specific sectors or transactions.
- “No general “grace period” with blanket penalty suspension has been announced.”
Invoice Validity and Payment: For B2G transactions, invoices not submitted via CamInvoice will likely be rejected for payment.
- “For B2G transactions under the mandate, an invoice not submitted via the e-invoice system simply will not be accepted for payment by the government.”
Tax Penalties: Failure to comply is a violation of tax rules and can result in administrative penalties under the Law on Taxation.
- “Cambodia’s Law on Taxation provides for administrative penalties for failure to comply with tax obligations.”
- This can include penalties for late filing/under-reporting VAT, which could be applied to e-invoicing non-compliance.

7. Archiving Requirements and Retention:

Retention Period: Businesses must retain invoices for 10 years.
- “Businesses must retain invoices for 10 years for tax purposes.”
Format of Archive: Electronic archiving is allowed and encouraged. Storing the XML and a readable format (PDF with QR code) is recommended.
Taxpayers should save a copy of the electronic invoice in their own records, even though the invoice is also stored on the government system.
No need to print out e-invoices.
Electronic records must ensure integrity and accessibility for audits.

8. Pre-filled VAT Returns:

Currently, Cambodia does not offer pre-filled VAT returns based on e-invoice data.“As of the current implementation, Cambodia does not offer pre-filled VAT returns based on e-invoice data.”
Taxpayers must continue to prepare and file their own VAT declarations monthly.

9. References to Regulations and Official Resources:

Prakas No. 075 MEF (Jan 22, 2025): Officially launched CamInvoice.
- “Prakas (Ministerial Order) No. 075 MEF (Jan 22, 2025): Officially launched the Cambodia E-Invoicing System as the central platform for managing and validating e-invoices.”
Circular No. 003 MEF (Jan 22, 2025): Established Phase 1, Step 1.
- “Circular No. 003 MEF (Jan 22, 2025): Established Phase 1, Step 1 of mandatory e-invoicing (B2G for MEF and Environment ministries).”
Circular No. 012 MEF (July 14, 2025): Expanded mandate (Phase 1, Step 2).
- “Circular No. 012 MEF (July 14, 2025): Expanded the mandate to additional ministries (Phase 1, Step 2) and reiterated the ongoing voluntary status of B2B e-invoicing.”
Circular No. 017 MEF (Nov 20, 2025): Further extension (Phase 1, Step 3).
- “Circular No. 017 MEF (Nov 20, 2025): Further extension (Phase 1, Step 3) to cover more ministries – bringing the total to 14 ministries by end of 2025.”
Cambodia E-Invoicing System Website (e-invoice.gov.kh): Official portal with resources and regulations.

10. Key Considerations:

Businesses should proactively prepare for the mandatory B2B rollout in 2026.
Ensure accounting systems can generate UBL XML invoices.
Establish robust electronic archiving processes to comply with the 10-year retention requirement.
Monitor official announcements and seek professional guidance to stay updated on evolving regulations and compliance requirements.

Video on YouTube

INDEPTH ANALYSIS

Implementation Timeline: Cambodia is rolling out e-invoicing in phases under the national “CamInvoice” system. A soft launch occurred in late 2024, followed by a phased mandate starting 2025: [edicomgroup.com]

Dec 12, 2024: Soft launch of the Cambodia E-Invoicing System (CamInvoice) for pilot B2G use. Voluntary registration opened for some government suppliers. [edicomgroup.com] [innolabs.dev]
January 2025 (Phase 1, Step 1): Mandatory B2G e-invoicing begins for central government budget units of the Ministry of Economy and Finance (MEF) and the Ministry of Environment, and all their suppliers. Invoices for procurement payments in these entities’ 2025 fiscal year must be issued via CamInvoice (clearance model). This marks Stage 1 of the mandate. **B2B and B2C transactions remain unaffected (B2B optional, B2C not yet supported)】. [sovos.com] [sovos.com], [commerce-c…mbodia.com]
July 2025 (Phase 1, Step 2): Mandatory B2G extends to 6 more ministries. A circular (No. 012, 14 July 2025) added the Ministries of Agriculture, Commerce, Industry/Science/Tech., Education, Posts/Telecom, and Civil Service to the mandate. From this point, these ministries only accept e-invoices for public procurement payments. B2B e-invoicing is still voluntary (encouraged but not required) during 2025. [taxathand.com], [taxathand.com] [taxathand.com] [vatupdate.com], [b2b-cambodia.com] [vatupdate.com], [commerce-c…mbodia.com]
November 2025 (Phase 1, Step 3): The B2G mandate further expands to additional ministries, ultimately covering 14 ministries by end of 2025. Newly included are ministries such as Rural Development, Mines/Energy, Land Management, Health, Public Works, and Labor, among others. By late 2025, all major central government agencies and their suppliers are in scope for mandatory e-invoicing. B2B usage remains voluntary in 2025. [edicomgroup.com], [edicomgroup.com] [edicomgroup.com]
2026 (Phase 2): The mandate will broaden to sub-national government entities (provincial and local government agencies). Crucially, certain businesses in the private sector will be required to use e-invoicing for B2B in 2026. This is expected to start with a “defined group of taxpayers”, likely large taxpayers or specific sectors. In other words, B2G becomes mandatory at all levels of government, and B2B begins a phased obligatory rollout. [edicomgroup.com]
2027 and beyond: The plan is to expand B2B mandates to a wider group and eventually cover B2C transactions. By 2027, e-invoicing should be mandatory for all government entities and for a broad set of businesses in B2B, with B2C integration anticipated thereafter. In the long term, virtually all domestic invoices may be required to pass through the system for clearance. [vatcalc.com], [edicomgroup.com]

Grace Period: No general “grace period” with blanket penalty suspension has been announced. Instead, Cambodia opted for a gradual, phased enforcement (voluntary first, then mandatory by sectors) as the transition mechanism. When a sector or phase becomes mandatory, compliance is expected from the effective date. Notably, during the initial rollout to ministries, authorities allowed a short transitional tolerance: invoices not issued via the e-invoice system “may be accepted with official justification” while systems integration is being finalized, but ministries “reserve the right to reject payment requests if an invoice cannot be verified through [the system]”. This implies only a limited form of grace – companies had to use the platform unless there were extenuating circumstances, and even then the invoice could be refused. In summary, Cambodia’s approach to grace periods is to phase in obligations gradually rather than to impose and then forgive penalties; once a category of taxpayer or transaction is under the mandate, compliance is expected immediately, with any leniency handled case-by-case rather than via formal penalty holidays. [vatupdate.com] [data.opend…mbodia.net], [b2b-cambodia.com] [b2b-cambodia.com]

Transactions in Scope (Domestic vs. Cross-Border): The e-invoicing mandate currently focuses on domestic transactions, especially those involving the government. In Phase 1 (2024–25), the requirement exclusively covers B2G transactions within Cambodia – i.e. invoices issued by Cambodian businesses to domestic public sector entities must be electronic. Business-to-business (B2B) invoices between companies in Cambodia are not yet compulsory to route through CamInvoice (though companies may do so voluntarily). Consumer (B2C) invoices are out of scope at this stage, as the platform does not yet support B2C use. [sovos.com] [sovos.com], [commerce-c…mbodia.com] [commerce-c…mbodia.com]

For import/export transactions, there is no current e-invoice mandate. Cross-border invoices (e.g. a Cambodian company invoicing a foreign customer, or vice versa) are not required to go through the Cambodian e-invoicing system at present. The initial mandate is tied to VAT-taxable supplies in Cambodia (notably government procurement and, later, domestic B2B). However, it’s expected that as B2B requirements come into force in 2026–27, all VAT invoices by registered taxpayers, including those for exports or for foreign buyers, will eventually need to be reported through the system for compliance purposes. (In a clearance model, even if the buyer is not on the platform, the seller must still submit the invoice to the tax portal for validation.) For now, the mandate is effectively limited to domestic invoices. Import transactions are handled via customs, and exports or services to overseas customers are zero-rated and currently do not trigger any special e-reporting obligation beyond the normal VAT return declaration. [edicomgroup.com]

Taxable Persons in Scope (Established vs. Non-Established): The e-invoicing rules apply to taxable persons established in Cambodia (including companies, enterprises, and any VAT-registered person) when they engage in in-scope transactions. During Phase 1, this has meant primarily government ministries and their Cambodian-registered suppliers. For example, any company bidding on and invoicing a ministry must register on CamInvoice and issue e-invoices to that ministry. By extension, local subsidiaries or branches of foreign companies that are registered for tax in Cambodia are included when they transact with the in-scope entities. In contrast, non-established businesses (foreign companies with no local tax registration) are not directly obligated under the e-invoice mandate, since they generally cannot issue invoices within the Cambodian VAT system. In practice, a foreign supplier to the government would need to either register for Cambodian VAT or work through a local registered entity to get paid, thereby coming under the mandate indirectly. Thus, the mandate effectively targets established (registered) taxpayers. Future phases that extend to B2B will likewise apply to businesses registered in Cambodia (starting with large taxpayers). There is no separate framework for non-resident suppliers in the e-invoice system yet – Cambodia does have rules for VAT on digital services by non-residents, but that is handled via a special registration and reverse charge mechanism, not via CamInvoice. In summary, only established taxable persons in Cambodia are within scope, and non-established entities remain outside unless they obtain local registration and fall under the same rules as local companies. [edicomgroup.com] [b2b-cambodia.com], [b2b-cambodia.com] [vdb-loi.com], [grantthornton.global]

E-Invoice Format and Data Requirements: Cambodia’s e-invoices must be issued in a standardized electronic format with specific content requirements:

Format: The system uses the UBL XML format for all invoice data. This is a structured XML schema (Universal Business Language) ensuring all required fields are present. In practice, businesses can either input invoices via the CamInvoice web portal or integrate their ERP to submit XML invoices automatically. [melasoft.com] [commerce-c…mbodia.com]
Types of invoices: Both “Tax Invoices” and “Commercial Invoices,” as defined under Cambodian law, are handled, as well as related documents like debit notes and credit notes. (Generally, a tax invoice is for VAT-registered transactions, and a commercial invoice might be used in non-VAT contexts, but the platform supports both categories.) [melasoft.com]
Mandatory fields: Invoices must include all the usual VAT invoice details. This includes:
- Vendor information: Name of the seller company, address, contact, and Tax Identification Number (TIN). [edicomgroup.com]
- Buyer information: Name and address of the buyer; if the buyer is a business, their TIN (for B2B/B2G). [edicomgroup.com]
- Invoice details: Unique invoice number, invoice issue date, and (if applicable) the payment due date or expiration date. [edicomgroup.com]
- Line item details: Description of goods or services, quantity, unit price, and total per item. For tax invoices, prices are typically listed without VAT; for simplified commercial invoices, they may be inclusive of VAT. [edicomgroup.com], [edicomgroup.com]
- Tax details: The VAT amount and any other taxes applicable must be indicated. Cambodian VAT is 10% on taxable supplies (0% for exports); the invoice should show the VAT breakdown. If certain items are subject to special taxes (e.g. specific goods/services tax, public lighting tax, etc.), those should also be listed. [edicomgroup.com]
- Total amounts: Total invoice value, with and without VAT, clearly stated.
- QR code: After validation, a QR code is attached to each e-invoice. The QR code, generated by the CamInvoice system, certifies that the invoice has been officially validated and recorded. It serves as a unique “fingerprint” of the invoice on the blockchain-based system. Scanning the QR code allows verification of the invoice’s authenticity in the government database. [melasoft.com] [edicomgroup.com], [edicomgroup.com]
In essence, an e-invoice on CamInvoice contains the same data as a traditional VAT invoice, but in a structured digital form, and augmented with a government certification (the QR code and digital signature) to prove it’s an official e-invoice. The use of UBL XML ensures all this information is conveyed in a standardized way, and businesses have to adapt their systems to output invoices in this schema or input the data on the portal. [melasoft.com]

E-Reporting and Transmission Timelines: Cambodia employs a clearance model, meaning that qualifying invoices must be transmitted to the tax authorities in real time at the moment of issuance. There is no separate “periodic e-reporting” system for invoices outside the clearance platform at this time – the focus is on getting invoices cleared through CamInvoice rather than requiring summary reports after the fact. Key points: [melasoft.com]

Real-time clearance: When an in-scope invoice is created, it is submitted immediately to CamInvoice (either via the online portal or via API from an ERP). The platform performs instant validations (format checks, business validations against GDT rules, etc.). Only after passing these checks and being approved by the tax authority is the invoice considered legally valid. Practically, this means the data is in the government’s hands within seconds or minutes of invoice issuance, not days. There is no grace period of X days to report later – compliance requires on-the-spot submission and approval before an invoice can be used for payment or tax credit purposes. [melasoft.com], [vatcalc.com] [melasoft.com]
Transmission method: For those using their own software, CamInvoice offers integration (e.g. via API/web services). After an invoice is sent, CamInvoice returns a validated copy with the official QR code and digital attestation. If the buyer is also on the system, they receive it through the platform automatically; if not (say, a consumer or a non-registered foreign buyer), the seller must deliver a copy by other means (email, paper) but still must lodge it on CamInvoice for the tax authority. [edicomgroup.com], [edicomgroup.com] [edicomgroup.com]
E-Reporting for non-mandated invoices: As of now, Cambodia has not introduced a separate e-reporting mandate for invoices that are not yet covered by e-invoicing. In many countries, “e-reporting” refers to sending transaction data to the tax authority within a certain time (like France’s upcoming system for B2C and cross-border invoices). In Cambodia’s case, since B2B and B2C are still largely outside the e-invoice mandate (until they become phased in), those transactions continue under the existing compliance regime: companies keep records and report aggregated sales/purchases in their monthly VAT returns. There isn’t a requirement to upload each B2B invoice to a portal within X days (beyond the normal practice of attaching copies of invoices to the monthly tax filing, which has long been a compliance step). The government’s strategy appears to be to eventually bring all invoices into the real-time system, obviating the need for a separate e-reporting channel. So currently, no additional e-reporting of domestic transactions is required apart from the CamInvoice system. [grantthornton.global]
Timeline for data transmission: In summary, data must be transmitted at invoice issuance for those in scope. For invoices outside CamInvoice’s mandatory scope, the standard VAT filing timeline applies – businesses submit a monthly VAT return by the 20th of the following month (or 25th if filing online), including details of all invoices issued/received in that month. Thus, the “due date” for reporting those is effectively the VAT return deadline. But once e-invoicing is mandatory for a transaction, the only acceptable timeline is immediate electronic submission; there is no separate later deadline because the invoice itself must go through the system to be valid. [grantthornton.global] [melasoft.com]

Penalties for Non-Compliance: Cambodia’s authorities have signaled that compliance with e-invoicing is expected and enforceable, though detailed penalty regimes for e-invoice violations have not been heavily publicized yet (given the early phase focusing on government procurement). Key implications and known consequences include:

Invoice validity and payment: For B2G transactions under the mandate, an invoice not submitted via the e-invoice system simply will not be accepted for payment by the government. Ministries have been instructed to reject payment requests that they cannot verify in the CamInvoice (CEIS) platform. In practice, this is a very strong enforcement tool: a supplier who fails to issue an e-invoice to a ministry might not get paid until they comply. Thus, the immediate “penalty” is business-critical (no payment). [b2b-cambodia.com]
Interim leniency (if any): As noted, during the interim of Phase 1 some off-system invoices could be accepted with formal justification, but this was exceptional. Going forward, such exceptions will dwindle. Essentially, non-compliance means the invoice is not legally valid, which also means the buyer (especially a government buyer) cannot process it. This puts heavy pressure on compliance without needing to levy fines. [b2b-cambodia.com]
Tax penalties: Beyond the commercial consequence, failing to comply is a violation of tax rules (since mandated taxpayers must issue proper tax invoices via the system). Cambodia’s Law on Taxation provides for administrative penalties for failure to comply with tax obligations. While specific fines for “not using CamInvoice” aren’t published yet, the tax authorities could impose general penalties for improper invoicing or record-keeping. For instance, late filing or under-reporting VAT normally incurs a 10% or 25% additional tax penalty plus 1.5% interest per month. Similar provisions could apply if a taxpayer tries to circumvent e-invoice requirements (e.g. treating an affected sale as if it were not e-invoiced). Additionally, obstructing the tax system can draw administrative fines (for example, a fixed penalty of 2,000,000 riels – around $500 – is stipulated for real-regime taxpayers who obstruct tax provisions). These general penalties in the tax code would likely be leveraged in cases of e-invoicing non-compliance until any e-invoice-specific fines are introduced. [grantthornton.global]
Enforcement status: As of the latest updates, there is no indication of a “penalty holiday” for mandated e-invoicing – once required, the onus is on taxpayers to comply or face consequences. Companies are therefore strongly urged to get onboarded and comply by the stipulated dates. The phased rollout itself has been the main concession to give businesses time to adapt, rather than enforcing penalties and then waiving them. We can expect that as the system extends to B2B, explicit penalties for non-compliance (fines) will be detailed by regulation. But the prudent assumption for businesses is that non-compliance will expose them to the standard tax penalty regime and potential disallowance of invoices for VAT purposes. [melasoft.com]

Invoice Format for Transmission: (To avoid confusion with content vs. format, reiterating format specifics here) The CamInvoice platform uses a centralized clearance model that requires invoices to be uploaded in a machine-readable format (UBL XML). This means businesses may need to adapt their accounting software to output invoices in XML or use conversion tools. Once an invoice is uploaded:

It undergoes automated checks (XML schema validity, required fields present, business rule compliance, and even an e-Know-Your-Business verification). Only a correctly formatted and complete invoice passes these checks. [vatcalc.com]
The system then digitally signs and registers the invoice on a blockchain ledger (CamDL) to ensure tamper-proof storage. A unique hash/ID (reflected in the QR code) is assigned. [vatcalc.com]
Both seller and buyer get notified (via the system or via API webhook) that the invoice is approved. This real-time feedback loop means any errors (missing data, etc.) must be fixed immediately and the invoice re-submitted, essentially enforcing data quality at issuance. [vatcalc.com]

From a technology perspective, the format is unified (UBL XML) and the transport is via the CamInvoice portal/API, ensuring all required data reaches the GDT instantly in a structured way. [melasoft.com]

Data Transmission Deadlines: (Already covered under E-Reporting above – essentially immediate for clearance; otherwise monthly by 20th for regular VAT filing) – [This point is largely addressed above, will not repeat to avoid redundancy].

Archiving Requirements and Retention: Cambodia’s move to e-invoicing does not eliminate record-keeping obligations; instead, electronic invoices are subject to similar retention rules as paper invoices were. Key requirements:

Retention period: Businesses must retain invoices for 10 years for tax purposes. This long-standing requirement (a decade of document retention) continues to apply in the digital era. It was common for companies to store paper invoices for ten years; now they will need to ensure e-invoices are securely archived for at least the same duration. [innolabs.dev]
Format of archive: The law requires that invoices be kept in a reliable format. With CamInvoice, each e-invoice is stored on the government’s system (blockchain-backed storage) once issued. Taxpayers should also save a copy of the electronic invoice (the XML or a readable format like PDF with QR code) in their own records. Electronic archiving is allowed and encouraged. There is no need to print out e-invoices for storage (indeed, one goal is to eliminate paper). As long as the invoices can be reproduced in their original format and authenticity (with the digital signature/QR code) for an audit, that suffices. [vatcalc.com]
Legal archiving provisions: Cambodia’s regulations on electronic documents (as part of its e-commerce and digital laws) likely apply – these typically require that e-records be kept in a way that ensures integrity and accessibility. Companies should implement an e-archive or use the CamInvoice portal’s archive features. The Cambodia E-Invoicing System portal serves as an intermediary and archive, but the onus is still on the taxpayer to maintain their records. For instance, if the tax authority audits a business, the business should be able to produce the e-invoices from the past years. Storing the original XML and a human-readable version is recommended.
Audit and access: During a VAT audit, tax officers may access the CamInvoice database to cross-check a company’s sales and purchases. However, businesses are still expected to provide their books and records. Thus, proper archiving (with index of invoice numbers, dates, etc.) is important for compliance.
Previous paper archives: The new system underscores moving “from 10-year paper storage requirements to real-time digital” processes. This means that while the 10-year rule stays, the nature of storage shifts – instead of physical files, digital storage (with backup) is the norm. Companies that have been manually printing, signing, and boxing invoices for storage can transition to purely digital archiving, so long as they meet the 10-year retention and can ensure documents remain unaltered and accessible. [innolabs.dev]

Pre-filled VAT Returns: As of the current implementation, Cambodia does not offer pre-filled VAT returns based on e-invoice data. Taxpayers must continue to prepare and file their own VAT declarations monthly. The introduction of e-invoicing will give the tax authority much more transactional data, but this is used for verification and audit purposes rather than populating taxpayer returns at this stage. Each business still submits a monthly VAT return (Form VAT declarations) by the 20th of the next month, reporting output tax and input tax, and must pay any net tax due. There has been no announcement of the GDT providing pre-completed VAT forms using CamInvoice data, and given that B2B e-invoicing is not fully mandatory yet, the authorities wouldn’t have a complete dataset to do so. In short, no pre-populated VAT return system is in place – companies themselves compile the figures (though they can of course use the e-invoice records to help reconcile their taxes). As the e-invoicing system matures and once a significant share of transactions flow through it, it’s possible the government could consider leveraging that data for services like pre-filled returns or automated VAT refund calculations, but nothing of that sort is active as of 2025. [grantthornton.global]

References to Regulations and Official Resources: The legal basis for Cambodia’s e-invoicing rollout comes from several instruments:

Prakas (Ministerial Order) No. 075 MEF (Jan 22, 2025): Officially launched the Cambodia E-Invoicing System as the central platform for managing and validating e-invoices. This Prakas set out the foundation of the system and its role in public finance reform. [data.opend…mbodia.net]
Circular No. 003 MEF (Jan 22, 2025): Established Phase 1, Step 1 of mandatory e-invoicing (B2G for MEF and Environment ministries). It obliges those agencies and their suppliers to use the system for FY2025 onward. [data.opend…mbodia.net], [data.opend…mbodia.net]
Circular No. 012 MEF (July 14, 2025): Expanded the mandate to additional ministries (Phase 1, Step 2) and reiterated the ongoing voluntary status of B2B e-invoicing. [taxathand.com], [taxathand.com]
Circular No. 017 MEF (Nov 20, 2025): Further extension (Phase 1, Step 3) to cover more ministries – bringing the total to 14 ministries by end of 2025. [edicomgroup.com], [edicomgroup.com]
Pentagonal Strategy & Digital Economy Framework: These are high-level government strategies referenced in the announcements to underline that e-invoicing is part of Cambodia’s 2021–2035 digital economy policy and public financial management reform (Phase 4). [opendevelo…mbodia.net], [b2b-cambodia.com]
Cambodia E-Invoicing System website (e-invoice.gov.kh): The official portal provides resources, FAQs, and the text of relevant regulations (in Khmer). Notably, the site lists the circulars and prakas under “Laws and Regulations” for transparency. Businesses can refer to these original documents (Khmer) for the authoritative requirements. [e-invoice.gov.kh], [e-invoice.gov.kh]

For further reading, recent tax news articles and analyses by professional firms provide summaries in English. For example, KPMG and Deloitte Cambodia have issued tax alerts about the e-invoicing phases, and industry blogs (VATupdate, EDICOM, etc.) have detailed the technical model and timeline. These external sources confirm the key points: Cambodia’s e-invoicing (“CamInvoice”) is a clearance system being phased in from 2025 onwards, starting with B2G, with no explicit grace period aside from phased onboarding, covering domestic transactions (for now), requiring data-rich UBL XML invoices, real-time transmission, and expected to improve compliance and audit capability. All participants must plan for ten-year electronic archiving of invoices and continue standard VAT filings (no pre-filled returns yet). Non-compliance can lead to invoice rejection or penalties under the tax law. The Cambodian government’s official releases and the CamInvoice portal are the primary sources for these requirements, ensuring that the information above is grounded in the latest regulations and policy announcements. [kpmg.com], [taxathand.com] [edicomgroup.com], [melasoft.com] [vatupdate.com], [melasoft.com] [melasoft.com] [vatcalc.com] [innolabs.dev] [b2b-cambodia.com], [grantthornton.global]

Sources:

Cambodia Ministry of Economy and Finance – Prakas No. 075 (22 Jan 2025) & Circular 003 (Phase 1 Step 1); Circular 012 (14 Jul 2025, Phase 1 Step 2); GDDE Announcement (Dec 2024 soft launch). [data.opend…mbodia.net], [data.opend…mbodia.net] [taxathand.com], [vatupdate.com] [opendevelo…mbodia.net]
Deloitte Cambodia Tax@Hand (Jul 2025): Summary of Circular 012 and phased implementation (Phase 1: 2024–25 B2G, Phase 2: 2025–26 more ministries, voluntary B2B). [taxathand.com], [taxathand.com]
KPMG TaxNewsFlash (Nov 2025): Notes on Circular 012 and second phase of e-invoicing mandate. [kpmg.com]
EDICOM global blog (Nov 2025 update): “E-invoicing in Cambodia: Centralized Clearance Model” – detailed overview of CamInvoice, implementation timeline through 2027, invoice format (UBL XML, required fields), and process. [edicomgroup.com], [edicomgroup.com]
VATupdate (Aug 2025): News highlight confirming six additional ministries added in 2025 and phased approach (Mandate Phase 1 & 2). [vatupdate.com]
Melasoft News (May 2025): “Cambodia Rolls Out CamInvoice” – confirms timeline (2024 pilot; 2025 nat’l B2G, voluntary B2B; 2026–27 expand to all B2G/B2B; future B2C) and technical requirements (UBL XML, QR code). [melasoft.com], [melasoft.com]
Commerce-Cambodia Trade News (Jul 2025): Explanation of Phase 1 Step 1 vs Step 2 scope, Phase 2 (2026) plans, and system features (real-time validation, blockchain). [commerce-c…mbodia.com], [commerce-c…mbodia.com]
B2B Cambodia News (Jul 2025): Article on mandatory e-invoicing expansion – emphasizes that public procurement invoices must be on CEIS and that ministries will only accept e-invoices (with note on interim handling of exceptions). [b2b-cambodia.com], [b2b-cambodia.com]
Innolabs Blog (Oct 2025): Highlights the shift from paper to digital, noting 10-year invoice storage requirement persists and encouraging businesses to adopt e-invoicing early. [innolabs.dev], [innolabs.dev]
Grant Thornton Cambodia Guide (Jan 2025): General VAT compliance info – monthly VAT return deadlines (20th of next month) and penalties for late filing/payment. This reflects that no pre-filled return is provided – businesses must report liabilities themselves. [grantthornton.global], [grantthornton.global]
Sovos Update (Feb 2025): Confirms Stage 1 B2G mandate from Jan 2025 and that B2B is optional, B2C not yet supported. [sovos.com], [sovos.com]

These sources collectively substantiate the current scope and timeline of Cambodia’s e-invoicing & e-reporting initiative, as well as the compliance expectations (data, format, archiving) and the absence of pre-populated VAT returns in the system’s early stage. Each point above is grounded in the latest available regulations and commentary as of late 2025, ensuring a up-to-date and accurate overview for Cambodia. [edicomgroup.com], [b2b-cambodia.com]

See also

Join the Linkedin Group on Global E-Invoicing/E-Reporting/SAF-T Developments, click HERE
Join the LinkedIn Group on ”VAT in the Digital Age” (VIDA), click HERE

Latest Posts in "Cambodia"

E-invoicing VATupdate E-Invoicing and E-Reporting Guide

Briefing Document & Podcast: E-Invoicing and E-Reporting in Cambodia

Latest Posts in "Cambodia"

Advertisements:

Contact:

Support & Info

Sign up for our newsletter