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Legal Update: The Amendment of Annex 1 (Negative List) of Sub-Decree No. 139 ANKr.BK

Posted on July 16, 2025

On 6 June 2025, the Royal Government of Cambodia promulgated Sub-Decree No. 86 ANKr.BK, introducing amendments to Sub-Decree No. 139 ANKr.BK, dated 26 June 2023, concerning the implementation of the Law on Investment of the Kingdom of Cambodia.

This amendment specifically addresses Annex 1 (Negative List) under Section C, which relates to Investment Activities or Investment Activity Categories in the Industrial Sector. The newly added provision, C.12.15, explicitly covers “Manufacturing and/or Assembly or Installation of Electronic Cigarettes and All Types of Similar Electronic Smoking Devices.” The classification of this activity under the Negative List signifies that it is subject to regulatory scrutiny, restrictions, or prohibitions as stipulated by the Royal Government of Cambodia. Notably, such activities with an investment capital of less than USD 500,000 are excluded from eligibility for investment incentives under the current investment framework.

This regulatory development reflects the government’s strategic policy to regulate industries considered sensitive, especially those with potential implications for public health and safety. It emphasizes Cambodia’s ongoing efforts to ensure that investment inflows align with national development priorities and responsible investment standards.

This legal update is brought to you by Davies SM Attorneys-at-law.

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