- OVERVIEW
On 5 January 2026, the Royal Government of Cambodia issued Sub-Decree No. 03 ANKR.BK on the Management of Security and Safety in Concentrated Residential Areas (“Sub-Decree No. 03”). Sub-Decree No. 03 aims to strengthen social security, safety, and public order by establishing clear responsibilities for authorities to enforce security and safety control measures within concentrated residential areas, while imposing obligations on all heads of units, owners, managers, and residents to act as proactive partners in supporting law enforcement.
- SCOPE OF APPLICATION
Sub-Decree No.03 applies nationwide to all “Concentrated Residential Areas”, which are defined as collective places of abode or permanent residences of public or private institutions or enterprises. These specifically include gated communities, condominiums, apartments, resorts, bungalows, co-owned buildings, factories, enterprises, farms, Special Economic Zones (SEZs), Economic Land Concessions (ELCs), guesthouses, hotels, dormitories, pagodas, religious buildings, and orphanages. Collective residential areas of the Royal Cambodian Armed Forces (RCAF) and the National Police are excluded from the scope of application.
- CORE COMPLIANCE OBLIGATIONS
Under Sub-Decree No.03, the “Obligation to Participate in Security and Safety Control Measures” is imposed on relevant stakeholders involved in the management, operation, and occupation of Concentrated Residential Areas, as follows:
(1) Resident Data Management Obligation: The heads of units, owners, or managers of the Concentrated Residential Areas shall:
- record and maintain a written or electronic registry of all residents;
- report any changes in residency status to the Commune/Sangkat Administrative Police Station; and
- report the presence of any foreign national staying temporarily to the Commune/Sangkat Administrative Police Station or other competent authorities within 24 hours.
(2) Identity Verification Obligation: Owners or managers of Concentrated Residential Areas shall obtain valid documentation confirming a foreign national’s legal residence before permitting them to stay on the premises. Permitting foreign nationals who have entered Cambodia illegally to stay on the premises is strictly prohibited.
(3) Obligation to Cooperate with the Competent Authorities: The owners, managers, or heads of units must cooperate with the competent authority by:
- facilitating administrative inspections, including the on-site inspections of the Concentrated Residential Areas;
- providing resident registries and security and safety system layout plans upon request; and
- proactively reporting any suspicious targets or illegal activities to the competent authorities.
(4) Obligation to Register Residence: Foreign immigrants, or their representatives, who have been recognized by the Ministry of Interior and hold permanent residence cards, must register their residence within 48 hours upon arrival in accordance with the applicable laws and regulations. All other foreign nationals staying at a Concentrated Residential Area must also register their residence in accordance with applicable laws and regulations.
(5) Obligation to Maintain and Improve Security and Safety Systems: The owners or managers of Concentrated Residential Areas are required to maintain the quality and proper functioning of the security and safety systems of it, including the security camera systems, fire safety systems, lighting, elevators, and entry and exit routes, in accordance with applicable technical standards. They must also comply with the instructions of the competent authorities for any enhancements or improvements to these systems.
(6) Data Retention and Archive Obligation: All security camera footage in the Concentrated Residential Area must be retained for a minimum of 90 days, and the physical entry and exit logs of a Concentrated Residential Area must be retained for at least 1 year.
(7) Obligation of Private Security Agencies: Private security agencies are required to monitor the Concentrated Residential Areas under their responsibility, cooperate with competent authorities, and promptly report any illegal acts occurring within the premises.
- COMPETENT AUTHORITIES
The Ministry of Interior (MOI) is responsible for overseeing the implementation of Sub-Decree No.03 through delegation of power to the Capital/Provincial and Khan/District Administrations. Capital/Provincial Police Commissariat and City/District/Khan Police Inspectorate serve as supporting bodies to the Capital/Provincial and Khan/District Administrations in supervising the Commune/Sangkat Administrative Police Stations in enforcing Sub-Decree No. 03.
- ENFORCEMENT AND PENALTIES
Non-compliance with the provisions of Sub-Decree No. 03 may result in the following consequences:
- The owners or managers of the Concentrated Residential Areas who neglect the maintenance of safety and security systems may be subject to a fine of 400,000 Riels (approximately US$100), in addition to any damages that may arise;
- Owners or managers who intentionally harbor or allow the illegal stay of foreign nationals may be subject to a fine of 4,000,000 Riels (approximately US$1,000) per foreigner, without affecting any criminal liability under applicable laws; and
- Public Officials found assisting the harboring of foreign nationals who have entered Cambodia illegally shall be dismissed from their posts, without affecting any criminal liability.
- CONCLUSION AND KEY IMPLICATION
Sub-Decree No.03 marks a significant shift in Cambodia’s regulatory landscape, expanding the compliance obligations of developers, property managers, and other stakeholders of multi-resident properties. By recognizing them as custodians of resident data, first-line verifiers of legal residency of foreign nationals, and active partners in supporting law enforcement, Sub-Decree No. 03 underscores the critical role of property management in safeguarding public order. Relevant stakeholders are therefore recommended to promptly review and update their internal rules and procedures to ensure full compliance with these new statutory obligations.
Disclaimer: The information provided herein is for information purposes only and may not be relied upon as constituting legal advice.
