Cambodia lending rules: a rate cap and complaint duties, but no DTI cap in NBC legislation

Facts

The NBC list of Prakas and circulars includes the Prakas on Interest Rate Ceiling on Loan (13 March 2017). The Prakas sets the cap at 18% a year for any loan maturity; it applies to MDIs, MFIs and rural credit operators, for new loan contracts (including restructured and refinanced loans) from 1 April 2017, and its text does not mention fees ¹.

On consumer protection, there is a Prakas on Resolution of Consumer Complaints (25 October 2018). According to the NBC FSR 2025 (published 28 March 2026), the NBC received 721 complaints and enquiries in 2025 (533 at head office and 188 at branches), of which 683 were resolved, 12 were pending and 26 moved to litigation ². On 24 June 2026 the IFC Board included support for a financial ombudsman in Cambodia in its action plan.

For credit information, there is the Prakas on Credit Reporting (26 June 2020). For deposit-taking institutions, Prakas on capital buffers (19 November 2025) and early supervisory intervention (17 July 2025) were issued in 2025. For non-deposit-taking institutions there is a Prakas on the liquidity ratio (22 July 2024). On IT, the Technology and Cyber Risk Management Guidelines (January 2026) were published.

No Prakas setting a debt-to-income (DTI) cap was found in the NBC legislation list as of 28 September 2026. In response to the border conflict, the NBC waived fees and penalties and deferred principal and interest payments for affected borrowers (FSR 2025).

Analysis

Lenders' regulatory costs fall into three layers: first, the rate cap, which sets a ceiling on revenue; second, fixed operating costs such as complaint handling, credit reporting and IT risk management; and third, capital and liquidity rules. Small unsecured lending is most exposed to the first two, because fixed costs weigh more heavily the smaller the loan (see the illustrative calculation in our T&S View).

By comparison, Indonesia's OJK in September 2026 withdrew a proposal to cap the number of lenders per borrower and signalled a focus on repayment burden relative to income (see separate article). In Cambodia no statutory DTI cap could be found, and affordability assessment appears to be left to each institution's credit policy.

Implications

Counterpoints and uncertainties

The complaints and credit-reporting Prakas are scanned PDFs, and their conditions (covered institutions, deadlines, penalties) were not verified. A DTI rule may exist in a form other than a Prakas, such as a circular or guidance. The NBC Annual Report 2025 says the NBC is preparing and reviewing Prakas and guidelines on interest rate ceilings, so the cap could change. Whether EWA providers and digital lenders fall under the NBC or the Non-Bank Financial Services Authority (NBFSA) is unverified.