NBC–UN microfinance plan: 10 of 22 actions done by September 2025; reviewed July 2026
Correction: Adds the information date (September 2025) to the headline and updates with the July 2026 progress review, the IFC action plan and NBC complaint statistics.
Key points
- As of the third high-level convening in September 2025, 10 of 22 over-indebtedness actions were complete
- Remaining areas include responsible pricing, compliance monitoring, data sharing and inclusive insurance
- NBC reviewed progress on 7 July 2026; no updated completion count has been published
Facts
At the third NBC–UN high-level convening on microfinance, reported by Cambodia Investment Review on 25 September 2025, 10 of the 22 priority actions had been completed 1. Work was continuing on responsible pricing, compliance monitoring, data sharing and inclusive insurance.
According to Khmer Times (10 July 2026, republished on the CMA website), the NBC reviewed implementation of the actions with relevant ministries on 7 July 2026, in a meeting chaired by Lay Sokheng. The areas covered were stronger regulation and supervision, borrower protection and financial literacy, data sharing, curbing illegal lending, and insurance and other support for vulnerable borrowers. A fourth high-level convening was scheduled for August 2026. The report did not include an updated completion count, and the outcome of the fourth convening could not be confirmed as of 28 September 2026.
Relatedly, on 24 June 2026 the IFC Board included in its action plan support for establishing a financial ombudsman in Cambodia and improved responsible-lending certification for about 65,000 loan officers 2. According to the NBC FSR 2025, the NBC received 721 complaints and enquiries in 2025, of which 683 were resolved, 12 were pending and 26 moved to litigation 3.
As of 28 September 2026, the NBC list of Prakas and circulars did not include a Prakas setting a debt-to-income (DTI) cap.
Analysis
As of September 2025 fewer than half of the actions were complete, and the remaining ones, such as pricing and data sharing, bear directly on lenders' revenue and operations. The easier actions appear to have been completed first.
By comparison, Indonesia's OJK in September 2026 withdrew a proposal to cap the number of online lenders per borrower and signalled a focus on repayment burden relative to income (see separate article). How a DTI rule would be specified is an open question in Cambodia, but no such rule appears in published legislation.
Implications
Counterpoints and uncertainties
No updated completion count has been published, so it is unclear whether progress is accelerating or stalling. What counts as 'complete' (issuance of a rule or operational implementation) is not defined. Supervisory priorities may have shifted toward the border-conflict response and bank supervision.
Figures: see definitions
- NBC–UN actions completed: 10. Actions completed as of the third high-level convening. Microfinance sector. Basis date: 25 Sep 2025. Source: Cambodia Investment Review: third NBC-UN convening (2025-09-25)
- Loan officers targeted for responsible-lending certification: about 65,000. Loan officers covered by the certification improvement in the IFC action plan. Cambodian microfinance loan officers. Basis date: 24 Jun 2026. Source: IFC Board statement on the CAO investigation report on Cambodia microfinance (2026-06-24)
- Complaints and enquiries received by NBC: 721. Complaints and enquiries received in the year. NBC consumer-protection function. Basis date: 31 Dec 2025. Source: NBC Financial Stability Review 2025 (2026-03-28)
FSR 2025, Box 2.1 (p. 13); the same counts appear in the Annual Report 2025.
Sources
- NBC: Financial Stability Review 2025（苦情件数、2026-03-28）primary
- IFC: Statement from IFC Board on the CAO Investigation Report on Cambodia Microfinance（2026-06-24）primary
- NBC: Prakas & Circulars（法令一覧）primary
- CMA／Khmer Times: NBC evaluates progress on 22 microfinance priority actions（2026-07-10）
- Cambodia Investment Review: Third NBC–UN convening（2025-09-25）
Reports are for information only and are not investment advice. Methodology: sources, verification and definitions
A Japanese version of this article is available: 日本語版