VLP Legal Press #39 : Single-Purpose E-Money
When you walk into a modern cafe, gym, or beauty salon in today, and you'll likely be offered some membership or reload program. It is win-win loyalty program for the business and the customer.
But under Cambodian law, the moment a business starts holding customers' money as stored value for future use, it steps into an area that usually requires licenses and is reserved for banks and licensed financial institutions.
This article breaks down what every company or business offering preloaded credit or membership balances, with or without an app, needs to know.
Below are scenarios that we experience in our daily life.
Scenario 1: I run a tuk-tuk/ride-hailing service and I want to let customers top up USD 20 onto an account, deducted automatically per ride, usable only within my fleet. Do I need a license from the National Bank of Cambodia?
It depends.
The recent Notification No. 14.026.1075 on Obligations of Business Owners Issuing Electronic Money (E-Wallet Account) for Payment of Products or Services within Same Business Network (2026) (“Notification”) of National Bank of Cambodia (“NBC”) addresses about the businesses(such as coffee shop, restaurant, transportation operators) who issues e-wallets or membership cards which allow customers to preload money for payment for the business’s own products or services.
The Notification frames this as “Single-Purpose E-Money”. The customers may create the e-wallet account or top up the balance only to pay for goods or services provided by the issuing business and the Notification routes back to NBC's underlying licensing framework for businesses providing a means of payment.
Under Law on Banking and Financial Institutions (1999), providing payment facilities to customers is generally treated as a “banking and finances” activity. In addition, Article 20(1) of Prakas No. B14.017.161 on the Management of Payment Service Institutions (2017) (“Prakas”) generally prohibits a legal person, other than a banking/financial institution or a licensed payment service institution, from issuing electronic money.
Article 20(2) of the Prakas provides a limited exception where a business may issue certain e-money without obtaining a payment-service institution license if the business has notified NBC in writing and satisfies the following conditions:
an outstanding of each payment account does not exceed a limit of KHR200,000 (approximately USD50) or equivalent;
total outstanding of all payment account does not exceed a limit of KHR800,000,000 (approximately USD200,000) or equivalent;
electronic money service provided for payment of certain goods or services as specified in advance by single natural person;
other conditions as determined by NBC.
Therefore, the “Single-Purpose E-Money” is not automatically exempted from licensing, it only qualifies for the exemption if all of the above conditions are met.
This arrangement of “top-up” balance usable within a single fleet may fall within the concept of “Single-Purpose E-Money”. However, the following points shall be assessed in order to confirm if this Single-Purpose E-Money is qualified for license exemption and only required to notify the NBC:
whether the fleet is operated by a natural person and not a company (see our Food for Thought section),
whether the top-up balance of USD20 satisfies the per-account and aggregate limits discussed above.
Otherwise, the tuk-tuk/ride hailing services may only carry out such top-up arrangement with prior payment-service license from NBC.
Scenario 2: My program doesn't have a mobile app - customers just use a physical card and record their phone number with us. Does the rule to get the license still apply to me, or is it only for businesses with an app?
The absence of a mobile app does not take the programme outside the rules.
The Notification specifically refers to e-money issued through mobile applications or membership cards. Therefore, a business should not assume that it is outside the regulatory framework simply because its stored-value program operates through a physical card, QR code, customer number, or another system rather than an app.
The key question is what the card represents and how the balance operates, rather than what technology is used.
For example:
Customer pays USD 20;
The business records a USD 20 balance against the customer’s card/phone number;
The customer uses that balance to pay for the business’s services; and
The business holds the corresponding value until it is used.
That arrangement may still constitute the issuance of e-money even though there is no mobile application.
So, for business owners, the practical rule is: do not focus only on whether you have an app. Focus on whether you are accepting money in advance and issuing electronic/prepaid value that customers can subsequently use to pay for your goods or services.
Scenario 3: If I don't need a license, does that mean I can just start the program freely, or do I still have to inform the government authority first?
For a qualifying Single-Purpose E-Money arrangement that relies on the Article 20(2) exception in the Prakas, the business may operate without obtaining a payment-service institution license, but it must submit written notification to NBC and comply with the applicable conditions.
This is particularly important because NBC issued the Notification on 6 August 2026 specifically reminding affected businesses of their notification obligation. Businesses already operating such e-wallet/stored-value programs are required to notify NBC within 90 days from the date of the Notification (i.e. by 4 November 2026).
Scenario 4: Is there a limit on how much money I can collect from customers through this kind of program?
Yes.
Under the Article 20(2) conditions reflected in the Prakas:
Maximum balance per customer account: KHR200,000 (approximately USD50), or its equivalent; and
Maximum aggregate outstanding balance across all such accounts: KHR800,000,000 (approximately USD200,000), or its equivalent.
So, for example, a customer should not be permitted to maintain a balance equivalent to USD100 which exceeds the applicable KHR200,000 limit.
Likewise, the business cannot simply have an unlimited amount of customers’ prepaid balances outstanding at the same time. The aggregate outstanding balance must remain within the KHR800,000,000 limit.
Does it mean that the business can never process more than KHR800,000,000 in total transactions over the lifetime of the program? The relevant concept should be the outstanding balance held in the e-money accounts at a given time. The business should therefore have controls that monitor:
each customer's maximum balance; and
the total outstanding balance across all customers.
Scenario 5: What if I want my card to also work at my partner's restaurant next door, not just my own café, does that change anything?
Yes. This can materially change the regulatory analysis.
The Notification specifically describes the relevant arrangement as payment within a single network and requires the e-money to be used for products or services provided by the relevant single business.
This is different from a general-purpose e-wallet such as one that can be used to pay many unrelated merchants, transfer money to other users, or cash out. The latter may fall outside the limited exception and may require the appropriate NBC licensing/authorisation.
Therefore, there is an important difference between:
Example A - likely within the Single-Purpose model
ABC Café issues a stored-value card. The customer can use it at ABC Café’s branches, all operated by the same natural person.
and
Example B - potentially outside the exception
ABC Café issues a stored-value card, but customers can also use the balance to pay at XYZ Restaurant, which is a separate legal entity.
In Example B, the e-money is no longer limited to goods or services provided by the same single business. This may mean that the program does not qualify for the limited Article 20(2) exception, potentially requiring a different regulatory structure or an appropriate NBC licence/authorisation.
Simply calling the businesses "partners" or saying that they are part of the same commercial network does not necessarily mean you are within the same entity. The legal identity of the businesses and the actual flow and use of the funds should be examined.]
💭 Food for Thought:
The Notification makes reference to the business such as coffee shop, restaurant, transportation company, entertainment center, gas station and other business. Further, the Single-Purpose E-Money concept is defined as e-wallet account or top up the balance or payment for goods or services provided by the issuing business/legal person only.
However, one of the conditions for license exemption is “electronic money service provided for payment of certain goods or services as specified in advance by single natural person”.
This raises an open issue as to whether those businesses adopting the Single-Purpose E-Money that are registered as legal entities (e.g. company, sole proprietorship) are in principle excluded from this exemption or whether the Notification tends to also apply this exemption to legal entities provided that they have fulfilled the exemption conditions.
The information in this article reflects the law as at the date of publication and is for general reference only. It does not constitute comprehensive legal advice. If you need further guidance, feel free to reach out to us at connect@vlplaw.co.