Paying CDC Fees from 26 October 2026: What the New Digital Invoice Means for QIPs and Investors

What has changed?

Until now, CDC fees have been paid in one of two ways. Applications submitted through the Cambodia Investment Project Management system (cdcIPM) were paid by digital invoice. Other applications, including payments at CDC counters, were paid directly to the responsible unit against a conventional paper receipt.

Instruction No. 1707/26 and Notification No. 1708/26 merge these two tracks into a single digital invoice. The stated aims are to simplify procedures, reduce processing times and increase investor confidence and transparency.

The main operational principles are:

• One invoice for everything: The digital invoice is generated by the CDC's service systems (cdcIPM and cdcService), which are integrated with the CDC's online payment system (cdcOSP).
• 'Pay and Track' QR code: Each invoice carries a QR code generated from the official cdc.gov.kh domain.
• Invoice contents: Company name, name of the applicant or authorised representative, the responsible CDC unit, the services requested and fees payable, payment status (unpaid or paid) and, once paid, the bank transaction reference and the payment confirmation date and time.
• Where you receive it: Directly through the CDC's online systems or at the CDC service counter.

How does payment and tracking work?

The applicant scans the QR code on an unpaid invoice and pays by one of three methods: Bakong KHQR, mobile banking, or an international VISA or Mastercard card. Once payment is made, the invoice status changes to 'paid' and records the bank transaction reference and confirmation date and time.

Scanning the same QR code afterwards shows the status of the service from payment until completion. The Instruction also directs CDC officials to help applicants who visit the counter or ask about progress by checking status through the QR code.

What is the legal status of the paid invoice?

According to Instruction No. 1707/26, a paid digital invoice has the legal value of an original official document verifying that the public service fee has been correctly paid. In practice, it replaces the conventional paper receipts the CDC previously issued and should be retained as the primary supporting document for all CDC fees.

This confirms that the electronic payment receipt generated by cdcOSP constitutes admissible prima facie evidence of public fee settlement for Cambodian administrative and statutory compliance.

Accounting and tax treatment

Corporate accounting departments and tax advisers should note four fundamental principles regarding the digital payment voucher:

• Not a tax invoice: The CDC digital invoice is a CDC payment document. It is not a tax invoice under the Law on Taxation, as the CDC does not issue tax invoices.
• Value Added Tax (VAT): The Instruction does not address VAT. VAT has not in practice been charged on CDC public service fees. If VAT did apply, no input VAT credit could be claimed solely on the basis of this document.
• Withholding tax: As the public service fees are paid directly to a sovereign government body, no withholding tax applies.
• Separate from GDT e-invoicing: The CDC digital invoice concerns statutory fees paid to the CDC only. It is entirely distinct from the Cambodia E-Invoicing System being rolled out by the General Department of Taxation (GDT) for invoicing between businesses (B2B).

What this means commercially

For investors, the change is mainly operational, but it directly touches payment authority, corporate treasury controls, and the timing of investment approvals:

• Who can pay? Many foreign-owned companies rely on local staff or an external agent to handle CDC filings, often with cash advances. These arrangements must now be replaced by an electronic payment route with sufficient limits. CDC fees for QIP registrations and amendments can be substantial.
• Approval workflows: Group policies that require a paper receipt before reimbursement, or that restrict corporate card use, may slow filings unless they are updated to recognise digital payment confirmations.
• Evidence for audits and due diligence: Because the paid digital invoice serves as the proof of payment, it belongs in the company's permanent QIP file alongside the registration certificate and amendment approvals. Gaps in these records can surface in audits and in acquisition due diligence.
• Project timelines: A QIP registration or amendment that is held up by an unpaid invoice delays the incentives and approvals that depend on it. For related statutory investment deadlines, see our insight on the CDC Three-Year QIP Investment Deadline.

What should investors do before 26 October?

A practical 7-step checklist for foreign investors, project sponsors, and finance teams:

Key takeaways

• Instruction No. 1707/26 and Notification No. 1708/26 (25 September 2026) make the CDC digital invoice mandatory from 26 October 2026.
• It applies to all CDC public services, at the counter and online, including QIP registration and amendments.
• Payment is by Bakong KHQR, mobile banking or VISA/Mastercard via a 'Pay and Track' QR code. Direct payment against paper receipts ends.
• A paid digital invoice has the value of an original legal document proving payment and replaces conventional receipts.
• It is not a tax invoice and is separate from GDT B2B e-invoicing.
• Companies should set up payment access, limits and approval workflows before the deadline.

How MLV Law Group can help

MLV Law Group advises foreign investors on registering and maintaining Qualified Investment Projects with the CDC. Our investment team can review your CDC filing and payment arrangements, prepare and manage QIP registrations and amendments, coordinate the timing of pending applications around 26 October 2026, and help you keep compliant records of CDC approvals and payments for audits and transactions. We review each matter and issue a written service proposal.

To discuss your CDC filings, contact our team at legal@mlvlawgroup.com or +855 71 777 4168. For more context, see our Invest in Cambodia / QIP guide and our practice area on Ongoing Compliance, Aftercare and Project Lifecycle Support.