SERC's 2026–2028 Rolling Action Plan: What Cambodia's Securities Regulator Plans Next

At a glance

The Securities and Exchange Regulator of Cambodia (SERC) has published its Three-Year Rolling Action Plan 2026–2028 (Khmer only). It was posted on SERC's website around 9 October 2026, after endorsement on 30 September 2026 by H.E. Aun Pornmoniroth, Deputy Prime Minister, in his capacity as Chair of the Non-Bank Financial Services Authority (FSA) Council. The plan puts into effect the Securities Sector Development Strategy 2025–2035.

• Structure: three strategic pillars: strengthening, expanding and supporting the development of the securities market. Under these sit 13 strategic measures and 59, 64 and 94 activities respectively.*
• Contents: a review of 2025 results, the 2026–2028 rolling plan, a detailed 2026 annual plan with quarterly indicators, and annex tables by department.
• Status: this is a regulator's work programme, not a binding rule. Obligations will arise only when the individual prakas and guidelines it lists are adopted.

What is on SERC's 2026 agenda?

From the 2026 annual plan, the items most relevant to market participants are:*

• Exchange-traded funds: a guideline on the public offering of ETF units, to be prepared and put into effect, and a new SERC office for fund-unit offerings.
• Sustainable finance: continued application of the ESG / sustainability disclosure framework (currently on a voluntary basis), and a draft guideline on sustainability-linked bond offerings, to be completed and implemented.
• Debt market infrastructure: work towards a bond index and bond yield curve. Review of one infrastructure bond offering application is targeted.
• New products and venues: rules on the listing and trading of REITs, rules on equity listings by holding companies, a draft prakas licensing derivatives market operators and their clearing and settlement systems, rules on margin trading, rules on repo / securities lending transactions, and a feasibility study on a carbon credit exchange and an OTC market.
• Intermediaries and fintech: draft prakas on licensing cross-border securities trading services, branch openings by securities firms and CIS operators, codes of conduct for fund managers, securities firms and advisers, and amendments to the prakas on intermediaries' financial soundness requirements. Further rules cover digital assets, securities crowdfunding, P2P lending, supply-chain finance and robo-advice.
• Technology risk: draft guidelines on technology and cyber-risk management, eKYC and outsourcing, plus a move towards risk-based supervision.
• Listed-company oversight: monitoring of corporate governance, disclosure and financial reporting. Specific targets are set (e.g. governance assessment of 12 listed companies), and an IPO and post-IPO financial-analysis system is being rolled out.

What does it mean for issuers, firms and investors?

Listed companies should expect closer, more data-driven review of disclosure, governance and periodic financial reports. SERC is building analytics systems and has set quantified review targets. Voluntary ESG reporting is being actively monitored. Boards should treat it as a direction of travel, not an optional extra.

Prospective issuers have more routes coming. A sustainability-linked bond guideline would sit alongside the green, social and sustainability bond activity already seen on CSX. A yield curve and bond index would help issuers price debt and help investors benchmark it. REIT, ETF and holding-company listing rules could open structures that local groups and real-estate sponsors have so far been unable to use. Existing bond offerings, including those for qualified investors, remain subject to the current rules. The plan does not change them now.

Securities firms and other intermediaries face the heaviest rule-making load: financial-soundness amendments, codes of conduct, branch rules, cyber, eKYC and outsourcing guidelines, and risk-based inspections. Firms should budget for policy updates, IT changes and board time in 2026–2027.

Foreign investors and service providers should watch the cross-border trading prakas, derivatives, margin and securities-lending rules. Together these determine how easily offshore capital and products can reach CSX. Firms considering market entry should time licensing applications to the new frameworks.

What to watch

• Release of draft prakas and guidelines for consultation, especially ETF, sustainability-linked bond, cross-border trading and derivatives operator rules.
• Adoption of the financial-soundness amendments for intermediaries.
• Publication of the cyber-risk, eKYC and outsourcing guidelines.
• Progress on the bond yield curve and bond index.
• SERC's quarterly and annual progress reporting. The FSA Council reviews annual results.

Key takeaways

• The plan is a roadmap: no new obligations arise until each instrument is adopted.
• 2026 is heavy on product rules (ETF, REIT, sustainability-linked bonds) and on intermediary regulation (soundness, conduct, cyber).
• Issuers and firms that engage early in consultations can influence the final rules.

How MLV Law Group can help

MLV Law Group advises issuers, securities firms and investors on Cambodian capital-markets matters. Our services include:

• structuring equity and bond offerings, including green, social and sustainability-linked issues and offerings to qualified investors;
• SERC licensing and approvals;
• disclosure and governance compliance for listed companies;
• gap analyses against new prakas as they are issued;
• preparing consultation submissions.

We review each matter and issue a written service proposal. To discuss your requirements, contact our team at legal@mlvlawgroup.com or +855 71 777 4168. For related practice areas, see our expertise on Securities Litigation and Digital Asset Service Provider (DASP) Licensing.

Official sources

• SERC, Three-Year Rolling Action Plan 2026–2028 (Khmer)

• Summary: DG Cambodia, 9 October 2026

*Translated from the Khmer original by MLV Law Group. Item descriptions and figures should be checked against the official text.*