Cambodia's rules for bad-loan buyers: what NBC-licensed asset management institutions may and may not do

Implications for lenders

With the banking-system NPL ratio at 9.6%, banks and MFIs can consider sales to licensed AMIs, but should budget for NBC approval, valuation documents and the transfer of original documents for each portfolio. Because buyers may not lend, refinance or guarantee loans, a sale cannot be used to roll a borrower into new credit, and lenders may need to keep restructuring options for borrowers who can still pay. Lenders using an AMI for collections remain exposed to conduct risk, so contracts can require the AMI's code of conduct, complaint handling and correct credit-bureau updates.

Implications

Facts

Licence and capital: the National Bank of Cambodia's Prakas on Conditions for Asset Management Institutions (B37-026-113), dated 19 February 2026 and effective from signing, creates a licence for companies that buy and manage non-performing loans. An AMI needs registered capital of at least KHR 200 bn (about USD 50 m) ¹, fully paid in before operations, plus a capital guarantee of 5% of registered capital ² deposited with the NBC. Licences last five years ³ and are renewable; the annual fee is KHR 50 m ⁴. According to DFDL, a licence can be revoked if the AMI does not start operations within six months ⁵.

What an AMI may do (Article 4): acquire and manage NPLs and associated collateral from banks and financial institutions; acquire property through court-ordered auction, provisional administration or liquidation; provide debt collection services to banks and financial institutions; facilitate collateral sales with the debtor's consent; and sell loans to banks or other AMIs.

What it may not do (Article 5): make loans or refinance, give loan guarantees, or buy NPLs from an institution that has lent to it directly or indirectly.

Transfers and conduct: a bank or MFI needs prior NBC approval to sell NPLs to an AMI, supported by a board resolution and valuation documents (Article 17). It must transfer original loan documents and formally notify the customer and the credit reporting service provider. AMIs must adopt a code of conduct for all debt collection and train staff on it (Article 18), follow consumer complaint rules, and meet credit-reporting obligations. Governance rules require a board with independent members, and NBC approval for board and senior appointments and for outsourcing. Records must be kept for at least 10 years ⁶ after an NPL is finally resolved (Article 24), and daily fines for breaches range from KHR 1 m to 3 m a day ⁷ (Article 34).

Next steps: AMRO has published terms for technical assistance to the NBC on further AMI rules, including a capital adequacy framework, valuation and transparency standards, transfer guidelines and coordination with ministries on tax treatment, out-of-court mechanisms and property registration.

Analysis

Time series: the NBC's NPL ratio rose from 8.9% ⁸ at end-2025 to 9.6% ⁹ in June 2026, up from 8.4% at end-June 2025, while restructured loans stood at 7.5% ¹⁰ of the portfolio. The chart shows the rise at each published reading. A licensed buyer gives lenders an exit for loans that do not cure, but the rules require each sale to be approved case by case and priced at arm's length, so the AMI route adds an option rather than a fast clearing channel.

Cross-country: Vietnam chose a state-owned model. Decree 359/2026/ND-CP set up an Asset Management Company with charter capital of VND 5 trillion (about USD 190 million) ¹¹, and a credit institution with an NPL ratio at or above 3% ¹² that does not sell bad debts to it may face SBV measures. Cambodia's framework relies on private licensed buyers and voluntary sales. Its success therefore depends on whether investors will price and fund loans whose collateral can take years to realise through the courts; a Phnom Penh-based investment adviser told CamboJA News he doubted investor appetite for that reason.

Counterpoints and uncertainties

The Prakas sets conditions but does not guarantee buyers: the sources cited name no licensed AMI so far. Pricing may stay far apart if sellers value collateral above what buyers can recover, and cross-agency arrangements on tax treatment, out-of-court mechanisms and property registration are still being worked on with ministries. A sale moves a loan off one balance sheet but does not change the borrower's debt, so over-indebted households may face a new collector rather than relief.