Background
Sub-Decree No. 03 establishes Cambodia’s management framework for security and safety at collective accommodation sites where multiple residents or temporary occupants stay in one location. The regime places reporting and record-keeping duties on owners, managers, and responsible persons at sites that host residents, including foreigners, and links local administration with immigration and police oversight.
Collective accommodation under the sub-decree covers a broad range of premises, including borey developments, condominiums, apartments, resorts, bungalows, co-owned buildings, factories, enterprises, farms, special economic zones, economic land concession areas, guesthouses, hotels, dormitories, pagodas, religious buildings, and orphan care centers. The system requires operators to register occupants, report changes in residency, and notify competent authorities of temporarily staying foreigners within 24 hours. Before permitting a foreign national to stay, site operators must obtain documents proving lawful residence status.
The General Department of Immigration said authorities intensified implementation of Sub-Decree No. 03 and imposed strict fines on site owners and other violators, with total fines reported at 1,744,000,000 riel. According to the figures cited by the authorities, 1,720,000,000 riel came from penalties for unlawful stays, calculated at 4,000,000 riel per foreigner, while 24,000,000 riel came from violations related to security system management.
Enforcement Actions
The reported enforcement campaign covered the period from 3 April to 20 April, during which local authorities carried out administrative inspections at 2,696 locations involving 21,259 related persons nationwide. The inspection totals cited by the authorities included 1,045 locations in Phnom Penh, 1,108 in Takeo, 345 in Kratie, 83 in Preah Sihanouk, 56 in Banteay Meanchey, 37 in Kampong Cham, 12 in Mondulkiri, 5 in Oddar Meanchey, 3 in Kandal, 1 in Ratanakiri, and 1 in Siem Reap.
For unlawful stay violations, the authorities reported fines totaling 956,000,000 riel in Phnom Penh, 668,000,000 riel in Preah Sihanouk, 60,000,000 riel in Kandal, 20,000,000 riel in Mondulkiri, and 16,000,000 riel in Siem Reap. For security management violations, the reported fines were 400,000 riel in Mondulkiri and 23,600,000 riel in Kandal.
Compliance Implications
The enforcement figures indicate that compliance exposure extends beyond hotels and guesthouses to residential, industrial, agricultural, and investment-linked sites that accommodate foreign nationals. Operators of factories, enterprises, farms, special economic zones, apartments, and other collective living facilities are expected to maintain occupant records and cooperate with administrative inspections.
The sub-decree also allocates responsibilities to provincial, municipal, district, and khan authorities to direct and monitor implementation, while police commissioners and inspectors support planning and supervision through local administrative police posts. The authorities stated that owners, heads, managers, and responsible persons at collective accommodation sites who fail to perform their obligations may be fined 4,000,000 riel per foreigner, without prejudice to potential criminal liability. Competent officials who fail to perform their duties honestly or intentionally conceal unlawful foreign residents may face disciplinary dismissal, also without prejudice to possible criminal penalties.
Institutional Role
The Ministry of Interior said stricter implementation of Sub-Decree No. 03 is intended to be a continuing priority rather than a one-off campaign. The authorities linked regular inspections and foreigner reporting duties to broader efforts to strengthen local administrative control, manage the presence of foreign nationals, and address social order and security risks, including technology-enabled fraud offenses.
Official Source
General Department of Immigration (GDI), citing statements and enforcement figures released through its official communication channels on 22 April 2026.
