Environmental Impact Assessment (EIA): The case of Cambodia
What Responsible Investors Need to Know
β Overview of Environmental Impact Assessment in Cambodia
β Legal and Institutional Framework for EIA
βΆCore Legal Instruments
β Legal Requirement for EIA
β Types of Projects Requiring EIA
βΆClassification of Environmental Assessment
βΆProject Sectors Commonly Requiring EIA
β Who Can Conduct an EIA Study in Cambodia?
βΆAccreditation Requirement
βΆConditions for EIA Consultant Accreditation
βΆForeign Consultants
β EIA Process Flow in Cambodia
Step β: Screening
Step β: Scoping
Step β: EIA Study and Report Preparation
Step β: Public Consultation and Disclosure
Step β: Submission and Review by Ministry of Environment
Step β: Project Approval and Licensing
Step β: Implementation, Monitoring, and Compliance
β Penalties for Non Compliance with EIA Requirements
βΆTypes of Non Compliance
βΆAdministrative Penalties
βΆFinancial Penalties (Fines)
βΆCriminal and Civil Liability
βΆPenalties for EIA Consultant Companies
β Who Can Conduct an EIA Study in Cambodia?
β Overview of EIA in Cambodia
Environmental Impact Assessment (EIA) is a mandatory environmental safeguarding tool in Cambodia, designed to ensure that development projects are planned and implemented in a manner that prevents, minimizes, or mitigates adverse environmental and social impacts. The EIA system supports Cambodia’s national objectives for sustainable development, natural resource protection, and public participation in decision making.
In Cambodia, EIA applies to both public and private development projects, including proposed, existing, and ongoing activities that may significantly affect the environment. All EIA reports are reviewed and approved by the Ministry of Environment (MoE) prior to project approval by relevant authorities.
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ββ Legal and Institutional Framework for EIA
ββΆ Core Legal Instruments: The Environmental Impact Assessment system in Cambodia is governed by the following key laws and regulations:
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Law on Environmental Protection and Natural Resource Management (1996)
This framework law establishes the obligation to assess environmental impacts for development projects and mandates environmental safeguards in project planning and implementation. -
SubβDecree No. 72 α’αααα.αα on Environmental Impact Assessment Process (1999)
This is the principal regulation governing EIA procedures in Cambodia. It:-
Requires EIAs for all public and private projects listed in its annex;
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Mandates MoE review and approval before project authorization;
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Requires monitoring of Environmental Management Plans (EMP) throughout the project lifecycle.
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Environmental and Natural Resources Code (2023)
The Code modernizes Cambodia’s environmental governance and strengthens EIA enforcement, monitoring, and consultant accreditation requirements. -
Prakas No. 3591.0525αααα α.ααα/αα α on Classification of Development Projects for EIA (2025)
Issued by the Ministry of Environment, this Prakas replaces Prakas No. 021αααα α.ααα (2020) and expands the classification of projects requiring environmental review from 197 to 238 project types, with clearer screening thresholds and timelines.
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β Legal Requirement for EIA
Under Cambodian law:
• No project may be approved or implemented without MoE consideration of its environmental assessment.
• The type of environmental document required depends on the project’s scale, sector, and potential impacts.
• Compliance with approved Environmental Management Plans (EMP) is legally binding and subject to inspection and enforcement by the MoE.
Failure to comply may result in:
• Suspension or cancellation of approval,
• Administrative penalties,
• Revocation of operating licenses.
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β Types of Projects Requiring EIA in Cambodia
ββΆClassification of Environmental Assessment: Under Prakas No. 3591.0525αααα α.ααα/αα α on Classification of Development Projects for EIA (2025), development projects are classified into three categories:
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Low Environmental and Social Impact Projects
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Require an Environmental Protection Contract (EPC) and EMP
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MoE review period: up to 30 working days.
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Medium Environmental and Social Impact Projects
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Require an Initial Environmental Impact Assessment (IEIA)
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MoE review period: up to 60 working days.
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High or Serious Environmental and Social Impact Projects
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Require a Full Environmental Impact Assessment (FEIA)
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MoE review period: up to 90 working days.
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βΆProject Sectors Commonly Requiring EIA: Projects commonly subject to IEIA or FEIA include:
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Hydropower and energy projects
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Mining and quarrying
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Industrial manufacturing plants
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Special economic zones (SEZs)
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Infrastructure (roads, ports, airports, railways)
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Tourism resorts and large real estate developments
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Agroβindustry and plantation projects
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Waste treatment and landfill facilities.
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β Who Can Conduct an EIA Study in Cambodia?
ββΆAccreditation Requirement: Since February 2024, only Ministry of Environment–accredited EIA consultant companies are legally permitted to conduct EIA studies in Cambodia.
This requirement is established under Prakas No. 08 αααα.α.ααα/αα α (2024) on Accreditation of EIA Consultant Companies.
Only MoE licensed companies may prepare IEIA, FEIA, and related EIA reports for submission and approval.
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βΆConditions for EIA Consultant Accreditation: To be accredited by the MoE, an EIA consultant company must:
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Be legally registered in Cambodia;
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Possess a qualified organizational structure, including:
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Director
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General Manager
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Technical Team Leader
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Environmental Experts
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Demonstrate technical capacity and experience;
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Obtain an official Letter of Approval (EIA License) valid for 5 years, renewable upon reβregistration.
βΆForeign Consultants: Foreign EIA companies may participate only if:
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They are accredited by the MoE; or
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They cooperate formally with a licensed Cambodian EIA consultant company.β
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β EIA Process Flow in Cambodia
β Environmental Impact Assessment (EIA) Process Flow in Cambodia
The Cambodian EIA process is mandatory, sequential, and approval driven, overseen by the Ministry of Environment (MoE). A project cannot legally proceed without compliance.
βΆStep 1: Screening
Purpose: To determine whether an EIA is required and what level of assessment applies.
Process:
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The project proponent submits basic project information to the MoE or relevant line ministry.
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Screening is conducted using the project classification list under Prakas No. 3591.0525 αααα.α.ααα/αα α (2025).
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Projects are categorized as:
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Environmental Protection Contract (EPC)
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Initial Environmental Impact Assessment (IEIA)
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Full Environmental Impact Assessment (FEIA)
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Legal basis: Sub Decree No. 72 α’αααα.αα on Environmental Impact Assessment Process (1999) under MoE; Prakas No. 3591.0525αααα α.ααα/αα α on Classification of Development Projects for EIA (2025)β
βββΆStep 2: Scoping
Purpose: To identify key environmental and social issues that must be assessed.
Process:
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Conducted for IEIA and FEIA projects.
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Defines:
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Spatial and temporal boundaries
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Key impacts (environmental, social, health, cultural)
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Methodologies and baseline data requirements
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Stakeholder concerns must be incorporated.
Output: Terms of Reference (ToR) for the EIA study.
Legal basis: Sub Decree No. 72 α’αααα.αα on Environmental Impact Assessment Process (1999) under MoE
ββββΆStep 3: EIA Study and Report Preparation
Purpose: To assess impacts and propose mitigation and management measures.
Key Components:
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Baseline environmental and social conditions
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Impact identification and significance assessment
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Alternatives analysis (including “no project” option)
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Environmental and Social Management Plan (EMP)
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Monitoring and reporting framework
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Budget and institutional responsibilities
Important rule: The EIA report must be prepared by an MoEβaccredited EIA consultant company.
Legal basis: Sub Decree No. 72 α’αααα.αα on Environmental Impact Assessment Process (1999) under MoE; Prakas No. 08 αααα.α.ααα/αα α (2024) on EIA consultant accreditation (2024)
βββΆStep 4: Public Consultation and Disclosure
Purpose: To ensure transparency and community participation.
Process:
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Mandatory consultation with affected communities and local authorities.
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Public concerns must be documented and addressed in the EIA report.
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Applies mainly to IEIA and FEIA projects.
Legal importance: Failure to conduct meaningful consultation is a frequent cause of EIA rejection.
Legal basis: Sub Decree No. 72 α’αααα.αα on Environmental Impact Assessment Process (1999) under MoE; Law on Environmental Protection and Natural Resource Management (1996)
βββΆStep 5: Submission and Review by Ministry of Environment
Process:
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EIA report is submitted to MoE’s Department of EIA Review.
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MoE coordinates with relevant line ministries and technical agencies.
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Review timelines (indicative):
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EPC: up to 30 working days
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IEIA: up to 60 working days
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FEIA: up to 90 working days
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Outcome:
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Approval
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Conditional approval (with required revisions)
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Rejection
Legal basis: Prakas No. 3591.0525αααα α.ααα/αα α on Classification of Development Projects for EIA (2025)β
βΆStep 6: Project Approval and Licensing
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A project can only be approved by the relevant authority after MoE approval of the EIA.
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The approved EIA becomes a legally binding document.
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EMP conditions must be integrated into project licenses.
Legal basis: Sub Decree No. 72 α’αααα.αα on Environmental Impact Assessment Process (1999) under MoE, Articles 3–5
βββΆStep 7: Implementation, Monitoring, and Compliance
Purpose: To ensure environmental commitments are carried out.
Process:
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Project proponent implements the EMP.
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MoE conducts inspections during:
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Construction
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Operation
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Closure/decommissioning
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Monitoring reports must be submitted periodically.
Legal basis: Sub Decree No. 72 α’αααα.αα on Environmental Impact Assessment Process (1999) under MoE; Environmental and Natural Resources Code (2023)
β Penalties for Non Compliance with EIA Requirements
β Strategic Takeaways
β Penalties for Non Compliance with EIA Requirements
βCambodia has strengthened enforcement powers under recent reforms. Nonβcompliance can trigger administrative, financial, and operational sanctions.
βΆTypes of Non Compliance
Examples include:
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Starting a project without EIA approval
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Using an unlicensed EIA consultant
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Failing to implement the EMP
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Providing false or misleading information
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Ignoring MoE monitoring instructions
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Failure to conduct public consultation
βΆAdministrative Penalties
The Ministry of Environment may:
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Issue formal warnings
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Order corrective actions
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Suspend EIA approval
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Suspend or revoke environmental licenses
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Temporarily or permanently suspend project operations
Legal basis: Sub Decree No. 72 α’αααα.αα on Environmental Impact Assessment Process (1999) under MoE; Environmental and Natural Resources Code (2023)
βΆFinancial Penalties (Fines)
Under the Environmental and Natural Resources Code (2023):
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Fines may be imposed for:
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EIA violations
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EMP nonβimplementation
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Environmental damage caused by negligence
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Fine levels vary depending on:
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Severity of impact
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Repetition of offense
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Intent (negligence vs. deliberate violation)
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Legal basis: Environmental and Natural Resources Code (2023)
βΆCriminal and Civil Liability
In serious cases, such as:
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Largeβscale environmental damage
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Repeated violations
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Environmental harm to public health
Responsible parties may face:
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Criminal liability
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Courtβordered compensation
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Environmental restoration obligations
Legal basis: Law on Environmental Protection and Natural Resource Management (1996); Environmental and Natural Resources Code (2023)
βΆPenalties for EIA Consultant Companies
MoEβlicensed EIA consultants may face:
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Suspension of accreditation
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Revocation of EIA license
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Blacklisting from future EIA work
If they:
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Submit fraudulent or substandard reports
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Violate professional or ethical obligations
Legal basis: Prakas No. 08 on Accreditation of EIA Consultant Companies (2024)
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β CONCLUSION
In Cambodia, Environmental Impact Assessment is a legally binding, centrally administered process that is fundamental to aligning economic growth with environmental stewardship. Recent regulatory reforms—particularly in project classification and consultant accreditation—have significantly enhanced transparency, accountability, and technical quality.
Today, EIA compliance is a nonβnegotiable prerequisite for project approval and a cornerstone of longβterm project viability. EIA approval, effective Environmental Management Plan (EMP) implementation, and continuous monitoring are enforceable legal obligations, with tangible financial and operational consequences for nonβcompliance.
Relevant Regulatory References
Legal title:
α αααΆααααααΈααΈαα·α αα ααΆαααΆαααα·ααααΆα αα·αααΆααααααααααααααΆαααααααΆαα· ααααΆαα‘α©α©α¦
Law on Environmental Protection and Natural Resource Management (1996)
Ministry/Institution:
Ministry of Environment
Legal title:
αααααΆαααα α α’α‘ αααα α.ααα ααααΈααΈα αααΆααααααΆααααααΆαααΆααααααα ααα»αααααΆααααα·ααααΆααααααΆααααααααα’αα·αααααα ααααΆαα’α α’α
Prakas No. 021 αααα α.ααα on the classification of environmental impact assessments (EIA) for development projectsβ (2020)
Ministry/Institution:
Ministry of Environment
Legal title:
αααααΆααααβ α α¨αααα α.ααα/αα α ααααΈααΈαααααααα αα·αααΈαα·αα·ααΈ αααααΆααα α»ααααααΈααα½αααααΆαααααα»αα αα»αααΈααααΉααααΆααΆααααααα ααα»αααααΆααααα·ααααΆα ααααΆαα’α α’α€
Prakas No. 08 αααα α.ααα/αα α on Accreditation of EIA Consultant Companies (2024)
Ministry/Institution:
Ministry of Environment
Legal title:
αααααΆαααα α£α₯α©α‘.α α₯α’α₯ αααα α.ααα/αα α ααααΈααΈα αααΆααααααΆααααααααα’αα·αααααααααΆααααΆαααΆααααααα ααα»αααααΆααααα·ααααΆα ααααΆαα’α α’α₯
Prakas No. 3591.0525αααα α.ααα/αα α on Classification of Development Projects for EIA (2025)
Ministry/Institution:
Ministry of Environment
Legal title:
α’αα»ααααΉαααααα α§α’α’αααα.αα ααααΈααΈαα·α αα ααααΎαααΆαα αΆααααααα ααα»αααααΆααααα·ααααΆα ααααΆαα‘α©α©α©
Sub Decree No. 72 α’αααα.αα on Environmental Impact Assessment Process (1999)
Ministry/Institution:
Royal of Government of Cambodia
