31 Oct 2026 · Vietnam VI

Citizenship · Capital · Global Mobility

The Legation Times

Naturalisation by investment/donation (Sub-Decree No. 225/2025)

Cambodia Citizenship by Investment

Open verified 2026-09-20 · cdc.gov.kh

Under Nationality Law No. 96, those who donate 1,000,000,000 riels or more to the national budget or spend initial investment capital of 1,250,000,000 riels or more may be considered for Cambodian naturalisation by Royal Decree; Sub-Decree No. 225 of 2025 is reported to have raised the levels, but the original has not been checked. The investment door still requires a residence in Cambodia on filing, the donation door does not, and according to Prosperous Intelligence the Cambodian passport reaches 42 destinations without applying for a consular visa in advance.

Programme overview

  • Official programme name: Naturalisation by investment/donation (Sub-Decree No. 225/2025)
  • Website: cdc.gov.kh
  • Regulator: Ministry of Interior

Minimum capital threshold

The Act sets three doors at three different levels, and a fourth with no figure at all.

The investment door appears in two consecutive articles at the same threshold but differing on the paperwork that opens it:

Article 10 covers a foreigner who already holds a letter of authorization for investment from the Cambodian Development Council and has concretely implemented the project by spending initial capital of from 1,250,000,000 riels and up.

Article 11 covers a foreigner with no such letter from the Council but who received authorization for investment legitimately from the Royal Government, on the same initial capital of 1,250,000,000 riels and up.

The two differ only in who granted the authorization; the figure is identical.

The third door is donation, Article 12: a donation in cash to the national budget of from 1,000,000,000 riels or more, which the Act ties expressly to the interest of restoration and rebuilding of the Kingdom's economy — so the donation threshold sits 250 million riels below the investment one.

The fourth door is Article 13, for a person who shows evidence of special merit or achievement in the interest of the Kingdom, and it names no figure whatever.

Two things must be read alongside the numbers. First, this English text states within its own body that the Khmer version is the official one, so every figure here is a figure of the translation.

Second, Sub-Decree No. 225 of 1 December 2025 has been reported to raise the levels, but the gazette original could not be checked, so the figures stay as the Nationality Law No. 96 sets them.

Naturalisation is decided by Royal Decree; in law this is a favour of the Kingdom rather than a right of the applicant.

The four doors the Law opens — two investment doors, one donation door and one merit door — all lead to that same outcome, so choosing between them is choosing which entry documents to present rather than choosing what is received.

The sums attached to each door, and the uncertainty around those figures following Decree No. 225, are recorded in the capital threshold cell of this table.

Grant is not the last step. Under Article 17, a person authorised to acquire nationality must take an oath before the Supreme Court, with its wording set by sub-decree.

Article 19 reserves Cambodian identity cards and passports for Cambodian nationals. A foreigner who holds or uses them faces five to ten years' imprisonment under Article 20.

Applicants may ask to take a Khmer name, stating it in writing in the naturalisation application. The law does not require giving up a former nationality; its provision on loss covers only voluntary renunciation by a Cambodian who already holds another nationality.

Published processing time

The Act sets no time limit, and it does not conceal the fact: Article 16 states plainly that the formality and procedure for applying for naturalisation shall be determined by a sub-decree, so the whole question of timing is pushed into subordinate legislation.

What the Act does fix is the form of the destination rather than the distance to it, and that form sits at the highest level: Article 16 provides that naturalisation granted to any person shall be decided by a royal decree.

After the decree comes one further step readers often miss because it does not sit in the procedural part: Article 17 requires a person authorised to acquire Khmer nationality to take an oath before the Supreme Court, the substance of that oath likewise left to a sub-decree.

The true end point of a file is therefore not the date the decree is signed but the date of the oath, and the law attaches a time limit to neither.

Physical residence requirement

The Act sets two separate residence conditions, and what decides matters is that four relief doors do not relieve equally — the donation door waives more than the investment door, which is very easy to read past.

Article 8(3) requires a paper certifying residence in the Kingdom and having lived continuously for seven years from the date of receiving a residence card issued under the Law on Immigration.

Article 8(4) is a different condition, not a restatement of the third: the applicant must have residence in the Kingdom at the time of applying for naturalization.

Now the divergence. Article 9 covers a person born in Cambodia: the seven years drops to three, a reduction rather than a waiver.

Articles 10 and 11, the two investment doors, use one identical formula: the period of living stated in sub-paragraph 3 of article 8 shall be exempted — sub-paragraph 3 only, so sub-paragraph 4 survives and the investor must still have residence in Cambodia when the application goes in.

Article 13, the special-merit door, likewise relieves only sub-paragraph 3 and says so expressly.

But Article 12, the donation door, is not drafted as a waiver at all; it is drafted as a positive list: the donor may file once they have fulfilled sub-paragraphs 1, 2, 5 and 6 of article 8.

Sub-paragraphs 3 and 4 are absent from that list, so both residence conditions fall away. The result is a little-noticed ladder: a person donating one billion riels need not have resided in Cambodia for a single day, while a person investing 1.25 billion riels must still hold residence there on the day of filing.

Dependants admitted

A single article, article 14, contains the whole dependant regime: a foreigner who has a spouse or children under 18 years of age who also intend to apply for Khmer nationality may file an application for naturalisation as a family as a whole, and a family is defined in that same article as a husband, a wife and children under 18.

There is no recognition of an unmarried partner, no parents, grandparents or siblings, and no financial dependency or education condition; the sole criterion for a child is being under 18.

The statute states no additional financial threshold per dependant, since article 14 speaks of filing as one family rather than multiplying the sum.

For comparison, the principal threshold is a donation of 1,000,000,000 riel or more to the national budget under article 12, or an actual investment of 1,250,000,000 riel or more under articles 10 and 11 to be relieved of the residence period.

Two warnings travel with this record: the file itself prints at the foot of every page that the Khmer version is the official version, so the English text is a translation; and Sub-Decree 225 setting out the form and procedure is an image scan with no extractable text, so any per-head fee, if one exists, sits there and remains unread.

Visa-free destinations

A person granted citizenship under this programme receives the Cambodia passport, so the figure in this cell is the figure for that passport itself.

According to the Passport Index of Prosperous Intelligence, on data dated 30 September 2026, the Cambodia passport reaches 42 destinations without applying for a consular visa in advance. The figure combines three forms of entry and does not count an e-Visa that must be obtained beforehand:

Form of entryDestinations
Visa-free20
Visa on arrival19
Electronic travel authorisation (eTA)3
Total, the Passport Index figure42
e-Visa obtained in advance, not counted65

It is therefore a measure of how easily the holder travels, not a count of visa-free countries in the narrow sense.

For comparison, on the same source and the same method of counting, the Vietnamese passport reaches 44 destinations. The two lists of destinations do not nest inside one another, so the difference is an indication rather than a list of places newly opened.

Prosperous Intelligence dates its data and advises checking with the destination’s official authorities before travelling.

Tax obligations arising

The programme carries no tax regime of its own. The English text of the Law on Nationality published by the Council for the Development of Cambodia does not use the words tax, fiscal, revenue or resident; the instrument sets naturalisation conditions and nothing more.

Article 10 waives the residence period for a foreigner who holds an investment authorisation letter from the Council and has actually invested 1,250,000,000 riel or more.

Article 11 applies the same capital threshold to a person holding a lawful investment permit outside the Council route, and Article 12 covers a person donating 1,000,000,000 riel or more in cash to the national budget.

One limit belongs in the record: the text of Sub-Decree 225 of 1 December 2025 implementing the Law on Nationality is an image scan with no text layer, so it could not be read, and finding no mention of tax in that file does not mean the instrument is silent.

This record makes no guess about its contents.

The public sub-decree index of the Council of Jurists likewise does not carry it.

Mandatory costs beyond the investment

The Act names no fee at all, and that silence carries weight because this same Act does speak about money elsewhere.

The Act mentions no fee or charge; the national currency is named only in the thresholds of Articles 10, 11 and 12, namely 1,250,000,000 riels for the two investment doors and 1,000,000,000 riels for the donation door.

In other words, the Act prices the investment but does not price the procedure. Where procedural cost lives is answered indirectly by Article 16: the formality and procedure for applying for naturalisation are to be determined by a sub-decree, so any fee schedule belongs to that instrument rather than to the statute.

The two warnings carried by this record apply here in full. First, the Khmer version is the official one by the English text's own statement, so these are the translation's figures.

Second, the reported rise in the levels under Sub-Decree No. 225 of 1 December 2025 could not be checked against the gazette original — and if a procedural fee schedule exists anywhere, that is precisely the kind of instrument that would carry it.

Investment options

Option Threshold Type Status
Initial investment capital under the Nationality Law, which waives the residence period for naturalisation 1,250,000,000 KHR Business Open

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