Your Cambodian customer or buyer is asking for ESG information. Here is what the regulatory environment requires โ and what international buyers need from you.
Cambodia is a major supplier in global garment, footwear, and electronics supply chains, with the garment sector accounting for approximately 80% of Cambodia's export earnings. Cambodia's ESG regulatory framework is developing, with the Securities and Exchange Regulator of Cambodia (SERC) introducing sustainability reporting requirements for listed companies. However, the primary ESG compliance pressure on Cambodian suppliers comes from international buyers subject to EU CSRD, CSDDD, UK Modern Slavery Act, and US trade preference conditions. Labour rights โ particularly freedom of association, living wages, and working conditions in garment factories โ are the central ESG issue for Cambodian suppliers to international buyers.
Key regulations in Cambodia โ ESG Supplier Guide
SERC Sustainability Reporting โ Listed Companies
The Securities and Exchange Regulator of Cambodia (SERC) has introduced sustainability reporting requirements for companies listed on the Cambodia Securities Exchange (CSX). Listed companies are required to disclose ESG information in their annual reports, covering environmental performance, social responsibility, and governance. The framework is aligned with GRI Standards and is being progressively strengthened. Cambodia's capital market is small and developing, so the primary ESG compliance pressure on Cambodian companies comes from international buyer requirements rather than domestic regulation.
EU CSDDD โ Corporate Sustainability Due Diligence Directive
EU companies sourcing from Cambodia โ particularly in garments, footwear, and electronics โ will be required under CSDDD to conduct human rights and environmental due diligence across their supply chains. Cambodian suppliers will receive questionnaires on labour practices, freedom of association, environmental management, and anti-corruption compliance. The garment and footwear sectors are primary targets given their scale in Cambodia's export economy.
EU Everything But Arms (EBA) Trade Preferences โ Sustainability Conditionality
Cambodia benefits from the EU's Everything But Arms (EBA) trade preference scheme, which provides duty-free access to the EU market for least developed countries. EBA preferences are conditional on compliance with core human rights and labour rights conventions. The EU partially withdrew Cambodia's EBA preferences in August 2020 following concerns about political and labour rights. The partial withdrawal affects garments, footwear, and travel goods. Cambodian exporters in affected sectors face higher EU tariffs and must demonstrate compliance with labour rights standards to support any future restoration of full EBA preferences.
UK Modern Slavery Act 2015
UK companies sourcing from Cambodia's garment and footwear sectors are required to publish annual Modern Slavery Act transparency statements disclosing steps taken to identify and address modern slavery risks. Cambodia's garment sector has documented risks including debt bondage, recruitment fees, and restrictions on freedom of association. UK buyers must conduct due diligence on Cambodian suppliers and may require suppliers to complete labour rights questionnaires and third-party social audits.
Cambodia Labour Law and ILO Core Conventions
Cambodia's Labour Law provides for freedom of association, collective bargaining, minimum wages, and workplace health and safety. Cambodia has ratified ILO core conventions. However, implementation and enforcement have been inconsistent, and international buyers conduct independent assessments of Cambodian suppliers' labour practices. The Cambodian garment sector has a history of labour disputes, factory fires, and building safety incidents. International buyers require Cambodian garment suppliers to demonstrate compliance with the Better Work Cambodia programme standards and buyer-specific codes of conduct.
Cambodia Data Protection & Cyber Obligations
Cambodia's Law on Telecommunications (2015) and the Sub-Decree on Electronic Commerce provide limited data protection provisions. The Ministry of Post and Telecommunications (MPTC) oversees telecommunications cybersecurity and operates CamCERT (Cambodia Computer Emergency Response Team). Cambodia does not yet have a comprehensive data protection law or mandatory breach notification regime. International buyers from the EU, UK, or USA will assess Cambodian suppliers โ particularly in the garment and manufacturing sectors โ against their own data protection standards under CSRD and CSDDD supply chain due diligence. Suppliers should implement incident response procedures aligned with international best practice.
What this means for you as a supplier
Cambodian suppliers โ particularly in garments, footwear, and electronics โ face ESG requirements primarily from international buyers rather than domestic regulation. EU buyers subject to CSDDD will require supply chain due diligence evidence from Cambodian suppliers from July 2029. UK buyers require Modern Slavery Act compliance evidence. US buyers may require compliance with the Responsible Business Alliance (RBA) Code of Conduct for electronics suppliers. The central ESG issues for Cambodian garment suppliers are: freedom of association and collective bargaining rights, living wage compliance, workplace health and safety, building structural safety, and absence of forced labour and child labour. Participation in the Better Work Cambodia programme โ a joint ILO/IFC initiative โ is increasingly a buyer requirement and provides a recognised framework for demonstrating labour compliance.
Key dates
August 2020
EU partial EBA withdrawal โ garments, footwear, and travel goods from Cambodia face higher EU tariffs
2024 (ongoing)
Better Work Cambodia โ ILO/IFC programme assessments ongoing; buyer requirement for garment sector suppliers
July 2029
CSDDD Phase 1 โ largest EU companies must conduct supply chain due diligence including Cambodian suppliers
Better Work Cambodia: the recognised compliance framework
Better Work Cambodia is a joint programme of the International Labour Organization (ILO) and International Finance Corporation (IFC) that assesses garment factories against ILO core labour standards and national labour law. Better Work Cambodia conducts factory assessments covering freedom of association, collective bargaining, discrimination, forced labour, child labour, compensation, contracts, occupational safety and health, and working time. Assessment reports are shared with participating buyers. Participation in Better Work Cambodia is increasingly a requirement for supplying major international fashion brands and retailers. Cambodian garment factories that are not enrolled in Better Work Cambodia should consider joining as a way to demonstrate labour compliance to international buyers.
EBA partial withdrawal: impact on EU market access
The EU's partial withdrawal of EBA trade preferences from Cambodia in August 2020 โ the first such withdrawal in EBA history โ has significant implications for Cambodian garment and footwear exporters. Affected products now face EU tariffs of 12% for garments and 12โ17% for footwear, compared to zero under full EBA. The withdrawal was triggered by concerns about restrictions on political rights and labour rights, including the dissolution of the main opposition party and restrictions on trade union activity. Cambodian exporters in affected sectors should monitor EU-Cambodia trade relations and engage with their buyers on the tariff impact. The EU has indicated that full EBA preferences could be restored if Cambodia demonstrates sustained improvement in human rights and labour rights.
Electronics sector: RBA Code of Conduct requirements
Cambodia's electronics sector โ including assembly operations for international brands โ is subject to the Responsible Business Alliance (RBA) Code of Conduct, which sets standards for labour, health and safety, environment, and ethics in global electronics supply chains. RBA member companies require their Cambodian suppliers to complete the RBA Self-Assessment Questionnaire (SAQ) and may conduct or commission RBA Validated Audit Process (VAP) audits. Key RBA requirements for Cambodian electronics suppliers include: no recruitment fees charged to workers, freely chosen employment, working hours within legal limits, safe working conditions, and environmental management systems. Cambodian electronics suppliers should familiarise themselves with the RBA Code of Conduct and prepare for buyer audits.
Last reviewed: April 2026. This guide is for general information only and does not constitute legal advice. Regulations change โ verify current requirements with a qualified adviser.
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