Cambodia: Building Foundations for a Digital and AI-Ready Future

Cambodia is in the early stages of building its AI governance foundations, moving methodically through readiness assessments, strategy drafting, and foundational data protection legislation. The country completed a UNESCO-led AI Readiness Assessment in July 2025, the fourth ASEAN nation to do so, which identified significant gaps in workforce capacity, infrastructure, and data quality. The Ministry of Post and Telecommunications (MPTC) is leading the development of a Draft National AI Strategy 2025-2030 (Version 5), which outlines six strategic priorities and 41 concrete measures. Cambodia does not yet have a comprehensive national AI law, but the government is pursuing a 'regulate, not strangulate' approach that prioritises building enabling conditions before imposing binding requirements. A Personal Data Protection Law is in final draft form and awaiting legislative passage. Through its participation in ASEAN AI governance working groups and forums, Cambodia is aligning its emerging framework with regional standards whilst addressing unique local challenges including low AI literacy, limited high-quality Khmer-language datasets, and infrastructure constraints.

Cambodia's AI governance landscape is evolving on multiple fronts simultaneously. The Draft National AI Strategy 2025-2030 underwent extensive development through 12 internal meetings, two rounds of technical UN-ESCAP review, and a deep-dive workshop in Phnom Penh in April 2025 before opening for public consultation in June 2025. The strategy defines six priorities: human resource development, data and infrastructure, AI for digital government, sectoral AI adoption, ethical and responsible AI, and collaboration and innovation. MPTC established a Working Group on AI and Data Science Research and Development in April 2024 and is preparing both a National AI Governance Framework and Cambodian Guidelines on AI Governance and Ethics. The Personal Data Protection Law, modelled significantly on the EU's GDPR, reached its final draft in July 2025 and awaits legislative passage with a two-year implementation period expected. A Cybersecurity Law remains in draft form, delayed by concerns from international human rights organisations about its scope. Cambodia's AI governance portal at ai.gov.kh now serves as the official information hub for governance initiatives. The National AI and Data Science Center is under development with support from the French Agency for Development (AFD), announced in March 2026, to provide shared high-performance computing infrastructure.

Government agencies across all ministries face new digital transformation requirements as the National AI Strategy mandates AI integration in public services and digital government operations. The technology sector, though small, faces both opportunity and regulatory preparation as the Personal Data Protection Law introduces GDPR-aligned obligations for all private sector organisations and NGOs processing personal data. Educational institutions are central to the strategy, with a government target of training 1,000 AI and data science professionals by 2030, though only one-third of university graduates currently pursue STEM fields. Agriculture, a dominant sector, faces unique AI readiness challenges: many farm-level records remain manual, and the digitisation required for AI-driven productivity gains is still nascent. Financial services companies, particularly fintech operators handling Cambodia's rapidly growing digital payment ecosystem (1 billion transactions through e-wallets), will face data protection compliance obligations. International development organisations play an outsized role, with UNESCO, UN-ESCAP, and AFD actively supporting governance capacity building. Foreign investors should note that while Cambodia's regulatory environment remains permissive, the direction of travel is toward structured governance aligned with ASEAN frameworks.

Cambodia's emerging AI governance approach draws from multiple sources. The ASEAN Guide on AI Governance and Ethics serves as the primary regional reference, with MPTC having participated in the preparation and adoption of the guide, the Expanded ASEAN Guide for Generative AI, and the ASEAN Responsible AI Roadmap 2025-2030. The Draft National AI Strategy embeds ethical and responsible AI as one of its six strategic priorities, reflecting a commitment to rights-based and human-centred governance. Cambodia's approach has a distinctive cultural dimension: UN-ESCAP has explored the integration of Buddhist values in AI development through its 'Generous AI' initiative, emphasising compassion and inclusiveness as governance principles. Transparency and accountability feature prominently in the draft strategy and forthcoming AI governance guidelines. The 'regulate, not strangulate' philosophy articulated by Secretary of State Keo Sothie reflects a pragmatic recognition that premature binding regulation could stifle an AI ecosystem that is still forming. Data protection principles in the draft Personal Data Protection Law align with GDPR standards, establishing consent, purpose limitation, data minimisation, and individual rights. The overall governance architecture emphasises multi-stakeholder engagement, with the government, private sector, civil society, and international partners each assigned roles in the draft strategy.

Cambodia's business environment for AI remains largely unregulated but is moving toward structured governance. Companies should prepare for the Personal Data Protection Law, which will introduce consent requirements, purpose limitation, data subject rights, and mandatory data protection impact assessments once enacted. The two-year implementation period following passage provides a compliance runway. The digital economy is growing rapidly, with transaction values reaching $1.62 billion in 2023 and projected to reach $2.87 billion by 2027. The fintech sector is particularly dynamic, with 19.5 million e-wallet users as of 2022. These growth sectors will be the first to feel regulatory impact. The National AI Strategy identifies digital government, agriculture, healthcare, and education as priority sectors for AI adoption, creating opportunities for technology providers and consultants. However, infrastructure constraints remain real: Cambodia lacks data centres capable of training advanced AI systems, and compute capacity is limited. The government's partnership with AFD to establish a National AI and Data Science Center will help, but commercial options remain thin. Businesses should also note the workforce pipeline challenge. With a government target of only 1,000 AI-trained professionals by 2030 and limited STEM graduate output, companies may need to invest in their own training programmes or recruit regionally.

The most immediate development is the passage of the Personal Data Protection Law, which has reached final draft stage and could be promulgated in late 2025 or early 2026. This will be Cambodia's first comprehensive data protection legislation and will indirectly shape AI governance by establishing rules for personal data processing. The finalisation of the National AI Strategy 2025-2030 following public consultation will provide the definitive roadmap for government priorities and investment. The establishment of the National AI and Data Science Center with AFD support will be a critical infrastructure milestone, providing shared high-performance computing resources that Cambodia currently lacks. MPTC's forthcoming Cambodian Guidelines on AI Governance and Ethics will translate regional ASEAN frameworks into local context. Cambodia's Government AI Readiness ranking improved 27 positions from 145th to 118th globally between 2024 and 2025, indicating accelerating institutional capacity. The country's active participation in the ASEAN Working Group on AI Governance and the AI Safety Network will continue to shape its domestic approach. Dedicated AI legislation remains several years away, but the foundational building blocks of data protection, strategy, governance guidelines, and institutional capacity are being assembled in a deliberate sequence.