MPTC Publishes Framework for Active and Passive Network Sharing

The framework distinguishes passive sharing, which covers towers, shelters, power and transmission, from active sharing, which covers radio equipment and, in more advanced forms, core network elements. Each category is subject to different notification and safeguard expectations.

The framework restates the general principle that sharing arrangements should reduce cost and environmental impact without diminishing competition, service differentiation or subscriber choice.

Passive sharing is broadly encouraged and subject to a light notification process. Active sharing arrangements, including radio access network sharing and multi-operator core network configurations, may be permitted subject to prior review.

Sharing that affects service quality parameters visible to subscribers requires particular attention because customers who purchase differentiated services should continue to receive them.

The framework identifies specific concerns that sharing agreements should avoid, including the exchange of commercially sensitive information beyond what is necessary to operate the shared elements, alignment of retail pricing and coordinated network investment decisions.

Governance arrangements within a sharing venture should include information barriers between the shared operations team and the commercial teams of the participating operators.

Sharing arrangements should be notified to TRC before they take effect. The notification should include the identity of the parties, the scope of the arrangement, the geographic footprint, the expected duration and the competition safeguards adopted.

TRC may request additional information and, in cases raising competition concerns, may impose conditions or require modifications before the arrangement proceeds.

For operators, the framework opens a clearer path to shared deployment, particularly in rural areas where individual deployment is uneconomic. It also raises the bar on documentation and governance for arrangements that already exist informally.

Existing arrangements should be reviewed against the framework and, where necessary, formalised through a notification.

The network sharing framework sits within Cambodia's broader telecommunications legal framework, principally the Law on Telecommunications (2015), the sub-decrees on licensing and spectrum management, and successive Prakas issued by the Ministry of Posts and Telecommunications and the Telecommunication Regulator of Cambodia.

Where a specific instrument has not yet been formally adopted, operators should read announcements together with existing licence conditions, general regulatory duties and international commitments Cambodia has undertaken through the ITU and ASEAN.

Because ministerial and regulatory instruments in Cambodia are frequently updated, compliance teams should not rely on a single Prakas in isolation but should trace the underlying legal basis and any amending texts before assuming a rule applies.

Cambodia-licensed mobile network operators, fixed operators, internet service providers, tower and passive-infrastructure providers, satellite and VSAT operators, equipment importers and vendors, enterprise connectivity buyers and investors evaluating market entry should all monitor the network sharing.

Foreign companies providing cross-border digital services to Cambodian customers should also assess whether their commercial model creates a nexus that brings them within scope, even if they do not hold a Cambodian licence.

Group companies with a Cambodian subsidiary should ensure that head-office compliance policies are localised and do not simply mirror requirements from another jurisdiction, as Cambodian requirements often differ in detail even where the overall policy objective is similar.

Operators should map current internal practices against the direction of the network sharing framework and identify areas where documentation, disclosures, contracts, technical measures or governance need to be strengthened.

A written internal impact assessment — capturing which business lines are affected, which teams own each obligation, and what evidence would be produced in a regulator inspection — is a low-cost step that materially improves readiness.

Where obligations are not yet in force, boards and executive committees should be briefed on likely direction of travel so that budget cycles, procurement decisions and vendor contracts already reflect anticipated requirements rather than being retrofitted later at higher cost.

The network sharing framework does not operate in isolation. Companies should consider how it intersects with data protection expectations, cybersecurity obligations, consumer-protection rules, tax and foreign-exchange controls, and — where relevant — sectoral rules for banking, e-commerce or critical infrastructure.

Contracts with vendors, roaming partners, tower companies, cloud providers and interconnection counterparties should be reviewed to allocate responsibility and cost for any additional obligations that arise.

For groups operating in multiple ASEAN jurisdictions, alignment with regional peers can reduce friction, but Cambodia-specific carve-outs are usually required rather than a purely regional template.

The regulatory calendar in Cambodia often compresses between announcement and effective date. Operators that wait for a formally adopted text before starting work frequently find themselves with only weeks to implement changes that require quarters of preparation.

Legal and compliance teams should establish a monitoring routine covering MPTC and TRC official channels, the Royal Gazette, and industry association updates, and should record the date each new document is reviewed together with a short internal note on its impact.

Where uncertainty remains, engaging early with the regulator through industry associations or bilateral technical meetings is usually more effective than waiting for enforcement action to clarify the intended interpretation.

Lex Civora advises Cambodia-licensed operators, foreign investors and vendors on the practical implications of the network sharing, including gap analyses against existing licence conditions, drafting of internal policies and customer-facing documentation, and structured engagement with MPTC and TRC.

For matters that touch adjacent regimes — data protection, cybersecurity, consumer protection, tax and foreign investment — we coordinate with specialist counsel so that the client receives a single integrated compliance view rather than fragmented advice.

Where a matter is time-sensitive, we can deliver a focused risk brief within a short timeframe to inform board or investment-committee decisions while the full compliance workstream is being scoped.