Submarine Cable Landing Station Licensing Framework Clarified

Cambodia's international connectivity has, historically, relied primarily on terrestrial cross-border fibre links with neighbouring countries. As demand for capacity has grown and as regional submarine cable projects have expanded, the Kingdom has moved to establish clearer arrangements for the landing of submarine cables on its territory. The 2023 framework consolidates the authorisation, licensing and technical requirements applicable to submarine cable landing stations and to the operators that own or use them.

The framework is relevant to international cable consortia planning new cable systems, to Cambodian operators seeking to invest in landing infrastructure, to backhaul providers extending capacity from landing stations to major population centres and to enterprise customers whose services depend on the diversity and resilience of international routes.

The framework defines a submarine cable landing station as a facility located on Cambodian territory that terminates one or more submarine cable systems, provides the equipment necessary to convert the transmitted signal into a form suitable for onward transport and connects to domestic terrestrial networks. It distinguishes between the landing station itself, the marine and beach segments of the cable, the terrestrial backhaul from the landing station to major interconnection points, and the international capacity carried over the cable.

Different regulatory treatments apply to these segments. The framework focuses on the landing station and its immediate connections, while ensuring that arrangements at the beach and in the marine segment respect Cambodian sovereignty, environmental rules and coordination requirements with other users of the maritime area.

Under the framework, the establishment and operation of a submarine cable landing station requires specific authorisation from the sector regulator, complementing any general telecommunications licence held by the operator. Authorisation applications are expected to include information about the cable systems to be landed, the ownership structure of the consortium, the intended location of the landing station, the technical characteristics of the equipment to be installed, the planned commissioning date and the intended commercial arrangements for the sale of capacity.

The framework provides for engagement with other authorities responsible for maritime, environmental, spatial planning and security matters, since a submarine cable landing raises issues that go beyond the telecommunications sector alone. Applicants should therefore approach the process with a coordinated project team capable of engaging with each of these authorities and with local communities near the proposed landing point.

Landing stations are expected to be designed to internationally recognised standards, with appropriate provision for reliability, security, power backup, cooling, physical protection and monitoring. The framework encourages arrangements that support resilience, such as diverse routing between landing stations and interconnection points, and clear procedures for detecting and responding to cable faults.

Operators are expected to maintain records of the technical configuration of the landing station, of the cable systems landed and of the capacity in service, and to make relevant information available to the regulator when required. The framework also addresses the treatment of dark fibres, of test capacity used during commissioning and of any spare capacity reserved for future expansion or for civil-protection purposes.

Because submarine cable landing stations are typically bottleneck facilities, the framework addresses the terms on which access is provided to other operators and to enterprise customers. Landing station operators are expected to publish reference terms for co-location, cross-connection and access to backhaul, and to negotiate individual arrangements on reasonable, non-discriminatory terms. Where a landing station operator is vertically integrated with a retail operator or with a backhaul provider, additional safeguards may apply to avoid distortion of competition in downstream markets.

The framework recognises that some cable systems have specific commercial arrangements, such as consortium ownership structures or indefeasible rights of use (IRUs), and does not seek to override those arrangements. However, it insists that access to Cambodian landing stations be sufficiently transparent and predictable to support the development of a competitive market for international capacity in Cambodia.

Landing stations are critical infrastructure. The framework requires that appropriate physical and logical security measures be implemented, that access to the site be controlled, that operational technology be protected against cyber threats and that emergency response arrangements be in place. Operators are expected to notify the regulator promptly of significant incidents affecting the landing station or the associated cable systems and to cooperate in investigations.

The framework also supports coordination on cable protection at sea, including with fishing communities, port authorities and the navy, so that the risk of accidental damage to submarine cables is reduced and so that repair operations can be conducted promptly when incidents occur. Operators are encouraged to participate in regional cooperation mechanisms that facilitate cable protection and repair.

For cable consortia and prospective landing station operators, the framework provides a clearer path for planning investment in Cambodia. Early engagement with the regulator, with the ministries responsible for maritime and environmental matters, and with local authorities near the proposed landing point is essential. Feasibility studies should reflect the full range of authorisations that will be needed and should build in realistic timelines for permitting.

For backhaul providers and Cambodian operators, the framework signals the direction of policy in favour of transparent access to international capacity. Business models based on long-term arrangements with landing station operators should be developed with an understanding of the applicable regulatory expectations and of the potential for further capacity to become available as new cables land in Cambodia.

For enterprise customers and public sector organisations that depend on international connectivity, the framework offers a basis for engaging more actively in the design of resilient connectivity solutions. Diverse routing over multiple cable systems, geographic diversity of landing stations and clear service level arrangements with providers should all be part of enterprise connectivity strategy.

Lex Civora advises cable consortia, landing station operators, backhaul providers and enterprise customers on the authorisation process, the negotiation of access and wholesale arrangements, coordination with maritime and environmental authorities and the development of resilient international connectivity strategies aligned with the 2023 framework.