TRC Publishes Revised Type Approval Fee Schedule

The revised schedule restructures fees for equipment type approval, distinguishing between initial applications, amendments, renewals and administrative changes. Fees vary by equipment category, technology and complexity of the technical file.

The revision reflects an effort to align fee levels with the actual resource cost of review while maintaining accessibility for smaller applicants.

The schedule introduces a distinct fee for family approvals, where multiple variants of the same base design are approved together. This can significantly reduce the cost of certifying a product line, provided the variants are technically close.

Certificate maintenance fees are introduced for the continued validity of certificates over their lifetime, replacing the previous approach of renewal-only charging.

For frequent importers, the family approval option is the most consequential change. Product roadmaps should be structured to take advantage of family approvals where the technical variance permits.

For occasional importers, the practical impact is modest, though the introduction of certificate maintenance fees means that legacy certificates on discontinued products should be closed formally to avoid unnecessary cost.

Regulatory fee budgets for the coming financial year should be recalculated against the revised schedule. Where the revision leads to material increases, procurement contracts that assumed the previous schedule may need commercial adjustment.

The type approval fee schedule revision 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 type approval fees.

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 type approval fee schedule revision 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 type approval fee schedule revision 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 type approval fees, 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.