Inclusive Policy Governance & GEDSI

API has a successful history of pushing for policy changes and helping other organizations build their skills to achieve similar goals. In the last 20 years, API has played a key role in getting 15 important laws and policies created or improved.

 

API leads the Access to Information (A2I) Working Group, which includes 18 organizations. The group has played a crucial role in advocating important provisions such as the protection of sensitive personal information and ensuring that the law promotes inclusivity by guaranteeing access for all segments of society, including marginalized groups. Despite these ongoing efforts, Cambodia still does not have a formal Access to Information law as of October 2025.

 

Efforts to develop such a law have been ongoing for many years. In August 2007, the Government completed a Draft Policy Paper on Freedom of Information. The main opposition party introduced draft Access to Information bills in 2010 and 2012; however, these bills were not approved by Parliament. In 2013, under the leadership of API, the A2I Working Group developed a Model Law that drew on international standards and Cambodia’s specific needs, incorporating input from civil society, government officials, and members of Parliament.

 

In 2015, the Government established a technical working group tasked with preparing a draft law. API led public consultations before the release of the first government draft. The most recent draft of the law was published in April 2020. While the Government had initially planned to pass the law in 2016, the process was delayed until 2020. In January 2023, Prime Minister Hun Sen stated that the law might be approved after the 2023 elections, potentially in 2024 or 2025.

 

During the 46th session of the United Nations Universal Periodic Review, the A2I Working Group provided legal advice and recommendations on Access to Information legislation, anti-corruption measures, and digital rights.

 

There have been four main versions of Access to Information law proposals in Cambodia:

• The policy framework on Access to Information led by the Ministry of National Assembly & Senate Relations.
• The Model Law on Access to Information developed by API and submitted to the Government and Parliament.
• Two draft laws proposed by the Cambodia National Rescue Party.
• Draft laws developed by the Ministry of Information in 2018 and 2020.

 

API’s leadership has been pivotal in pushing for the clear demands of civil society organizations, focusing on integrating nine internationally recognized principles into Cambodia’s A2I law. These principles are:

• Maximum Disclosure: Presumption that all information held by public bodies is accessible, except under limited, justified exceptions.
• Obligation to Publish: Public bodies must proactively publish key information about their operations, policies, decisions, budgets, and activities without waiting for requests.
• Promotion of Open Government: Governments should actively promote transparency through training, awareness campaigns, and improved information management.
• Limited Scope of Exceptions: Exceptions must be lawfully defined, narrowly drawn, and justified by potential harm to legitimate interests.
• Processes to Facilitate Access: Requests for information should be simple, fast, and inexpensive, with assistance available to requesters.
• Costs: Access should be free or low-cost, covering only reproduction and delivery expenses.
• Open Meetings: Government public meetings should be accessible to the public, with records made available.
• Disclosure Takes Precedence: In cases of doubt, the public interest in disclosure should outweigh secrecy.
• Protection for Whistleblowers: Individuals disclosing wrongdoing should be protected from retaliation.

 

Please take a look at the link to the UPR and Legal Analysis.

• Joint Submission for the UN Universal Periodic Review for the 46th Session of the UPR Working
• Legal Analysis _Cambodia Draft Law on Access to Information -2020

The Public Procurement Law, enacted in 2023, was partially shaped by API’s recommendations on essential international principles of transparency, fairness, efficiency, and accountability. The Ministry of Economy and Finance adopted four of API’s proposals, including publicizing the procurement process and maintaining transparency at all stages, such as in contracts between buyers and successful bidders.

 

See the API’s inputs on the Draft Public Procurement Law.

• Legal Analysis Report on the Draft Law of Public Procurement

Since 2017, the National Budget Laws have steadily increased funding for education, health, agriculture, and social development. From 2017 to 2024, API led both the Civil Society Organization Budget Working Group and the Coalition for Partnership in Democratic Development, a network of around 100 member organizations focused on promoting democratic governance and accountability. This leadership fostered ongoing, constructive collaboration between civil society, government ministries, and the National Assembly in budget monitoring and enhancing budget transparency.

 

Furthermore, the Annual National Budget Laws from 2017 to 2025 have raised funding for local governments and broadened budget categories to include social services, social accountability, and environmental protection. API has played a coordinating role in facilitating civil society’s analytical contributions to the budget formulation process.

 

See CSO’s inputs on National Budget Laws.

•  Joint Civil Society Inputs to the Draft Law on Finance and Property Management of Sub-National Administrations
• Summary of Civil Society Budget Working Group Recommendations for the 2026 National Budget
• Key Inputs from the Civil Society Budget Working Group to the PFMRP Technical Working Group
•  Joint Analysis and Recommendations from the CSO Budget Working Group on Cambodia’s 2024 National Budget
• Submission of Civil Society Budget Working Group Comments on the Law on Public Financial Management for 2024 Implementation and Future Public Financial Management and Budget Planning Improvements
• Recommendations from the CSO Budget Working Group on the Law on 2024 Finance for Management
• Key Inputs on the New Draft Law on Public Financial Management from the Budget Working Group of National and International Civil Society Organizations-2023
• Summary Results of the National Public Forum on Citizen Participation in Budget Formulation and Public Budget Oversight in the COVID‑19 Context-2022
• Statement on Key Positions and Inputs of the Budget Working Group of National and International Civil Society Organizations on the Development of the Macroeconomic Policy Framework and Public Financial Policy for the Preparation of Draft Laws on Finance for Management 2023

 

In 2024, API contributed key recommendations to the Draft Social Protection Law and related government initiatives focused on often excluded groups such as people with disabilities, the elderly, and street vendors. API also promoted the Social Protection for All (SP4ALL) initiative and participated in a citizen-led platform that raised public awareness and amplified citizens’ voices to influence government policy frameworks and implementation plans. In 2023, the government progressed by launching the National Social Security Fund (NSSF) package and an economic recovery plan targeting informal workers, including street vendors, domestic workers, and tourism workers. Cambodia continues advancing informal economy development through strategic frameworks like the National Social Protection Policy Framework (2024–2035) and the National Informal Economy Strategy (2023–2028), which include digital registration platforms and emphasize voluntary participation, capacity building, and social protection access.

 

See CSO’s inputs on draft Social Protection Law and National Social Protection Policy Framework (2024–2035).

 

API, in collaboration with the Digital Rights Working Group, has been actively advocating digital rights issues, including draft laws and policies related to the National AI Strategy, Personal Data Protection Law, Cyber Crime Law, Cyber Security Law, and the Sub-Decree on Internet Gateway, among others. In 2024, API led the creation of the Phnom Penh Internet Forum, offering a platform for CSOs to contribute input on personal data protection and cybercrime legislation. The government reviewed these contributions during consultations with the Ministry of Post and Telecommunications and incorporated some CSO recommendations, resulting in higher-standard laws that better protect digital rights and personal data. Since 2022, API has led monitoring efforts and produced the Internet Freedom Censorship Report in Cambodia, advocating for internet freedom and digital rights with relevant ministries. Policy dialogues based on these reports and draft law analyses were held with the Ministry of the Interior and the Minister of Post and Telecommunications. The Digital Rights Working Group issued a key message urging the Cambodian Government to ensure that the Draft Law on Information Technology Crimes and the Cyber Security Law comply with international human rights standards and safeguard responsible and safe technology use. Moving forward, API will continue to raise awareness and share updates on new digital rights laws with the public. The Cambodia Internet Censorship Report (2022-2023) and submissions to the Universal Periodic Review (UPR) were shared with development partners, including USAID, EU Member States, the media, the public, and the UN Human Rights Headquarters in Geneva as part of Cambodia’s 2024 UPR process. API remains committed to collaborating with all stakeholders—including the Cambodian government, relevant ministries, and development partners—to provide input on draft laws concerning the right to information, digital rights, and human rights.

 

See CSOs’ inputs on Digital Rights-related draft Laws and Policies.

• Submission to the Universal Periodic Review of Cambodia – 46th Session of the UPR Working Group-2024
• Factsheet 4th Cycle of The Universal Periodic Review on Cambodia: Freedom of Expression
• Legal Analysis: Cambodia Draft Law on Cybersecurity-2023
• Comments on the Draft Law on Cybercrime ( 6 files)

 

The Social Accountability Framework or ISAF (phases I and II, 2016–2025) has greatly benefited from API’s input in strengthening government policies and guidelines by promoting practices focused on learning, monitoring, and feedback. API supported the framework’s implementation across seven provinces, reaching over 300 communes, 200 health centers, and 700 primary schools. The current phase concentrates on addressing district-level challenges and ensuring the inclusion of disadvantaged groups. API has been an active member of the ISAF Technical Working Group, contributing to the completion of the ISAF Demand Side Operational guidelines for the District/Municipality/Krong (DMK) level in 2025. Additionally, API developed technical guidelines and successfully piloted a Social Protection project within the Social Accountability Framework in 2024.

 

See CSO’s inputs on Social Accountability Framework.

• Draft guiding technical document for integration of social protection through the implementation of the social accountability strategic plan
• Lessons Learned from “Persons with Disabilities’ Voices and Actions in I-SAF” Project

 

The New Road Traffic Law 2015 was the outcome of years of collaboration between API and road safety networks, sharing experiences and knowledge to support advocacy efforts. Thanks to this collective work, the law was passed by Parliament in 2015. Continued lobbying led the Ministry of Information to regulate alcohol advertising, launch public campaigns against drinking and driving, and contribute to the development of the draft Alcohol Control Law.

 

Please take a look at CSO’s inputs on the New Road Traffic Law 2015.

• Road Safety Governance & Traffic Law Implementation 2014–2016 (10 files)

 

The Anti-Corruption Law 2010: As a member of two working groups, API engaged in discussions on government reports regarding corruption in Cambodia, including those related to the implementation of the United Nations Convention Against Corruption and the Universal Periodic Review. Although the government sought to limit civil society input, API, alongside other CSOs and UN stakeholders, successfully produced a shadow report on several chapters, which was submitted to the UN Human Rights Office in Geneva in late 2018. The Anti-Corruption Law was eventually passed and partially enforced, particularly at the local level, resulting in increased transparency in public service fees and procedures. For more details, see CSO inputs on the UPR Anti-Corruption process.

In response to recent developments in Cambodia and the shifting global political and economic landscape—particularly following the end of US grants and the return of one million Cambodian workers from Thailand due to the 2025 border conflicts—API has revised its 2024-28 strategy to maintain its relevance. At the grassroots level, activities of community-based organizations and NGOs have faced increased monitoring and scrutiny over the past few years. This pressure intensified as the government strengthened the new NGO Law, widely perceived as a threat to civil society’s freedom of assembly.

This political and economic context has had significant implications for API’s work alongside other CSOs. For example, activity-related information must now be submitted to the government before organizing community meetings or people’s forums. As a result, API has adopted a more measured advocacy approach, focusing on constructive dialogue and building mutual trust rather than confrontation. Neither the government nor development partners are currently supportive of advancing the adoption and enforcement of the Access to Information Law.

 

Nonetheless, API remains committed to leading and participating in advocacy through the Access to Information Working Group, Budget Working Group, Coalition for Partnership in Democratic Development, Social Protection Working Group, Digital Rights Working Group, Peace Working Group, and Social Accountability Working Group to address the following key priorities:

 

• Limited capacity to implement Decentralisation and Deconcentration Reform and Public Financial Management Reform
• Insufficient youth and women’s participation and voice in local governance and community social and economic development
• Low public involvement in governance, policy dialogue, and monitoring of law and policy enforcement
• Limited budget transparency
• Persistent restrictions on freedom of expression

API’s strategies to strengthen good governance, democracy, human rights, and GEDSI by:

 

• Enhancing transparency, democratic accountability, inclusive public participation, and effective oversight mechanisms within the Public Financial Management Reform, the Decentralization and Deconcentration Reform, and the promotion of human rights and GEDSI.
• Advocating for Sub-National Administrations and policymakers to fulfill their roles and responsibilities within decentralized structures according to relevant laws and policies, to reinforce public financial management in education, social protection, public services, natural resources, good governance, democracy, and human rights.
• Building the capacity and coordination of CSOs and their networks to advocate for budget transparency, accountability, and oversight in education, social protection, public services, and natural resources through joint initiatives and targeted capacity-building activities.
• Enhancing citizen engagement in government policy formulation and enforcement via structured dialogues that connect local challenges with national-level processes on Public Financial Management, budget transparency, and governance, including education, social protection, public services, natural resources, decentralization and deconcentration, democracy, and human rights policies and reforms.
• Increasing public knowledge and the exercise of rights to access information and freedom of expression, especially regarding comprehensive budgets, legal frameworks, government plans, and public information disclosure.
• Strengthening the coalition and technical capacities of CSOs to enhance their effectiveness in advocating for budget transparency.
• Promoting collaboration and synergies among CSOs, development partners, government entities, and the private sector.
• Conducting policy analysis and facilitating dialogues between marginalized groups and the government on laws and policies across various sectors.

Former UN Secretary-General Kofi Annan once said, “Information is a great democratising power, giving us a chance to conduct change and alleviate poverty.” Cambodia, however, currently lacks an access to information law. Despite this, civil society’s campaign for such legislation has achieved important progress. A draft law was developed in 2018 following a relatively open, participatory process in which NGOs were able to voice concerns and submit feedback. This draft still requires further amendments to meet international standards before Parliament can adopt it.

 

As taxpayers and voters, Cambodian citizens have a constitutional right to access public information, reinforced by international treaties. Since its founding in 2003, API has advocated for an Access to Information (A2I) Law that can translate this constitutional right into everyday practice. Continued lobbying remains a top priority for API, especially as these efforts have fostered a culture of better access to public institutions, information, and democratic participation in lawmaking.

 

For these reasons, we, as civil society organizations, urge the Government and Parliament to continue their efforts, improve the draft law, and ultimately pass it. At API, we are eager to actively participate in this process alongside state institutions, our NGO colleagues, and other stakeholders. We also call on international organizations, donors, embassies, and foreign governments to provide ongoing technical and financial support for this important effort.

 

Over the past 15 years, in collaboration with national and international partners, API has produced numerous analyses, position papers, and assessment studies on various draft versions. We have also organized multiple national consultations and an international conference on access to information. More about the history of this process and the importance of access to information in the daily lives of Cambodians can be found in one of our impact stories.

 

 

Our Identified Problems

Cambodia lacks a dedicated Access to Information Law. Existing laws provide limited, vague provisions and broad criminal sanctions discourage transparency, especially on sensitive topics like natural resource governance. Government information disclosure is inconsistent and often difficult to obtain.

Cambodia accepted UPR recommendations to enact an access to information law by 2026 aligned with international standards. The draft law needs improvements, and additional measures should follow civil society recommendations.

 

Secrecy Laws and Limited Access

Without a comprehensive law, Cambodia has weak obligations for government transparency. Some laws mention information access but lack clear procedures or enforcement and often enable secrecy.

The Press Law grants media access rights but allows officials broad discretion on confidentiality. The Archive Law restricts disclosure with long timeframes (20-120 years) and unclear access rules. Other sectoral laws have vague or unenforced transparency provisions.

Authorities are usually not required to proactively disclose information; disclosure is mostly voluntary.

The Mining Law enforces confidentiality on reports until licenses expire, with limited exceptions, creating barriers to mining data despite environmental codes promoting access.

Public access is irregular and discretionary. Authorities often delay or deny information, especially on contentious issues like extractive industries or land disputes, limiting effective transparency even when it is justified.

 

Our Strategy

API has focused on practically empowering citizens regarding their right to access information, while also building government capacity for information disclosure, particularly at the sub-national level. API considers access to information essential for meaningful participation and accountability in local governance, which contributes to poverty reduction and equity across social groups. This work has facilitated community access to basic documents and reduced corruption by increasing transparency around fee structures. The disclosure of sub-national budgets has enabled communities to better understand and influence local development priorities.

 

Key advocacy goals include:

• Improving and adopting an Access to Information Law aligned with international standards by 2026.
• Enhancing the draft law to clarify that it overrides other secrecy laws, establishes independent oversight, emphasizes proactive disclosure, and avoids criminal penalties for non-government actors or officials releasing information in good faith.
• Following enactment, launching public awareness campaigns to educate citizens about their right to information and the new law.
• Upon adoption, urging the government to implement the law promptly by appointing information officers, commissioners, or ombudsmen for oversight; providing training; raising public awareness; and proactively publishing essential information such as budgets, national development plans, procurement data, legal judgments, and official service prices in accessible formats.

 

Building on its successful experience, API also leads campaigns to promote disclosure on critical issues like public budgets, natural resource management, public-private contracts, and private sector investments, leveraging existing laws regulating sector-specific information access.

 

API monitors implementation of laws, policies, and programs related to the right to information and public disclosure by producing regular reports and advocating for the creation of an oversight system, such as an information ombudsman.

 

Regarding Gender Equality and Social Inclusion (GEDSI), API and its civil society allies work to strengthen capacity for monitoring inclusion, reporting findings, and advocating for legislative or regulatory improvements to embed and enforce social, economic, and gender inclusion principles across sub-national administrations and their staff.

 

 

Our Partnership and Accountability

 

API collaborates with government institutions, civil society organizations, and networks to strengthen their capacity to address the needs and concerns of the people. By fostering and enhancing partnerships, API works to create opportunities for citizens and civil society actors to engage in meaningful dialogue with government bodies on important issues. These efforts also aim to promote accountability among government institutions and their representatives.

 

API has consistently demonstrated a strong commitment to transparency, accountability, and integrity within its own operations. The organization believes its work contributes to Cambodia’s long-term democratic and social development, poverty reduction, human rights protection, and the promotion of a national culture of harmony founded on sustainable democratic, political, and economic stability.