The 54.25 per cent published for 2025 counts only the larger of two approval routes. A government release says most of the money in the smaller one came from China too, and gives no figure.
Foreign investment projects in Cambodia take one of two approval routes, and the size of the project decides which one. The figure the government publishes for how much of that money comes from China counts one of the two.
The Council for the Development of Cambodia approves and registers foreign investment. Its investment board handles the larger projects. Under Article 9 of the Law on Investment of October 2021, anything below a line of about five million dollars goes to a capital or provincial investment sub-committee instead. The split turns on size. Through 2025 the government published the two tiers apart. When it released February’s figures on 11 March 2026 it put them in one total. That was 42 projects worth about 166 million dollars, 18 from the board and 24 from the sub-committees. The headline said registered in Cambodia, where a year earlier it had said registered by the board.
For 2025 the board registered 630 projects carrying about ten billion dollars. Approved capital is money an investor has permission to put in, not money that has arrived. Chinese investors accounted for 54.25 per cent of it, or 5.42 billion dollars, in the Council’s report for the year. Domestic capital came second at 31.27 per cent and Singapore third at 5.99 per cent. Those are shares of the board tier, and none of them counts a sub-committee project.
The smaller tier came in a sentence of its own. The same release put it at 228 projects worth about 763 million dollars, roughly 7.6 per cent of the board total. Most of that funding came from China, it said, alongside domestic and other foreign investors. A comparative word, and no number.
How much is not published anywhere this desk has looked. A search of the Council’s own site and of cambodiainvestment.gov.kh on 8 September 2026 found no nationality breakdown of the sub-committee tier, for 2025 or for any other period. That search did not run in Khmer or reach the agency’s archive.
The size of the gap can still be fixed at both ends. Put the two tiers together and restate the year. If none of the smaller tier were Chinese, the 2025 share becomes 50.40 per cent. At half it is 53.95, at three quarters 55.72, and if every dollar of it were Chinese it reaches 57.50. The release says most, so the answer lies above half, where the combined figure sits a fraction under the published one. Only at the top of the range does it add about three and a quarter points. That arithmetic is this publication’s, worked from the two published totals.
So the smaller tier is not where large amounts of unreported Chinese capital could be hiding. What it can do is break a comparison between two years, because the government changed what it was adding up in between.
The first half of 2026 was published on the combined basis. Cambodia approved 276 projects worth about 4.7 billion dollars: 181 through the board at about 4.4 billion, and 95 through the sub-committees at about 291 million. China’s share of that combined total was 35.75 per cent. Domestic investors led at 41.74 per cent. Counting the board alone for those six months gives a range rather than a number. The Chinese share of board capital sits between 31.50 and 38.11 per cent, and nothing narrows it without the Chinese portion of the 291 million. Same missing piece, one year later.
Seetao, a Chinese trade site covering Belt and Road projects, put the two years side by side on 5 June 2026. It reported 188 projects worth 2.722 billion dollars for January to April. Chinese investors took a 67 per cent share of that and Cambodian domestic capital 33. Set against 2025, the site called this a jump from 54 to 67 per cent and a clear sign of accelerating foreign investment. Its two shares add to exactly a hundred, which leaves nothing for Singapore, third in the same 2025 line it quotes at 5.9 per cent. The two figures it compares are not counting the same set of investors.
This publication quoted the same January release on 16 August and stopped before the clause about where the funding came from. That clause is the part that ties the smaller tier to the headline share for the year.
Cambodia does not run its investment promotion at one country. The Council keeps four standing country desks, for China, the European Union, Japan and Korea, each with its own staff and address on the Council’s site. Lim Heng, vice-president of the Cambodia Chamber of Commerce, spoke to Khmer Times for the same report that carried the 2025 shares. The investment laws apply equally to investors of all nationalities, he said, and Cambodia does not target specific countries when it looks for capital. The state news agency named a standing Cambodia-Korea public-private dialogue on 29 January 2026, eleven days before the first Cambodia-China dialogue sat on 9 February.
None of that answers the question the January release opens. The Council publishes a nationality split for the board tier and none for the tier beside it. One line in a press release would close the gap. Until there is one, a share of a single approval channel will keep being read as a share of the country.