Issue Description

While the Cambodia’s digital healthcare sector was following up with international practices, these attempts were slowed down with multiple structural challenges, including an unclear regulatory environment, outdated and fragmented data systems, limited capacity building, and weak public-private partnerships. Digital health platforms, such as telemedicine, AI-based diagnostics, and electronic medical records played an important role in enabling accessible and high-quality healthcare services.  

Despite these positive developments, the existing regulatory environment is not coping with these technical evolutions. As a result, innovation in the sector has been constrained. Indeed, Cambodia currently lacks mechanisms that would allow new digital health solutions to be tested safely while ensuring patient protection and regulatory oversight.  

At present there is no formal licensing system recognising digital health platforms as distinct category of health service providers. This creates legal uncertainty for platform operators and healthcare professionals, particularly with regard to liability, data protection, and clinical responsibility. From a financing perspective, the exclusion of digital health services from national financing schemes has limited patient access to these platforms and discouraged adoption by healthcare providers.    

Moreover, the lack of a coherent and standardised health information system has prevented healthcare actors form securely sharing data about their patients to an other providers hampering quality services delivery and the continuity of care.  

The development of digital initiatives so far has been constrained by the absence of structured and systematic public-private dialogue. Many digital health initiatives rely on short-term donor funding, which has resulted in fragmented pilot projects and limited national scaling. 

Impact on business

The digital health landscape in the Kingdom has many loopholes which negatively impact the investments. 

Firstly, the lack of a streamlined process for health innovators causes them to lose significant time and financial resources attempting to achieve compliance. This lack of clarity also exposes them to non-compliance risks, which discourages investment in digital health innovation. 

Secondly, the absence of national interoperability standards forces businesses to develop custom information systems and integrations for each individual hospital. This raises costs, creates inefficiencies, and severely limits scalability. 

Thirdly, the exclusion of digital health services from reimbursement schemes, such as the Health Equity Fund and the National Social Security Fund (NSSF), has direct negative consequences for rural and low-income populations, while also disincentivising healthcare professionals from using these services. 

Furthermore, insufficient digital literacy within the health workforce limits capacity building, increases onboarding costs, slows adoption at healthcare facilities, and reduces the overall value that digital health platforms can deliver. 

Finally, the absence of a systematic public-private engagement platform limits the private sector’s ability to contribute expertise, co-create standards, and align innovations with national health priorities. 

Recommendation

  • Improve the Digital Health Ecosystem in Cambodia

We encourage the Royal Government of Cambodia to strengthen the Digital Health Ecosystem by following the below recommendations:  

  • Establish a Unified National Governance for Digital Health  

Mandate a  National Digital Health Coordination Committee (NDHCC)  and a supporting  Digital Health Taskforce, which would be enabled  through an inter-ministerial decree to ensure coherent leadership and cross-sector coordination. The NDHCC should be empowered to set national strategy, approve standards, and oversee implementation, while the Taskforce would  operate as a technical and co-regulatory working body.  

Formally recognise the  Cambodia Digital Health Alliance (CamDHA)  as the unified private-sector platform and integrate it into the NDHCC and all relevant technical working groups through a MOU with the MOH. This newly-crafted unified structure will institutionalize public–private dialogue, support co-development of standards, and enable effective piloting and scaling of digital health solutions.  

  • Introduce Adaptive Regulation and Risked-Based Licensing  

Establish a Digital Health Sandbox via a joint  Prakas  from MoH and MPTC to allow safe, supervised testing of emerging technologies. Issue interim, clear guidelines on digital health tools such as teleconsultation, e-prescriptions, AI ethics, and data use. Following this testing phase, develop a licensing framework that categorises digital health platforms as “health service intermediaries,” with requirements aligned to risk level, while clarifying liability rules and mandating  appropriate clinical and technical safeguards, particularly for AI-driven care.  

  • Develop a National Health Information Exchange (HIE) and Interoperability Standards  

Mandate FHIR-compatible data formats, standardise APIs, and certification processes. Build a national autonomous HIE infrastructure with registries and middleware, overseen by the NDHCC to ensure privacy, security, and compliance, enabling secure data sharing and integration with both public and private healthcare providers and public and private financing systems. 

  • Integrate Digital Health Services into Public Financing and Ensure Sustainable Funding  

Include accredited telehealth and digital services within HEF and NSSF schemes. Define reimbursable services, establish  tariffs, integrate platform APIs with claims systems, and pilot blended payment models for chronic disease management. Establish dedicated budget lines and a Digital Health Innovation Fund pooling contributions from government, donors, and industry. Introduce cost-recovery mechanisms and explore PPPs for infrastructure. 

  • Improve capacity building mechanism to develop Digital Competencies in the Health Workforce  

Include  mandatory  digital health training in pre-service curricula and fund CPD programs for in-service staff on cybersecurity, data governance, digital patient communication, and use of national digital systems. Moreover, there should be an alignment between donor and NGO training programs with supervision from national competency frameworks to ensure standardised skills across the sector. 

Dialogue with

Royal government of Cambodia

Initiative from Eurocham: The issue has been raised by the Healthcare Committee within The White Book edition 2026 in the Recommendation No. 41.

No response from the Royal Government of Cambodia

National Counterparts

Royal Government of Cambodia

Ministry of Post and Telecommunication

Ministry of Health

Contributors