The electronic structure of laser-deposited P-doped ZnO films was investigated by X-ray absorption near-edge structure spectroscopy (XANES) at the O K-, Zn K-, and Zn L3-edges. While the O K-edge XANES spectrum of the n-type P-doped ZnO demonstrates that the density of unoccupied states, primarily O 2p-P 3sp hybridized states, is significantly high, the O K-edge XANES spectrum of the p-type P-doped ZnO shows a sharp decrease in intensity of the corresponding feature indicating that P replaces O sites in the ZnO lattice, and thereby generating P(O). This produces holes to maintain charge neutrality that are responsible for the p-type behavior of P-doped ZnO. Both the Zn K-, and Zn L3-edge XANES spectra of the P-doped ZnO reveal that Zn plays no significant role in the p-type behavior of ZnO:P.