An image encoding apparatus of the present invention comprises a frequency converting unit which executes frequency conversion on the data of a frame in moving image data, and generates coefficient data of a plurality of subbands, an encoding unit which quantizes the coefficient data acquired by the frequency converting unit in accordance with a quantization parameter, and encodes the quantized coefficient data, and a code amount controlling unit which controls the encoding unit such that a code amount generated by the encoding unit achieves a target code amount are provided. Here, the code amount controlling unit determines a subband target code amount of each of the plurality of subbands by distributing the target code amount to the plurality of subbands based on a ratio determined according to an indicator indicating a difficulty calculated for each of the plurality of subbands.