Ship Registration in Bangladesh: Ownership, Mortgages and the Flag in 2026

by Barrister Tahmidur Rahman | Oct 23, 2026 | Disputes & Public Law, Insights | 0 comments

TRW Insight / Maritime & Shipping

The Bangladeshi register is a national one: ownership tests, recorded mortgages, government permission to reflag and a cargo-preference regime all flow from it. Getting the registration file right protects the asset, the finance and the trade.

Updated 23 October 2026Legal insightBangladesh22 min read

Ship registration in Bangladesh decides far more than the flag painted on a vessel's stern. It determines who may own the ship, whether a bank can take enforceable security over it, which cargoes the ship may carry under the national flag-protection regime, how the vessel can later be sold or reflagged, and what tax treatment follows its import. For shipowners, financiers, buyers of second-hand tonnage and foreign investors working with Bangladeshi partners, the registration file is the legal foundation of the asset.

This guide explains the framework that applies in 2026: the registration chapter of the Bangladesh Merchant Shipping Ordinance 1983, the role of the Department of Shipping and the Mercantile Marine Office in Chattogram, the ownership tests, the documents and surveys required, provisional certificates, mortgages and their priority, transfers, closure of the register and reflagging, the Bangladesh Flag Vessels (Protection of Interests) Act 2019, the separate regime for inland vessels, and the VAT and income-tax changes of 2024 and 2025 that now shape the economics of bringing a ship onto the Bangladeshi register.

Ship registration in Bangladesh — bulk carrier at anchor in the outer anchorage of Chattogram
Sea-going ships above fifteen tons net must be on the national register

Summary: Sea-going, mechanically propelled Bangladeshi ships above fifteen tons net must be registered under Chapter 3 of the Bangladesh Merchant Shipping Ordinance 1983, with the Principal Officer in Chattogram acting as Registrar. Only Bangladeshi citizens, qualifying Bangladeshi-controlled companies, statutory corporations and certain lease-purchase arrangements qualify. Registered mortgages rank by recording date, and both reflagging abroad and the 2019 flag-protection regime require government involvement.

Key point: A ship that should be registered but is not cannot be recognised as a Bangladesh ship and may be detained. The Register Book cannot be inspected without the owner's written consent, so buyers and lenders must build that consent into their transaction documents from the outset.

At a glance

01

Governing law

Chapter 3 of the Bangladesh Merchant Shipping Ordinance 1983 governs the registration of sea-going Bangladesh ships.

02

Who registers

The Director General of Shipping is Registrar General; the Principal Officer at Chattogram is the Registrar.

03

Who may own

Citizens, statutory corporations, majority Bangladeshi-controlled companies and qualifying lease-purchase arrangements.

04

Security

Registered mortgages rank by the date of recording and are enforced through the High Court Division.

05

2025 tax change

The 7.5 per cent VAT on importing ocean-going vessels above 5,000 DWT was waived in September 2025.

Table of Contents

The core statute for ship registration in Bangladesh is the Bangladesh Merchant Shipping Ordinance 1983 (Ordinance No. XXVI of 1983), dated 30 June 1983. Its Chapter 3, headed "Registration", sets out who may register a ship, where and how, what the certificate of registry does, and how mortgages, transfers and closures are recorded.[1] The Ordinance has been amended several times since 1983, so practitioners work from the current consolidated text rather than an old printed edition.

Which ships the registration chapter covers

The chapter applies to all sea-going Bangladesh ships exceeding fifteen tons net that are fitted with mechanical means of propulsion. It does not apply to ships registered under the separate law on inland vessels plying on inland waters.[1] The practical dividing line is therefore the vessel's trade: an ocean-going bulk carrier, tanker, container feeder or offshore support vessel belongs on the merchant shipping register, while a river cargo vessel or passenger launch falls under the inland regime discussed later in this guide.

Registration is compulsory, not optional

Every Bangladesh ship to which the Ordinance applies must be registered. Until it is, the ship is not recognised as a Bangladesh ship, and it may be detained until the master produces a certificate of registry when required to do so.[1] An unregistered Bangladesh ship also loses the privileges and protection that registered ships enjoy, including the right to fly the national colours, while remaining liable for dues, fines and forfeiture as if it were registered.[1] The combination is deliberately harsh: an owner gains nothing by staying off the register.

The Merchant Shipping Act 2020 text

A consolidated text titled the Bangladesh Merchant Shipping Act 2020 is published on the Department of Shipping's portal. It reorganises the registration rules into a dedicated chapter, includes sections on the registration of foreign-flag vessels under bareboat charter and of Bangladesh-flag ships bareboat-chartered out.

It also moves mortgages into a separate chapter that includes authority to sell or mortgage a ship outside Bangladesh. The text states that it comes into force on a date the government notifies in the official Gazette.[2] We have not located a commencement notification, so the 1983 Ordinance remains the working reference in this guide. Anyone relying on the 2020 provisions, particularly bareboat registration, should first confirm their status with the Department of Shipping.

The authorities: Department of Shipping and the Mercantile Marine Office

The Ordinance makes the Director General of Shipping the Registrar General of Bangladesh ships. At the port of Chittagong (now Chattogram), the Principal Officer is the Registrar, and the government may appoint registrars at other ports by Gazette notification, together with deputy and assistant registrars.[1] Chattogram and any other ports notified by the government are the ports of registry, and the port where a ship is registered is treated as the port to which she belongs.[1]

In practice the work is done at the Mercantile Marine Office in Chattogram, headed by the Principal Officer.[3] The same office compiles the official figures on the national fleet, issues provisional and permanent registrations and administers the flag-vessel waiver regime described below.[5] [7] Each Registrar keeps a Register Book and must report registrations, cancellations and transfers to the Registrar General twice a year, by 15 January and 15 July.[1]

Registrar General

Director General of Shipping

Statutory Registrar General of Bangladesh ships under the 1983 Ordinance.

Registrar

Mercantile Marine Office, Chattogram

The Principal Officer registers ships, issues certificates and records mortgages and transfers.

Abroad

Bangladeshi consular officers

Issue provisional certificates on the Registrar General's instructions and handle lost certificates.

Tax

National Board of Revenue

Sets customs duty, VAT and income-tax treatment of imported and operating ships.

Courts

High Court Division (Admiralty)

Enforces registered mortgages, orders judicial sales and hears maritime claims.

Flag protection

Mercantile Marine Department

Issues waiver certificates for foreign vessels under the 2019 Act.

Who can own a Bangladesh ship

Eligibility is the first question in any ship registration in Bangladesh, because the register is a national one rather than an open registry. The Ordinance defines a Bangladesh ship as a ship belonging to a statutory corporation; a ship acquired and owned by a foreign national or company and leased to the government, a Bangladeshi citizen or a Bangladeshi company under an agreement that ownership will pass to the lessee after a specified period; or a ship owned wholly by persons each of whom is a Bangladeshi citizen or a qualifying company.[1] [3]

The company ownership test

A company qualifies only if four conditions are all met: its principal place of business is in Bangladesh; Bangladeshi citizens hold more than fifty per cent of the share capital or of the voting power; a majority of its directors are Bangladeshi citizens; and either the chairman or the managing director is a Bangladeshi citizen.[1] These are continuing conditions. A share transfer, board change or new investor that tips control abroad can take the ship outside the definition, so shareholders' agreements in shipowning companies should contain covenants and transfer restrictions that protect the flag.

Foreign investors and the lease-purchase route

Because majority foreign ownership disqualifies a company, foreign capital usually enters through a minority stake, through finance secured by a registered mortgage, or through the lease-purchase structure in the statutory definition, under which a foreign owner leases the ship to a Bangladeshi party with title passing at the end of the term.[1] Maritime academics have argued that the national-register rules discourage investment, noting that much of the Bangladeshi-controlled commercial fleet has sailed under foreign flags and proposing a second register open to non-citizens.[3] That remains a policy debate, not the law.

Limits on the number of owners

No more than ten persons may be registered at the same time as owners of one ship, although this does not affect the beneficial interests of others claiming through a registered owner.

Fractional parts of a share cannot be registered, up to four persons may be registered as joint owners of a ship or of a share, joint owners are treated as one person, and a company may be registered in its corporate name.[1] Separately, no notice of any trust may be entered in the Register Book, and the registered owner has power to dispose of the ship subject to the rights shown on the register.[1] Beneficial owners therefore protect themselves by contract and by mortgage, not by registering a trust.

How ship registration in Bangladesh works, step by step

The statutory sequence for ship registration in Bangladesh is short on paper and document-heavy in practice. The application is made by the owner or, where there are several owners, by one or more of them or by agents appointed in writing. An individual appoints an agent under his own hand; a company appoints one under its common seal.[1]

Step 01

Confirm eligibility

Check that the owner is a citizen, statutory corporation, qualifying Bangladeshi-controlled company or lease-purchase lessee, and that it will stay that way.

Step 02

Clear the previous flag

Obtain the bill of sale, the deletion certificate from the previous registry and discharges of any existing mortgages.

Step 03

Appoint agents and file

Lodge the application with the Principal Officer, with agents appointed in writing or under the company's common seal.

Step 04

Survey and mark the ship

Arrange tonnage measurement by a government or authorised class surveyor and mark the ship to the Registrar's satisfaction.

Step 05

Sign the declaration

Make the declaration of ownership and produce the builder's certificate or instrument of sale.

Step 06

Use the provisional route if abroad

Obtain a provisional certificate through the consular officer and complete registration within six months.

Step 07

Settle tax at import

Confirm duty, VAT waiver eligibility, advance income tax and any conditions before the ship arrives.

Step 08

Record the security

Present any mortgage to the Registrar on the day of closing so that its priority is fixed.

Survey, measurement and marking

Before registration the ship must be surveyed, at the owner's expense, by a government Surveyor or by a surveyor of a classification society authorised by the government, and its tonnage ascertained in the prescribed manner. The surveyor issues a certificate of tonnage, build and identifying particulars, which the owner delivers to the Registrar.[1] The ship must also be permanently and conspicuously marked to the Registrar's satisfaction. Failing to keep the marks, or tampering with them, is punishable with a fine of up to Tk 20,000 per offence, and an insufficiently marked ship may be detained.[1]

Declaration of ownership and evidence of title

No person may be registered as owner unless a declaration of ownership in the prescribed form has been made and signed. It must confirm that the ownership requirements are satisfied, state when and where the ship was built (or that this is unknown), give any previous foreign name, name the master and his citizenship, and state the number of shares claimed.[1]

For a ship built abroad, the applicant produces the builder's certificate and the instrument of sale; where the time and place of building are unknown or the builder's certificate cannot be obtained, the instrument of sale alone may suffice.[1] On a second-hand purchase, the bill of sale, the deletion certificate from the previous registry and evidence that prior mortgages have been discharged are the documents that most often delay the file.

Entry in the Register Book and the certificate of registry

Once the declaration and evidence are in order, the Registrar enters the ship's name and port, the survey particulars, the origin of the ship and the owners and their shares in the Register Book. The Registrar may refuse a proposed name that duplicates or closely resembles another ship's name or is otherwise undesirable.[1] Where the government doubts a ship's title to registration, it may direct the Registrar to require evidence on at least thirty days' notice, and a ship whose entitlement is not proved is liable to forfeiture.[1] On completion the Registrar grants a certificate of registry in the prescribed form.[1]

The practical sequence at the Mercantile Marine Office

Research on the registration system describes the administrative path in more detail: an application with supporting documents to the Principal Officer, statutory survey against IMO conventions such as SOLAS and MARPOL, provisional safety certificates, a call sign and radio licence from the telecoms regulator, an MMSI number, a provisional certificate, a physical survey, payment of taxes to the National Board of Revenue and fees, and then the permanent certificate of registry. The same research reports that imported vessels should not exceed twenty-five years of age.[3] Age limits and import conditions sit in import policy and tax instruments that change, so confirm the current position before contracting to buy older tonnage.

Ship registration in Bangladesh — surveyor inspecting a vessel's hull and markings before registration
Survey, tonnage measurement and marking come before entry in the Register Book

Provisional registration and temporary passes

Ships are often bought abroad and need a Bangladeshi document before they can sail home. Where a ship becomes entitled to be registered as a Bangladesh ship at a port outside Bangladesh, the Bangladesh consular officer may, on specific instructions from the Registrar General, issue a provisional certificate of registry to the master. It has the effect of a certificate of registry for six months from its date or until the ship arrives at a port with a Registrar, whichever happens first.[1]

For movement within Bangladesh, the government may authorise the Registrar to grant a pass allowing an unregistered Bangladesh ship to sail from one Bangladeshi port to another; the pass has the effect of a certificate of registry for the time and within the limits stated in it.[1] Official figures show how commonly the provisional route is used: of the vessels added to the national fleet in the first half of 2024, the Mercantile Marine Office counted both permanent and provisional registrations.[7] A provisional certificate is a bridge, not a destination. Delivery-voyage planning should assume that every outstanding document must be completed before the six-month window closes.

Using and protecting the certificate of registry

The certificate of registry may be used only for the lawful navigation of the ship. It cannot be detained by anyone claiming a title, lien, charge or interest in the ship, and whoever holds it must deliver it on demand to the person entitled to custody for navigation, to a Registrar or to a Collector of Customs.[1] A master or owner who uses a certificate not lawfully granted for the ship faces a fine of up to Tk 50,000, and the ship becomes liable to forfeiture.[1]

Defaced, lost or destroyed certificates can be replaced by the Registrar of the port of registry. If the loss happens abroad, the master declares the facts to the nearest Bangladeshi consular officer, who issues a provisional certificate that must be delivered to the Registrar within ten days of the ship's next arrival at her port of registry.[1] Changes of master and changes of registered ownership must be endorsed on the certificate, and a Collector of Customs may refuse to deal with a person as master unless his name is endorsed as the last appointed master.[1]

Names, alterations and conversions

A registered ship may not be described by any name other than her registered name, and a change of name must follow the prescribed procedure; breach carries a fine of up to Tk 50,000 and possible detention.[1]

If a ship is altered so that she no longer matches her registered tonnage or description, the owner must apply to register the alteration, usually within three days of the alteration or of arrival at a port with a Registrar, failing which daily fines accrue.[1] Converting or modifying a ship so as to change her character requires the prior written permission of the Director General of Shipping, and a contravention can attract imprisonment of up to three years, a fine of up to Tk 10 lakh, or both.[1]

Ship mortgages and ship finance

For lenders, ship registration in Bangladesh matters chiefly because it is the gateway to a registered mortgage. A registered ship or a share in it may be made security for a loan or other valuable consideration by an instrument in the prescribed form. The instrument is produced to the Registrar of the port of registry and recorded in the Register Book, and the Registrar endorses the day and hour of recording on it.[1]

Priority by date of recording

Where more than one mortgage is recorded against the same ship or share, the mortgages rank according to the date on which each was recorded, not the date of the mortgage instrument, and this applies regardless of any express, implied or constructive notice.[1] The rule rewards speed: a lender that signs first but records second ranks second. Completion mechanics should therefore make registration of the mortgage a condition of drawdown, with the instrument presented to the Registrar on the day of closing.

What a mortgagee can and cannot do

A mortgagee is not treated as owner except so far as needed to make the ship available as security, and the mortgagor does not cease to be owner.[1] Crucially, a mortgagee under a registered mortgage recovers by proceedings in the High Court Division, which may order the ship sold in execution of its decree; the mortgage alone does not give the mortgagee a private power of sale.[1] A registered mortgage is also protected against the mortgagor's later insolvency, and it may be transferred by a recorded instrument, with the transferee taking the transferor's priority.[1] Discharge is recorded on production of the mortgage with a signed and attested receipt.[1]

Enforcement in the Admiralty Court: a 2026 decision

On 26 February 2026 the High Court Division, sitting in its admiralty jurisdiction, decided Basic Bank Limited v M.V. Crystal Sapphire (Admiralty Suit No. 29 of 2017). The court held that a bank's suit to recover loan money secured on a vessel is maintainable under section 3(2) of the Admiralty Court Act 2000 and is not barred by section 5 of the Artha Rin Adalat Ain 2003, reasoning that the admiralty bench is a bench of the High Court Division under Article 101 of the Constitution rather than an ordinary civil court.[13]

The court decreed about Tk 128.5 crore with interest at twelve per cent from filing, to be satisfied from the proceeds of the vessel, which had already been sold at judicial auction in another admiralty suit.[13] For lenders, the decision confirms that a registered ship mortgage can be enforced in rem through the Admiralty Court. Our guides to registered ship mortgages and maritime liens and the Admiralty Court Act explain the ranking of competing claims.

Foreign lenders and cross-border structures

Where the lender is outside Bangladesh, the mortgage is only one part of the structure. Foreign-currency borrowing by a Bangladeshi shipowner raises exchange-control and approval questions, and the security package typically adds assignments of earnings, insurances and charter hire. Our analysis of foreign loans to Bangladeshi borrowers sets out the approvals, and the shipping finance and ship leasing practice advises on documentation.

Ship registration in Bangladesh — signing ship finance and mortgage documents
Registered mortgages rank by the date they are recorded

Transfer of ownership, transmission and court sales

A Bangladesh ship or a share in it can be transferred only by an instrument executed by the transferor in the presence of, and attested by, at least two witnesses. The instrument must identify the ship sufficiently, and once produced to the Registrar the transferee is entered as owner, with entries made in the order in which instruments are produced.[1] Each change of ownership must also be endorsed on the certificate of registry, and a master who fails to deliver the certificate for endorsement faces a fine of up to Tk 50,000.[1]

Where ownership passes on death or insolvency, the successor makes a declaration of transmission supported, in the case of death, by a succession certificate, probate or letters of administration under the Succession Act 1925. If the transmission would take the ship out of Bangladeshi ownership, the Registrar reports to the government, which may apply to the High Court Division for the ship or share to be sold to a qualifying Bangladeshi buyer, with the proceeds paid to the person entitled.[1] When any court orders a sale, its order vests the right to transfer in a named person, who can then transfer as if he were the owner.[1]

Any person may inspect the Register Book and obtain certified copies on payment of the fee, but only with the written consent of the ship's owner.[1] That is unusual by international standards and has a direct consequence: a buyer or lender cannot independently search the register. The memorandum of agreement or term sheet should oblige the seller or borrower to provide signed consent so that a current transcript of the register, showing owners and recorded mortgages, can be obtained before closing.

Transfer of registry, closure and reflagging

Registry may be moved from one Bangladeshi port to another on a written application by everyone shown in the Register Book as owner or mortgagee, and the move does not affect their rights.[1] Moving the registry to a port outside Bangladesh is a different matter. It requires the previous written permission of the government, and the Registrar takes no action on an application that is not accompanied by that permission.[1] Industry representatives have publicly described the ministerial approval needed to sell ships as a bureaucratic hurdle, which should be built into any sale timetable.[11]

Closure of the register

If a Bangladesh ship is actually or constructively lost, captured, burnt or broken up, or ceases for any reason to be a Bangladesh ship, every owner must notify the Registrar immediately on learning of the event. The Registrar records the event, and the entries are treated as closed except so far as they relate to any unsatisfied mortgage.[1] The master must surrender the certificate of registry, immediately if the event occurs in a Bangladeshi port and within ten days of arrival if it occurs elsewhere and the master later arrives in Bangladesh. Failure is punishable by a fine of up to Tk 20,000.[1]

The survival of unsatisfied mortgages on closure is the provision buyers and lenders most need to understand. Closing the register does not wipe out recorded security, so a ship sold for recycling or reflagged abroad should leave the register with every mortgage discharged and recorded as such. A ship whose registry has been closed, other than through capture, may not be re-registered until it has been surveyed and certified seaworthy at the applicant's expense.[1] Ships sold for recycling also engage a separate approval regime, which our guide to shipbuilding and ship breaking in Bangladesh covers.

National character and the flag

The government declares the national colours for Bangladesh ships, and hoisting other distinctive colours on a Bangladesh ship is an offence. A ship that is not a Bangladesh ship may not use those colours except to escape capture, and concealing a ship's Bangladeshi character or assuming a foreign one is punishable with imprisonment of up to two years, a fine of up to Tk 80,000, or both.[1] A Collector of Customs will not grant port clearance until the master declares the country to which the ship belongs.[1]

The Bangladesh Flag Vessels (Protection of Interests) Act 2019

The commercial value of ship registration in Bangladesh is closely tied to the Bangladesh Flag Vessels (Protection of Interests) Act 2019 (Act No. 18 of 2019), which repealed and re-enacted the Bangladesh Flag Vessels (Protection) Ordinance 1982.[4] Under the Act, a third-country flag vessel may carry cargo to or from Bangladesh only where no Bangladesh-flag vessel or vessel of the trading partner's country is available or able to carry it, and foreign vessels may not carry coastal cargo without a waiver certificate.[4]

Cargo reservation and the waiver certificate

The regime is widely reported as reserving at least fifty per cent of seaborne cargo in Bangladesh's foreign trade for national-flag vessels.[6] [7] Foreign vessels need a waiver certificate, applied for by their local agents through the Mercantile Marine Department in Chattogram, fifteen days before loading. Under the Bangladesh Flag Vessel (Protection) Rules 2023, published on 5 February 2023, the department seeks the views of Bangladesh Shipping Corporation and the Bangladesh Ocean Going Ship Owners' Association before issuing it.[5] Container feeder operators and shipping agents have long complained about the cost and delay this adds.[5] [6]

Effect on the national fleet

The policy has coincided with rapid growth. The Mercantile Marine Office reported 101 Bangladesh-flag ocean-going vessels in June 2024, the highest number since independence, with 67 registered between 2019 and 2023 and combined capacity of nearly fifty lakh tonnes.[7] By October 2024 it counted 102 active registered vessels with two more awaiting registration.[8] The debate has not closed. At an October 2025 seminar, private shipowners argued that the 2019 Act mainly benefits state carriers and called for its repeal.[11] Owners planning fleet investment on the strength of cargo preference should monitor this closely.

Ship registration in Bangladesh — container feeder vessel sailing under a national flag
Flag preference under the 2019 Act shapes the commercial value of the register

Tax and duty on importing and operating ships

The tax position has moved sharply since 2024, and it now drives the economics of any ship registration in Bangladesh. Historically, the National Board of Revenue granted VAT-free import of qualifying ocean-going ships, raised the eligible age limit to twenty-five years in 2021 and relaxed the restriction on reselling ships above 5,000 DWT from five years to three; advance income tax on vessel imports was cut to one per cent for FY2021-22.[14] [7] Foreign-currency income of Bangladesh-flag ocean-going ships was declared tax-exempt until 2030.[7]

The December 2024 reversal

In December 2024 the NBR imposed 7.5 per cent VAT on ship imports, effective 15 December 2024, and on 17 December 2024 a 27.5 per cent tax on income from ocean-going ships, ending the benefit that had been expected to run to 2030.[9] Shipowners pressed for relief, and on 11 September 2025 it was reported that the Council of Advisers had waived the 7.5 per cent VAT on imports of ocean-going vessels exceeding 5,000 DWT, with the stated aim of boosting foreign-exchange earnings and employment.[10] We have not seen a corresponding restoration of the income-tax exemption.

What to check before buying

For every acquisition, confirm the customs duty rate for the vessel's tariff heading, whether the VAT waiver applies to the vessel's deadweight, the conditions attached to any exemption, such as flag, crewing and foreign-currency earnings, the advance income tax payable at import, and any lock-in on resale. Earlier exemptions came with conditions on Bangladeshi crewing and foreign-currency accounts, and breach exposed importers to recovery of the tax waived. Our guide to import duty in Bangladesh explains how duties and VAT are calculated at the port.

Inland vessels: a separate register

Vessels that ply on inland waters are registered under the Inland Shipping Ordinance 1976 (Ordinance No. LXXII of 1976), adopted on 21 September 1976, rather than under the merchant shipping register. Inland ships must be surveyed and registered; a surveyor inspects the vessel and certifies compliance, including marking, and the Registrar may refuse registration if the ship is mechanically or structurally defective.[12] The 1983 Ordinance expressly excludes ships registered under the inland regime from its registration chapter.[1]

The distinction matters for owners of lighterage, coastal and river fleets, who may need to know whether a vessel's intended trade takes it beyond inland limits and into the merchant shipping regime. It matters for financiers too, because security over an inland vessel follows a different register. A vessel's survey certificate and registration should match its actual operating area, or the owner risks detention and uninsured operation.

Comparing routes for ship registration in Bangladesh

The table summarises the routes most often used. On a phone, scroll it sideways.

Ship registration routes and regimes in Bangladesh
RouteLegal basisWho qualifiesKey documentKey point
Permanent registrationMerchant Shipping Ordinance 1983, Chapter 3Citizens, statutory corporations, qualifying companiesCertificate of registryCompulsory for sea-going ships above 15 tons net
Provisional registration abroadOrdinance, s 32Ships becoming entitled to the flag abroadProvisional certificateValid six months or until arrival at a registry port
Lease-purchaseOrdinance, s 2(3)Bangladeshi lessee with title passingLease agreementLets foreign-owned tonnage onto the register
Registered mortgageOrdinance, ss 40 to 46Lenders to registered ownersRecorded mortgage instrumentPriority by date of recording
Transfer abroadOrdinance, s 35(7)Owners reflaggingGovernment permissionNo action without prior written permission
Inland registrationInland Shipping Ordinance 1976Inland vesselsSurvey and registration certificatesSeparate from the merchant shipping register

Most disputes over ship registration in Bangladesh trace back to a small number of avoidable gaps: an ownership structure that fails the company test, a foreign deletion certificate that arrives late, a mortgage recorded after a competing charge, or a sale contract that ignores the government's permission requirement. The maritime, shipping and admiralty practice at TRW advises owners, buyers and lenders on each of these points. Our overview of maritime law in Bangladesh places registration in its wider context, and our guide to vessel arrest and release explains what happens when a registered ship becomes the target of a claim.

Common mistakes to avoid

  • Testing ownership once: the company test applies continuously, and a later share issue or board change can take a ship outside the definition of a Bangladesh ship.
  • Letting the provisional certificate lapse: the six-month validity runs from the certificate's date, not from the ship's arrival.
  • Signing a mortgage without recording it: priority depends on the date of recording, so an unrecorded mortgage is exposed to every later recorded charge.
  • Skipping the register search: inspection needs the owner's written consent, which should be a condition of the deal.
  • Assuming a mortgagee can sell privately: enforcement runs through the High Court Division.
  • Ignoring tax conditions: exemptions and waivers have changed repeatedly since 2024 and may be conditional.
  • Treating reflagging as administrative: moving a ship to a foreign registry requires prior government permission.

What to watch in 2026 and beyond

Three questions will shape ship registration in Bangladesh over the next year. The first is whether the Merchant Shipping Act 2020 text is brought into force, which would introduce express bareboat-charter registration and restructure the mortgage chapter.[2] The second is the future of the 2019 flag-protection regime, which private owners have asked the government to repeal.[11] The third is fiscal: the VAT waiver of September 2025 eased imports, but the income-tax treatment of ocean-going ships remains a live issue for owners.[9] [10]

The earliest decisions carry the most weight: which entity will own the ship, how the purchase and finance documents deal with deletion, consent and recording, and how the tax position is locked in at import. If you are buying, financing, reflagging or selling a ship, contact TRW for advice on structuring and completing the registration.

Frequently asked questions

Which law governs ship registration in Bangladesh?

Chapter 3 of the Bangladesh Merchant Shipping Ordinance 1983 governs the registration of sea-going Bangladesh ships above fifteen tons net with mechanical propulsion. Inland vessels are registered under the Inland Shipping Ordinance 1976.[1] [12]

Has the Merchant Shipping Act 2020 replaced the 1983 Ordinance?

A text titled the Bangladesh Merchant Shipping Act 2020 is published on the Department of Shipping portal and states that it commences on a date notified in the Gazette. We have not located a commencement notification, so confirm its status before relying on it.[2]

Who is the registrar of ships in Bangladesh?

The Director General of Shipping is the Registrar General, and the Principal Officer at Chattogram, who heads the Mercantile Marine Office, is the Registrar.[1] [3]

Can a foreign-owned company register a ship in Bangladesh?

Not if it is foreign-controlled. A company qualifies only if its principal place of business is in Bangladesh, Bangladeshi citizens hold more than half the shares or votes, most directors are citizens and the chairman or managing director is a citizen. A qualifying lease-purchase arrangement is an alternative route.[1]

How long is a provisional certificate of registry valid?

A provisional certificate issued abroad by a Bangladeshi consular officer is valid for six months from its date or until the ship arrives at a port with a Registrar, whichever comes first.[1]

How do competing ship mortgages rank?

Registered mortgages rank by the date each is recorded in the Register Book, not the date of the instrument, regardless of notice.[1]

Can a bank enforce a ship mortgage in the Admiralty Court?

Yes. In February 2026 the High Court Division held that a bank's suit to recover a loan secured on a vessel is maintainable under section 3(2) of the Admiralty Court Act 2000 and is not barred by the Artha Rin Adalat Ain 2003.[13]

Can a Bangladesh ship be reflagged abroad?

Only with the previous written permission of the government. The Registrar will not act on an application to transfer registry outside Bangladesh without it.[1]

Is VAT payable on importing an ocean-going ship?

A 7.5 per cent VAT was imposed in December 2024, and in September 2025 the government waived it for ocean-going vessels exceeding 5,000 DWT. Check current conditions for each vessel.[9] [10]

What does the Flag Vessels Act 2019 require of foreign ships?

Foreign vessels generally need a waiver certificate, sought through their local agents from the Mercantile Marine Department fifteen days before loading, because cargo preference is given to Bangladesh-flag vessels.[4] [5]

Source register

Primary legal and regulatory sources

Materials checked on 23 October 2026. Confirm the current official text before relying on any provision.

  1. Bangladesh Merchant Shipping Ordinance 1983 (Ordinance No. XXVI of 1983), consolidated text — ILO NATLEX
  2. Bangladesh Merchant Shipping Act 2020 text — Department of Shipping portal
  3. Shaheen, Alamgir and Islam, 'Ship Registration System of Bangladesh: An Assessment', BMJ Vol 4 Issue 1 — Bangabandhu Sheikh Mujibur Rahman Maritime University
  4. Bangladesh Flag Vessels (Protection of Interests) Act 2019 (Act No. 18 of 2019) — UNEP LEAP / FAOLEX
  5. The Daily Star, 21 February 2023 — Foreign ships face uncertainty in getting key certificate
  6. The Business Standard, 2 September 2021 — Shipping agents demand amending Flag Vessels Act
  7. The Daily Star, 14 June 2024 — Oceangoing vessels sail past 100 milestone
  8. The Business Standard, 5 October 2024 — Uncared for, Shipping Corp fleet dwindles to almost nothing
  9. The Financial Express, 1 August 2025 — Ocean-going ship imports may get tax exemption again
  10. Jagonews24, 11 September 2025 — Govt waives 7.5% VAT on large ocean-going vessels
  11. The Financial Express, 12 October 2025 — Scrapping flag vessel act sought to boost ocean-going shipping industry
  12. Inland Shipping Ordinance 1976 (No. LXXII) — ILO NATLEX record
  13. Supreme Court of Bangladesh, High Court Division (Admiralty), 26 February 2026 — Basic Bank Limited v M.V. Crystal Sapphire, Admiralty Suit No. 29 of 2017
  14. The Daily Star, 15 June 2021 — Tax benefit to spur growth of oceangoing shipping sector

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