Launching a Voice and Video Calling App in Bangladesh: OTT Approvals and Telecom Regulation

Voice calling app Bangladesh: why features decide the law

A voice calling app Bangladesh users can download from an app store is not regulated as one product. The same code can be an unlicensed messaging tool, a licensed telephone service or an illegal international bypass route, depending on which features are switched on. The decisive features are whether calls stay inside the app, whether they break out to ordinary phone numbers, whether users receive a Bangladeshi number, and whether international traffic flows through the licensed gateways.[2] [4]

This guide answers one question: which app features change the regulatory position? It compares app-to-app, app-to-phone and incoming-number services; explains operator-specific app approvals; and deals with overseas users, server location, monitoring, identity checks and charging. It closes with three worked examples: a private communications app, an enterprise calling app and a diaspora calling product. Licences for selling minutes, international routing and privacy have their own guides in this series, linked rather than repeated.

Summary: Calls that stay inside an app have historically sat outside BTRC licensing, while any feature that connects app users to ordinary telephone numbers is IP telephony and needs a licensed operator. Since 2018 BTRC has approved IPTSP operators to run their own calling apps under specific conditions, including security deposits, routing through licensed gateways and subscriber registration. The 2025 licensing policy promotes OTT services and folds IPTSP licences into fixed telecom service licences, but detailed OTT guidelines are still pending, so each feature should be mapped before launch.

Key point: The licensing line is drawn at the public telephone network. App-to-app calling for non-business use was placed outside the IP telephony licence in 2009, but calling a mobile or landline number, or receiving calls on a Bangladeshi number, is IP telephony that only a licensed operator may provide, at a tariff BTRC has approved and through licensed interconnection and gateways.[2]

At a glance

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Table of Contents

Voice calling app Bangladesh rules: the legal starting point

Section 35 of the Bangladesh Telecommunication Act 2001 prohibits anyone from providing a telecommunication service in or from Bangladesh without a licence, and the Act defines telecommunication service widely enough to cover transmission of speech, value-added services and internet service.[4] Read literally, almost any calling feature is caught. What narrows the field is the licensing architecture BTRC built on top of the Act, and above all the IP telephony guidelines.

The 2025 to 2026 reforms have widened the statutory vocabulary without yet adding detailed app rules. The amending ordinance brought OTT services expressly within the Act's definitions, and the Telecommunications Network and Licensing Policy 2025 directs BTRC to "promote the proliferation of digital and over-the-top (OTT) services".[11] [1] The reform framework itself is explained in our guide to telecom licensing reform in Bangladesh, and the statute in our overview of telecommunications law in Bangladesh.

Where OTT services sit in the new framework

The policy creates a Telecom Enabled Service Provider (TESP) enlistment category for telecom-enabled services, naming SMS aggregation and "other emerging services", and leaves BTRC to define its scope from time to time.[1] Commentators have read TESP as the home for OTT and value-added services under light-touch regulation.[9] Enlistment is described as an option for entities seeking regulatory recognition, not a licence, but until BTRC publishes its scope a calling app cannot assume it will be enough.

App-to-app calling: outside the licence, within limits

The clearest rule is old. BTRC's amended IP telephony guidelines of June 2009 state that "PC to PC non-business voice traffic will be out of the scope of Licensing", adding that internet-based non-business voice traffic should not exceed limits the Commission decides.[2] A modern smartphone app is the successor to the PC client, and calls that start and end inside the app, over the user's own internet connection, fall on the unlicensed side of the line.

What "non-business" means for an app

The qualifier matters. The guideline excludes non-business traffic, which fits consumer messaging but leaves room for argument where an app is sold to businesses or charges per call. A voice calling app Bangladesh companies deploy internally, or an app that monetises calls directly, should not rely on the exemption without analysis. Advertising-funded or subscription apps that do not charge for individual calls are in a stronger position than apps that price minutes.

Global apps and local apps

The government has acknowledged the limits of its reach over foreign platforms. In 2021 the then telecom minister said of WhatsApp and Skype: "They are not registered here, so we do not have any authority over them."[7] A Bangladeshi company launching a comparable app is in a different position: it is reachable, its servers and staff are local, and it is more likely to face directions from BTRC. A draft BTRC regulation for digital, social media and OTT platforms was submitted to the High Court in October 2022 in writ proceedings; we found no record of it being finalised.[10]

When an ISP launches the app

A licensed internet service provider cannot launch an app-to-app service as freely as a start-up. The 2020 ISP guidelines allow ISPs to provide "any other Over The Top (OTT) services" and video conferencing only with BTRC's prior approval, pending new OTT regulations.[3] The licensed operator's own conditions follow it into the app business.

App-to-phone calling: where IP telephony begins

Once an app user can dial a mobile or landline number, the service is IP telephony. The IPTSP guidelines describe the licensee's business as providing "PC to Phone, Phone to PC, Phone to Phone or any other usages based on IP Telephony voice service to subscribers".[2] Only a licensed IP telephony service provider, or a licence with equivalent scope, may offer that feature. An app developer without a licence can supply the software to a licensed operator, but it cannot sell breakout calls itself.

The first IPTSP calling apps

BTRC began approving operator-run calling apps in 2018. Intercloud's app was cleared first, and in December 2018 Amber IT, BDCOM Online, MetroNet Bangladesh and Link3 Technology were approved, subject to fourteen conditions and a deposit of Tk 5 crore that BTRC could forfeit wholly or partly for violations.[5] The conditions required providers to prevent misuse that deprives the government or other entities of revenue, to route international call termination through licensed gateway and interconnection operators, and to obtain prior approval for value-added services.[5]

From case-by-case approval to a category

By June 2019 BTRC had decided to let any nationwide IPTSP launch an app-based call service, while reported conditions barred incoming and outgoing international calls through these apps.[6] The state-owned BTCL launched its own app, Alaap, in April 2021.[7] The approvals attach to the operator. A developer that wants app-to-phone calling must either hold the licence or partner with a licensee whose approval covers the app; the risks of the second route are analysed in our guide to white-label VoIP in Bangladesh.

Interconnection and routing

Breakout calls pass through the regulated interconnection chain. Under the IPTSP guidelines, domestic calls to other networks route through interconnection exchanges and international calls through ICX and IGW operators, and the licensee must not bypass them.[2] The 2025 policy is replacing those legacy layers, but it still requires access operators to reach international services through licensed international connectivity providers.[1] Gateway and routing rules are covered in our guide to international voice services in Bangladesh.

Incoming numbers: when the app becomes a telephone line

Giving app users a Bangladeshi telephone number, so that anyone can call them from a mobile or landline, is the feature that most clearly turns an app into a telephone service. Under the IPTSP guidelines, voice applications receive a separate numbering plan assigned by BTRC, numbers remain the property of the Commission, and neither the licensee nor its subscribers acquire proprietary rights in them.[2] An app cannot lawfully hand out numbers it has obtained informally from a licensee's range.

Numbers and number portability

The licensee must justify its use of numbers on request, inform BTRC of allocation arrangements within its range and comply with number portability requirements.[2] In practice, a product that offers incoming numbers is built by a licensed operator, or under a contract in which the operator remains the service provider of record. Number allocation and the operator's own licence obligations are covered in our guide to the VoIP licence in Bangladesh.

Foreign numbers for Bangladeshi users

Some apps offer Bangladeshi residents a foreign number, so relatives abroad can call at local rates. Calls to that number arrive over the internet and are delivered to a handset in Bangladesh. If the app then connects those calls onwards to Bangladeshi mobile or landline numbers, it is terminating international traffic outside the licensed routes, which is the conduct BTRC targets as illegal VoIP.

Operator-specific app approvals and the 2025 transition

Every operator-run calling app in Bangladesh rests on that operator's licence and its specific approval. That makes due diligence on the operator as important as the app's design. A voice calling app Bangladesh users rely on can disappear overnight if the underlying licence lapses, is suspended or migrates without the approval being carried across.

Licences the approvals depend on

An IPTSP licence is available only to ISP licensees, and its terms incorporate the ISP licence; the IPTSP licensee may provide no services beyond those in the two licences.[2] The 2025 policy provides that IPTSP licences will be merged with the corresponding ISP licence during migration to the Fixed Telecom Service Provider licence, which authorises domestic and international voice, data and value-added services.[1] District fixed licences will cover internet and data only, so a district-level operator may not be able to host a calling app.[1]

Approvals in a moving framework

The policy sets a soft cut-off of 30 June 2027 for most migration, and BTRC sent a revised draft policy to the Posts and Telecommunications Division on 24 May 2026, proposing to reclassify fixed licences again.[1] [14] At the end of 2025 BTRC said guidelines for the new categories were awaiting government approval.[13] Any app agreement with an operator should therefore address what happens to the app approval on migration, and who applies to carry it forward.

Overseas users, international calls and bypass risk

Overseas users change the analysis more than any other feature. App-to-app calls between a user in Dhaka and a user in London are, on the 2009 guideline, outside licensing if they are non-business. But the moment either leg reaches the Bangladeshi telephone network, the call is international voice traffic.[2]

Why regulators watch app traffic

BTRC's concern has always been revenue and routing. When it first approved IPTSP apps, its own engineering department warned that the service could turn incoming international calls into local calls and reduce government revenue.[5] The risk is not theoretical. In July 2026 BTRC fined four mobile operators about Tk 8.68 crore after 8,682 SIMs were found to have been used for illegal international call termination, and the report linked the practice to mobile dialler apps used for low-cost international calls.[8]

Design rules for apps with foreign users

• Keep app-to-app separate: a call between two app users should never be handed to a local SIM or line at either end.
• Route breakout through licensees: international calls to Bangladeshi numbers must enter through licensed international connectivity, not through local SIM boxes or unlicensed gateways.[1]
• Disable two-stage dialling: the IPTSP guidelines prohibit second-stage dialling codes, a feature classic calling-card products rely on.[2]
• Log origin and destination: call records should show where each leg started and ended, so the operator can prove compliance.

Server location, monitoring and lawful interception

A pure app-to-app service run from foreign cloud servers has no BTRC licence condition requiring local hosting. A licensed operator's app does. IPTSP licensees must provide lawful interception equipment and technologies, extend online and offline monitoring with redundancy, and support online listening of call content to ETSI and CALEA standards as specified by the monitoring centre.[2]

Monitoring and records

The licensee must also place an operations and maintenance console at BTRC's premises with storage for six months of traffic data, logs and CDR or IPDR records, give BTRC remote access, include all allocated IP addresses in call records and report device MAC addresses monthly.[2] An app architecture that keeps media and signalling outside Bangladesh may make these duties impossible to meet, which in turn puts the operator's licence at risk.

The 2026 interception framework

The 2009 guidelines refer to the National Monitoring Centre. The 2025 amending ordinance abolished the NTMC and created a Centre for Information Support that provides technical support to authorised agencies, with interception subject to approval by a quasi-judicial council.[12] The policy also requires all licensees to maintain lawful interception capability, exercised only on valid legal authorisation.[1] Call content and metadata also engage the Personal Data Protection Act 2026; recording, retention and overseas hosting are analysed in our guide to call recording law in Bangladesh.

Identity verification and subscriber records

App-to-app products typically verify users by mobile number and one-time password. That is a product choice, not a telecom condition. Licensed IP telephony is different: the IPTSP licensee must keep a register of subscribers with name, address, national ID number, business registration number where relevant, telephone number or IP address, activation date and the MAC address or IMEI of the device, open to BTRC and law enforcement.[2]

Confidentiality of subscriber data

The same guidelines limit how subscriber information may be used: internal planning, provisioning and billing, interconnection, other purposes BTRC approves and assistance to law enforcement as the law provides.[2] An operator-run app that uses calling data for advertising or analytics needs to check those limits as well as the data protection rules.

Why verification protects the operator

Strong verification is also the main defence against bypass. A breakout service with anonymous sign-up and bulk accounts is exactly what bypass operators look for. For a voice calling app Bangladesh operators host, national ID checks for any account that can reach the telephone network are a sensible baseline even where the product is free.

Charging models and tariff approval

How an app makes money also changes its position. Free app-to-app calling funded by advertising or subscriptions raises no tariff issue. Charging for calls to telephone numbers does. An IPTSP licensee must file a tariff chart with maximum and minimum charges and may not start providing any service before BTRC approves its tariff; changes also need written approval.[2]

Price floors for app calls

BTRC has set minimum prices for app breakout calls. From May 2021 it imposed a minimum of Tk 0.40 a minute for off-net calls made through apps such as Brilliant Connect and Alaap, of which Tk 0.10 went to mobile operators as interconnection charges and Tk 0.04 to interconnection exchange operators.[7] Current tariffs are set by BTRC's schedule and should be checked before pricing; the tariff process is covered in our guide to the VoIP licence in Bangladesh.

Value-added features

Voicemail, call recording, conferencing and similar features are value-added services. The 2018 approvals required prior BTRC approval for value-added services, and the ISP guidelines require prior approval for video conferencing.[5] [3] The 2025 policy allows access network licensees to offer any technically viable value-added service within their licence scope, which should simplify this once the new licences issue.[1]

Comparing calling features

The table below maps each voice calling app Bangladesh feature to its regulatory consequence. On a phone, scroll it sideways.

Three worked examples

The examples below show how the same building blocks produce different answers for a voice calling app Bangladesh business. Each assumes a Bangladeshi company with local staff and users.

A private communications app

A start-up launches an encrypted messaging app with free voice and video calls between registered users, funded by a premium subscription for storage and themes. It does not connect to telephone numbers or issue numbers. On the 2009 guideline the calls are non-business app-to-app traffic outside IP telephony licensing.[2] The live issues are data protection, content and cyber law rather than BTRC licensing, together with any future TESP enlistment. Our guides to cyber law in Bangladesh and the data protection law cover those areas.

An enterprise calling app

A software company sells a softphone app to banks and logistics firms so that field staff can call colleagues and customers. Internal calls stay in the app, but customer calls go to mobile numbers and staff want a fixed Bangladeshi number shown as caller ID. The internal leg is business app-to-app traffic, outside the express exclusion; the customer leg is app-to-phone IP telephony; and the number is a numbering resource.[2] The workable structure is a licensed operator providing breakout and numbers, with the software company as its technology supplier. Where the product is hosted for many customers, see our guide to cloud PBX in Bangladesh.

A diaspora calling product

A company targets Bangladeshi workers in the Gulf and Malaysia, selling prepaid credit to call family members' mobiles in Bangladesh. Every paid call is international voice terminating on Bangladeshi networks. It must enter through licensed international connectivity at approved rates; reported conditions on IPTSP apps barred international calls; and terminating the calls through local SIMs or unlicensed routes is the illegal VoIP that BTRC fines operators for.[6] [8] A lawful version needs a foreign-side carrier contract with a licensed Bangladeshi international connectivity provider.

Step-by-step: launching a calling app lawfully

The sequence below reflects how we review a voice calling app Bangladesh product before launch.

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Mistakes to avoid with a voice calling app Bangladesh launch

• Treating breakout as a feature toggle. Adding calls to phone numbers turns an unlicensed app into IP telephony.[2]
• Borrowing numbers informally. Numbers belong to BTRC and are assigned to licensees, not to app developers.[2]
• Relying on another operator's approval without checking scope. App approvals are operator-specific and conditional.[5]
• Pricing without tariff approval. A licensee may not charge for a service before its tariff is approved.[2]
• Ignoring international legs. Terminating foreign-originated calls onto local networks outside licensed routes is the core illegal VoIP risk.[8]
• Hosting everything offshore on a licensed product. Licensee monitoring and interception duties assume reachable infrastructure.[2]

What to watch in 2027

Three developments will define the next phase. First, BTRC's definition of the TESP enlistment scope, which will show whether calling apps that never touch the telephone network must enlist.[1] Second, the government's decision on the revised licensing policy and the migration of IPTSP licences into fixed telecom licences, which will decide how existing app approvals carry over.[14] Third, the practical operation of the new interception framework under the 2026 amendment to the Telecommunication Act.[12]

Each feature should be mapped to a licence, a licensee or a lawful exemption before launch, and revisited as the guidelines arrive. TRW's corporate and commercial advisory team reviews calling products, operator partnerships and BTRC approvals; contact TRW to discuss your app.

Frequently asked questions

Is app-to-app calling legal in Bangladesh without a licence?

BTRC's IPTSP guidelines place PC-to-PC non-business voice traffic outside licensing, which covers typical consumer app-to-app calls. Business use and per-call charging need closer analysis.[2]

Can my app let users call mobile numbers in Bangladesh?

Only through a licensed IP telephony operator with BTRC approval for the app and an approved tariff. App-to-phone calling is IP telephony under the IPTSP guidelines.[2] [5]

Can a calling app give users a Bangladeshi phone number?

Only via a licensed operator assigned numbers by BTRC. Numbers are the Commission's property and are allocated under the national numbering plan.[2]

Which local operators run approved calling apps?

Reported approvals include Intercloud, Amber IT, BDCOM Online, MetroNet and Link3 in 2018, and BTCL's Alaap launched in 2021. BTRC later allowed any nationwide IPTSP to apply.[5] [6] [7]

What security deposit did BTRC require for calling apps?

The 2018 approvals required a Tk 5 crore deposit that BTRC could forfeit wholly or partly for violations. Check current conditions with BTRC.[5]

Can an ISP launch its own OTT calling service?

Only with BTRC's prior approval. The 2020 ISP guidelines require prior approval for other OTT services and video conferencing pending new regulations.[3]

Must a calling app keep its servers in Bangladesh?

There is no general hosting rule for unlicensed app-to-app services, but licensed operators must support lawful interception, local monitoring consoles and six months of call records, which offshore architectures can make difficult.[2]

Is there a minimum price for app calls to phone numbers?

From May 2021 BTRC set a minimum of Tk 0.40 a minute for off-net app calls. Tariffs change, so check BTRC's current schedule.[7]

Will calling apps need TESP enlistment under the 2025 policy?

Possibly. The policy created TESP enlistment for telecom-enabled services and lets BTRC define its scope, but that scope had not been published at the time of writing.[1]

What penalties apply to illegal VoIP through apps?

Unlicensed service provision is an offence under section 35, and operators face administrative fines; in July 2026 BTRC fined four mobile operators about Tk 8.68 crore over SIMs used for illegal call termination.[4] [8]