White-Label VoIP, Calling-Minute Resale and Telecom Agency Agreements in Bangladesh

White label VoIP Bangladesh: who is really selling the call

White label VoIP Bangladesh offers look simple: a licensed operator supplies the network, numbers and gateway access, and an entrepreneur sells calling plans under its own name. Bangladeshi law does not treat that as a branding exercise. It asks who is providing the telecommunication service to the customer, and whether the licensed operator has a BTRC permit to let someone else use its system commercially. Get those two answers wrong and both parties are exposed: the entrepreneur for providing an unlicensed service, the operator for an unpermitted arrangement under section 40.[1]

This guide answers one question: can an entrepreneur sell calls using another company's network and licence? It separates software supply, referral, disclosed agency, wholesale resale and service under the entrepreneur's own brand; analyses section 40, permits and licence conditions; identifies the customer's legal service provider; allocates billing, regulatory duties and complaints; and addresses suspension and customer migration. Licence categories, tariffs and gateways are covered in sibling guides that we link rather than repeat.

Summary: An entrepreneur can lawfully earn money from calls carried on another company's licence, but only in structures where the licensed operator remains the service provider to the customer, or where BTRC has issued a permit for the arrangement. Software supply and referral are generally safe; disclosed agency is possible within the licensee's conditions; wholesale resale and own-brand service amount to providing a telecom service and need a licence or a BTRC-approved structure. The 2026 reform discussions on resellers concern broadband, not voice, and do not yet change this.

Key point: Section 40 of the Telecommunication Act prohibits an operator from allowing any other person to use its telecommunication system or facilities on a commercial basis without a BTRC permit, and section 35 prohibits anyone from providing a telecommunication service without a licence. A white-label deal that skips both is not a grey area; it is two offences committed by two parties.[1]

At a glance

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Table of Contents

White label VoIP Bangladesh: the two provisions that decide every deal

Two sections of the Bangladesh Telecommunication Act 2001 govern every arrangement in which one business sells calls carried by another. Section 35(1) provides that no person shall, without a licence, establish or operate a telecommunication system or provide any telecommunication service in Bangladesh or to any place outside it.[1] Section 40(1) provides that an operator shall not, without a permit issued by the Commission, allow any other person, on a commercial basis or for fees, price or other consideration, to use its telecommunication system or any installation, apparatus or facility by which telecommunication services can be provided.[1]

Section 35 targets the entrepreneur, section 40 the operator. A white label VoIP Bangladesh arrangement must satisfy both. The entrepreneur must not be providing a telecommunication service in its own right, or must hold a licence; and the operator must either keep the service as its own or obtain a section 40 permit for letting the entrepreneur use its system.

How a section 40 permit works

When an operator applies, BTRC may grant a permit after inquiry if it is satisfied that the permit will not adversely affect the telecommunication system or the provision of services. It may impose conditions it considers appropriate, the permit lasts for the period stated, and BTRC may cancel it at any time if a condition is breached.[1] The Act defines "permit" by reference to section 40(2), so a permit is a distinct authorisation, not an informal consent.[1]

Penalties

Both provisions are criminal. As originally enacted, section 40 carried up to three years' imprisonment or a fine for a first offence, and section 35 up to ten years' imprisonment or a fine.[1] The fine levels were later raised and then scaled back by the 2025 amending ordinance, which the government said would reduce high and repetitive penalties; unlicensed operation still carries imprisonment of up to ten years.[11] [13] Check the current consolidated text, summarised in our overview of telecommunications law in Bangladesh, before quoting a figure.

Five models, from software supply to own-brand service

Entrepreneurs describe very different businesses as white label. The legal analysis depends on which of five models the arrangement really is, judged by substance rather than labels in the contract.

Software supply

A company that licenses softphone apps, switching software or billing platforms to a licensed operator, and is paid a licence fee, is a technology supplier. It does not provide calls to anyone. The operator deploys the software as part of its own service, under its own licence. Equipment rules still matter: under the IPTSP guidelines, importers of VoIP adapters or IP phones need BTRC's prior permission.[3] Where the supplier also hosts and runs the platform, the line moves; see our guide to cloud PBX in Bangladesh.

Referral

A referral partner introduces customers to a licensed operator and earns a commission, while the customer signs up with, is billed by and complains to the operator. This is marketing, not service provision. The risk lies in drift: a referral partner that begins collecting payments, setting prices or issuing credentials has moved towards agency or resale.

Disclosed agency

The IPTSP guidelines allow a licensee to appoint agents, independent contractors or subcontractors to carry out works or provide services that enable it to discharge its licence obligations, provided the licensee remains liable for their acts and omissions. Subcontracting any part of the services or the system needs BTRC's prior written permission.[3] A disclosed agent sells the licensee's service, at the licensee's approved tariff, on the licensee's terms, and makes clear to customers who the provider is.

Wholesale resale

A reseller buys minutes or capacity in bulk and resells them to its own customers at its own prices. The reseller is now providing a telecommunication service, and the operator is letting it use its system commercially. Without a licence for the reseller and a section 40 permit for the operator, both are exposed.[1] BTRC has applied the same logic to broadband: in January 2023 it warned that ISPs appointing agents to sell internet services were engaged in illegal resale, in violation of the Act and the ISP guidelines, and threatened licence cancellation.[5]

Service under the entrepreneur's own brand

True white label VoIP Bangladesh service, in which the customer contracts with and pays the brand owner while the operator stays invisible, is the most exposed model. The brand owner looks like the service provider in every respect that matters: contract, billing, support and reputation. Unless it holds a licence, or BTRC has approved the arrangement, it is providing an unlicensed service.

Identifying the customer's legal service provider

The central question in any dispute, inspection or enforcement action is who the customer's service provider is. Contracts that call one party a "platform partner" do not answer it. BTRC and the courts will look at the obligations that the licensing guidelines attach to a service provider and ask who performs them.

The indicators that matter

• Tariff: a licensee must file a tariff chart and may not start a service before BTRC approves it; changes need written approval.[3] Whose approved tariff does the customer pay?
• Numbers: numbers are assigned by BTRC to the licensee and remain the Commission's property.[3] Whose range do the customer's numbers come from?
• Subscriber register: the licensee must keep a register with name, address, national ID, number or IP address, activation date and device identifiers, open to BTRC and law enforcement.[3] Who holds it?
• Complaints: the licensee must operate a complaints system, keep a log and report complaint numbers to BTRC.[3] Who answers the customer?
• Billing records: the licensee must keep metering records and separate call records for interconnected traffic.[3] Whose system generates the bill?

Applying the test

If the licensee performs all five functions, and the entrepreneur's role is sales and branding support disclosed to the customer, the licensee is the service provider. If the entrepreneur performs most of them, it is the service provider in substance, whatever the contract says. Split arrangements, where the entrepreneur bills but the licensee keeps the register, are the hardest to defend and the most common.

Licence conditions that limit what an operator can offer

Even an operator that wants to support a white-label partner is constrained by its own licence. These conditions are the first thing BTRC will examine if an arrangement comes to its attention.

No transfer of the licence

An IPTSP licence and any right under it cannot be transferred in whole or in part, and any transfer is void. The licensee may not pledge it as security.[3] The ISP guidelines similarly prohibit transfer of the licence or rights under it, wholly or partly, without prior government permission.[4] A white-label agreement that in substance hands the entrepreneur the right to provide service under the operator's licence risks being treated as a partial transfer.

Scope of services

An IPTSP licensee may not provide services beyond those in its IPTSP and ISP licences.[3] An operator cannot lend a partner authority it does not have. A zonal licensee, for example, cannot support a nationwide white-label product.

Call centres reselling telephony

Call centres sometimes drift into selling calls to walk-in or business customers. The 2013 call centre registration prohibits sub-leasing, partnership or third-party interests in the registration, forbids switched telephony and public call office services, and confirms that a registration does not authorise any service needing a separate licence.[8] Registration questions are covered in our guide to the call centre licence in Bangladesh.

What the 2025 to 2026 reforms change, and what they do not

The Telecommunications Network and Licensing Policy 2025 reorganises licences into access, infrastructure, international and non-terrestrial layers, and merges IPTSP licences into fixed telecom service licences on migration.[2] The transition and its 2027 soft cut-off are explained in our guide to telecom licensing reform in Bangladesh. For resale, three points matter.

MVNOs: a licensed route to an own-brand service

The policy introduces a Mobile Virtual Network Operator licence under the cellular mobile category, to enhance consumer choice and competition, with guidelines on eligibility, interconnection and operating conditions to follow.[2] For mobile services, this is the regulated version of an own-brand model: the brand owner holds its own licence and buys network capacity wholesale. Until BTRC issues the MVNO guidelines, there is no shortcut.

The broadband reseller model

In May 2026 BTRC and the telecoms division agreed in principle to introduce a reseller model for broadband, under which unlicensed operators could register with BTRC and sell services provided by licensed ISPs without holding a licence; the BTRC chairman said resellers would simply sell services provided by licensed ISPs.[6] The revised draft policy sent for approval on 24 May 2026 would let district ISPs appoint resellers under nationwide operators.[7] These proposals concern internet access, not voice, and were not in force when this guide was updated.

The policy's view of intermediaries

The reform was driven partly by hostility to layers that add cost without value. Commentators on the 2025 reset reported claims that intermediaries in the old licensing structure had extracted large sums without adding meaningful value.[12] A voice resale model that looks like a revenue-extracting layer is unlikely to attract a sympathetic permit decision unless it brings customers, investment or service quality.

Allocating billing, regulatory duties and complaints

Where a lawful structure is chosen, usually disclosed agency or a permitted arrangement, the contract must allocate each regulatory function expressly. A white label VoIP Bangladesh contract that leaves these points open shifts risk to whichever party BTRC reaches first.

Billing and tariffs

The customer must pay the licensee's approved tariff. A partner margin charged on top of that tariff risks being an unapproved charge. The cleaner structure is for the licensee to bill at its approved tariff and pay the partner a commission. Interconnection costs also constrain margins: BTRC's 2021 floor for off-net app calls was Tk 0.40 a minute, of which Tk 0.10 went to mobile operators and Tk 0.04 to interconnection exchanges.[9] Pricing and numbering are covered in our guide to the VoIP licence in Bangladesh.

Regulatory duties

The licensee should keep the subscriber register, call records, lawful interception interfaces and BTRC reporting. The partner can collect know-your-customer documents as the licensee's agent, but the register must sit with the licensee.[3] Audit rights, data-sharing terms and confidentiality obligations should flow both ways. Data handling between the parties also engages the Personal Data Protection Act 2026, discussed in our data protection compliance guide.

Complaints and customer communications

Customers must know who their provider is. The licensee's customer charter, complaints system and published service information apply to customers acquired through agents.[3] A partner may run first-line support, but escalation, logs and reporting must sit with the licensee.

Suspension, licence loss and customer migration

White-label businesses fail most often not through their own breach but through the operator's. The contract should deal with that before it happens.

When the operator is sanctioned

BTRC enforces against licensees for misuse of their facilities. In July 2026 it imposed about Tk 8.68 crore in administrative fines on four mobile operators after 8,682 SIMs were found to have been used for illegal international call termination.[10] A partner whose traffic triggers sanctions against the operator should expect immediate suspension under the commercial contract, and possibly investigation. International termination rules are covered in our guide to international voice services in Bangladesh.

When the operator stops providing service

An IPTSP licensee that intends to stop providing service must give the Commission and its subscribers three months' written notice.[3] That notice period is the window for migration. Because the customers are legally the licensee's subscribers and the numbers belong to BTRC, the partner cannot simply move them to another operator.[3] A migration clause should require the licensee to cooperate with transfers to a successor licensee, subject to BTRC's number portability rules.

When the partner leaves

If the partner exits, customers remain with the licensee. The contract should cover customer communications, final commissions and the return of any data the partner collected as agent. Disputes over these points are increasingly arbitrated; see our guide to technology arbitration in Bangladesh.

Due diligence on the operator before signing

A partner's business is only as durable as the licence beneath it. Before committing to a white label VoIP Bangladesh arrangement, the partner should examine the operator with the same care a lender would.

Licence scope, area and term

IPTSP licences come in nationwide and zonal forms, and only an ISP licensee of the matching scope may hold one; the IPTSP licensee also carries the conditions of its ISP licence.[3] Ask for the licence itself, the approved tariff, any app or value-added service approvals and evidence that fees are paid. A licensee that has not paid its dues is a licensee at risk of cancellation.

Migration status

Under the 2025 policy, once the new regime begins, existing licensees may renew only into the new categories, and most migration is to happen by the soft cut-off of 30 June 2027.[2] Ask whether the operator intends to migrate to a fixed telecom service licence, and whether any agent or partner arrangements will need fresh approval in the new category.

Ownership and control

An IPTSP licensee must obtain BTRC's prior written approval before any change in its ownership or shareholding, and may not transfer or issue shares without permission; breach can lead to cancellation.[3] A partner that is also taking equity in the operator, a common way of locking in a white-label deal, must build that approval into the timetable.

Enforcement history

Check whether the operator has faced BTRC fines, show-cause notices or suspension, particularly for traffic misuse.[10] Ongoing compliance and enforcement procedure is covered in our BTRC compliance guide.

Comparing white-label structures

The table below compares the five models in a white label VoIP Bangladesh analysis. On a phone, scroll it sideways.

Most viable businesses sit in the first three rows. Moving to the last two requires either a licence of the entrepreneur's own or a structure that BTRC has expressly approved.

Step-by-step: structuring a lawful calling partnership

The sequence below reflects how we structure partnerships between licensed operators and commercial partners.

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Mistakes to avoid in white label VoIP Bangladesh deals

• Relying on the operator's licence as a shield. Section 35 applies to whoever provides the service, not only to the network owner.[1]
• Signing without a section 40 analysis. Commercial use of an operator's system by another person needs a permit.[1]
• Charging a margin above the approved tariff. The customer price must be the licensee's approved tariff.[3]
• Letting the partner hold the subscriber register. The register is a licensee obligation open to BTRC and law enforcement.[3]
• Assuming broadband reseller reforms cover voice. The 2026 reseller proposals concern ISPs and were not in force.[6]
• Ignoring migration. Customers and numbers cannot move without the licensee and BTRC's rules.[3]

What to watch through 2027

Three developments could open new routes. First, BTRC's MVNO guidelines, which will define the licensed own-brand mobile model.[2] Second, the government's decision on the revised licensing policy and the broadband reseller model, which may be extended or adapted for other services.[7] Third, the fixed telecom service guidelines into which IPTSP licences will migrate, which will set new conditions on agents and subcontracting.[2] After the 2025 to 2026 amendments to the Act, these decisions rest with BTRC for most licence categories.[11]

Until then, the safe answer to the white-label question is to keep the licensee as the provider and the partner as a disclosed agent, or to apply for a permit. TRW's corporate and commercial advisory team and joint ventures practice structure operator partnerships and permit applications; contact TRW to review a proposed deal.

Frequently asked questions

Can I sell calling plans under my brand using a licensed operator's network?

Not as the service provider without a licence. Section 35 requires a licence to provide a telecom service, and the operator needs a section 40 permit to let you use its system commercially.[1]

What is a section 40 permit?

A BTRC authorisation allowing an operator to let another person use its telecom system or facilities commercially. BTRC may attach conditions, fix its duration and cancel it for breach.[1]

Can an IPTSP appoint sales agents?

Yes. IPTSP licensees may appoint agents and contractors but remain liable for them, and subcontracting any part of the service needs BTRC's prior written permission.[3]

Is buying minutes wholesale and reselling them legal?

Not without the right authorisations. The reseller would be providing a telecom service, and BTRC has called agent-based resale of internet services illegal.[1] [5]

Does the 2026 reseller model allow voice resale?

No. The model agreed in principle in May 2026 concerns broadband resellers of licensed ISPs and was not in force at the time of writing.[6]

Who owns the phone numbers in a white-label service?

BTRC. Numbers are assigned to the licensee, and neither the licensee nor its subscribers acquire proprietary rights in them.[3]

Can a partner add its own margin to the operator's call rates?

That is risky. A licensee may charge only its BTRC-approved tariff, so a commission paid by the licensee is the safer structure.[3]

Is an MVNO the lawful route to an own-brand mobile service?

Yes, once available. The 2025 policy introduces an MVNO licence under the cellular mobile category, with guidelines still to be issued.[2]

How much notice must an operator give before stopping service?

An IPTSP licensee must give BTRC and its subscribers three months' written notice before stopping service.[3]

Can a call centre resell telephone calls?

No. The call centre registration prohibits switched telephony and public call office services and does not authorise services that need a separate licence.[8]