Bangladesh Bank Approval in 2026: Foreign Exchange, Circulars, CIB, Licensing and Reform

by Barrister Tahmidur Rahman | Oct 20, 2026 | Banking & Finance, Insights | 0 comments

TRW Insight / Bangladesh

Most cross-border payments in Bangladesh are cleared by banks under delegated authority; the rest need the central bank itself. Knowing which is which, and which circular governs, decides whether a transaction closes in days or stalls for months.

Updated 20 October 2026Legal insightBangladesh22 min read

Bangladesh Bank approval in 2026: who decides and when

A Bangladesh Bank approval is the regulatory permission that sits between a commercial decision and the money actually moving. A foreign parent can agree to sell shares in its Dhaka subsidiary, a branch can close its accounts showing a profit, and a sponsor group can raise the capital for a new bank, but none of it completes until the central bank, or a bank acting under its delegated authority, says yes. In 2026 the rules on who says yes, and when, have shifted more than at any time in a decade.

This guide explains when a business needs Bangladesh Bank approval and when an authorised dealer bank can act alone; how share transfers to non-residents, guarantees, foreign loans and branch office remittances are handled after the arrival of the Invest Bangladesh Authority; how to read and track BRPD, FEPD and FEID circulars; how CIB circulars and the CIB report work; how loans are classified after the 2025 changes; what a banking licence requires under section 31 of the Bank Company Act 1991; and where the 2024 to 2026 banking sector reforms stand. Where TRW has a detailed guide on a sub-topic, we link to it rather than repeat it.

Bangladesh Bank approval — banker reviewing a foreign exchange application file
Most applications start and end with the authorised dealer bank

Summary: Most foreign exchange transactions in Bangladesh are approved by authorised dealer banks under general permissions in Bangladesh Bank's consolidated circulars; Bangladesh Bank itself decides only what falls outside them, always on an application routed through the bank. Share transfers to non-residents, guarantees for non-residents, branch profit remittances, banking licences and changes of control each have their own rule, and in 2026 several of those rules were rewritten.

Key point: Since FEID Circular No. 01 of 8 March 2026, a share transfer between a resident and a non-resident in an unlisted company needs no prior central bank approval if it is made at fair value, and repatriation of sale proceeds is approval-free up to defined thresholds. The approval burden has moved to the authorised dealer bank, which now carries the valuation risk.

At a glance

01

Delegated authority

Authorised dealer banks approve most foreign exchange transactions; anything outside the circulars goes to Bangladesh Bank through the bank, never directly.

02

Share transfers

FEID Circular No. 01 of 2026 freed fair-value transfers from prior approval and raised the repatriation thresholds.

03

Branch offices

Invest Bangladesh grants the permission; Bangladesh Bank receives the section 18B report and checks branch profit remittances after the event.

04

Circulars and CIB

BRPD sets prudential rules, FEPD and FEID set foreign exchange rules, and the CIB runs the credit database every lender checks.

05

Reform

The Bank Resolution Act 2026, the five-bank merger, asset quality reviews and a pending Bank Company amendment reshape the sector.

Table of Contents

When a business needs Bangladesh Bank approval

Bangladesh Bank wears several hats at once. It is the foreign exchange regulator under the Foreign Exchange Regulation Act 1947, the licensing authority and prudential supervisor of banks under the Bank Company Act 1991, the operator of the Credit Information Bureau, and, since 2025, the resolution authority for failing banks. A request for Bangladesh Bank approval can therefore mean very different things: permission to remit money abroad, consent to a change in a bank's shareholding, or a licence to carry on banking business at all.

For foreign exchange, the starting point is a prohibition. Payments to non-residents, dealings in foreign currency and transfers of securities to non-residents are restricted unless permitted, and Bangladesh Bank grants those permissions through directions to authorised dealers under section 20(3) of the 1947 Act. Each consolidated circular cites that section as its legal basis.[2] A contract, an invoice or a board resolution does not authorise a cross-border payment; only a general or specific permission does.

Delegated authority to authorised dealer banks

In practice most transactions never reach Bangladesh Bank. Authorised dealer banks, known as ADs, approve them under general permissions in the circulars and report afterwards. Where a transaction falls outside that delegated authority, the application must be submitted to Bangladesh Bank through the AD and not by the customer directly, and an approval generally lapses after 45 days unless it states a longer period or is revalidated.[2] The AD is therefore both the gatekeeper and the messenger, and the quality of its covering recommendation often decides how quickly the file moves.

Bangladesh Bank's role in inflows and outflows

The control is asymmetric. Inflows, such as equity capital, export proceeds and remittances, are broadly welcome, but each must arrive through the banking channel and be documented, because that record is what later permits dividends, sale proceeds and loan repayments to leave. Outflows on current account are largely delegated to ADs within limits. Capital account outflows, such as lending to non-residents, guarantees for non-resident obligations and investment abroad, remain the area where Bangladesh Bank's own approval is most often required. Our guide to foreign exchange regulations in Bangladesh maps the full regime.

Foreign exchange transactions beyond delegated powers

The question to ask of any cross-border transaction is not whether Bangladesh Bank approval is needed in the abstract, but whether a general permission in the current consolidated circular covers it. If it does, the AD acts. If it does not, the AD forwards the file with its recommendation.

Outward current account remittances

FEPD-1 Circular No. 40 of 30 September 2026 consolidates the rules for outward current account remittances other than imports and transport, is valid for one year and repeals earlier instructions other than the reporting rules in Volume 2 of the Guidelines for Foreign Exchange Transactions.[2] Travel, education, medical, family, service fee and dividend payments are all handled there, most within AD authority. We cover each head in our guide to outward remittance from Bangladesh, so this article does not repeat the limits.

Guarantees and credit involving non-residents

Guarantees are a common trap. FEPD-1 Circular No. 32 of 2 September 2026, the consolidated circular on loans, overdrafts, guarantees and external borrowings, lets ADs issue guarantees in favour of non-residents only within the authority it sets out, such as bid and performance bonds for Bangladeshi suppliers bidding internationally and certain export guarantees.[1] In other cases, including guarantees in favour of residents on behalf of non-residents, prior Bangladesh Bank approval is required.[1] Taka credit to non-residents is regulated in the same circular under sections 3, 4, 5, 18 and 20 of the 1947 Act.[1]

Foreign loans: Invest Bangladesh or Bangladesh Bank

Borrowing abroad is split between two regulators. Invest Bangladesh approval is required for foreign currency borrowing, including commercial loans and buyer's and supplier's credit, to import capital goods for new projects, replacement or expansion, and a Scrutiny Committee on Foreign Loan/Supplier's Credit verifies and approves the applications; loans used exclusively for working capital are not permitted.[4] Bangladesh Bank remains the approving authority for certain zone enterprises, finance companies and guarantees by banks.[1] Our guide to foreign loan approval in Bangladesh explains who decides each case, the cost ceilings and the general permission for parent loans.

Reading a circular before signing

Circular No. 32 states that its instructions remain valid for one year, that instructions issued during that year are to be read with it, and that where a newly incorporated provision creates a conflict, the original circular, FE Circular No. 34 of 2025, should be consulted.[1] A transaction document that refers simply to "Bangladesh Bank rules" without identifying the circular in force is an invitation to dispute.

Share transfers to non-residents under FEID Circular No. 01 of 2026

Share transfers involving non-residents were, for years, the classic case for prior central bank approval, with valuation debates that could hold a deal for months. On 8 March 2026 the Foreign Exchange Investment Department issued FEID Circular No. 01, a master circular on the transfer of shares and repatriation of sale proceeds in unlisted private and public limited companies, which consolidates and repeals the earlier instructions in GFET 2018 and later circulars.[3]

Transfers to non-residents

A transfer from a resident to a non-resident, or between non-residents, needs no prior approval provided it is made at fair value. A valuation report is not required where the deal value is up to Tk 10 million; above that, one is required.[3] Valuation reports must be prepared by a BSEC-licensed merchant banker or a chartered accountant listed with Bangladesh Bank or BSEC, using asset-based, market and discounted cash flow methods, either weighted or as a single justified method.[3]

Repatriation when a non-resident sells

When a non-resident sells to a resident, repatriation needs no prior approval if the price does not exceed net asset value on the latest audited accounts, if the deal value does not exceed Tk 10 million with a joint buyer-seller statement justifying the price, or if the deal value does not exceed Tk 1 billion and matches an independent fair valuation. All other cases go to FEID, and the AD must forward the application within three working days.[3]

Conditions and reporting

The parties must sign a dated memorandum of understanding, the audited accounts must be no more than six months older than it, and the transfer must complete within 45 days of the memorandum or the approval, whichever is later.[3] Capital gains tax and stamp duty must be paid by the non-resident from funds brought through the banking channel, not by the target company. The AD must report the transfer to FEID within 14 days with the RJSC-endorsed Form 117, an updated Schedule X and the valuation.[3] Shares in banks are different: a change of control there also needs prudential approval, discussed below.

Bangladesh Bank approval for branch office and liaison office remittances

Foreign companies that operate through a branch, liaison, representative or project office deal with two regulators, and confusing them is a frequent source of delay. The permission to open the office comes from the investment authority; Bangladesh Bank's role concerns the money.

Invest Bangladesh now registers the office

Applications for branch, liaison, representative and project offices are filed with Invest Bangladesh, the successor to BIDA, through its One-Stop Service, with hard copies to follow.[4] Initial approval is valid for three years. The office must then rent premises, open a bank account, bring in at least US$50,000 within two months of approval and apply to the RJSC within 30 days for a certificate of filing under section 379 of the Companies Act 1994.[4] Our guides to representative offices in Bangladesh and foreign company registration cover the establishment stage.

The section 18B report to Bangladesh Bank

Within 30 days of the investment approval, the office must notify Bangladesh Bank, through its bank, under section 18B of the Foreign Exchange Regulation Act 1947.[4] This is a reporting step rather than an approval, but missing it creates problems later: the AD will look for the report before processing outward remittances, and FEID will look for it when it checks them.

Remitting branch profits

Branches of foreign firms may remit profits abroad without prior approval from the central bank.[2] The application goes to the nominated AD with audited accounts of the Bangladesh business, the consolidated audited accounts of the head office, a year-wise head office reconciliation, tax documents, details of fixed asset additions and how they were funded, outstanding local borrowings and the government permission letter. The AD then sends the papers to FEID for post-facto checking within one month of the remittance, and the branch must notify FEID of its AD nomination in advance.[2]

Liaison offices and expatriate salaries

A liaison office earns no local income, so its money flows run mainly one way: from head office into Bangladesh to meet expenses. The approval questions it faces are about salaries and closure. Expatriate employees may remit 80 per cent of monthly salary after admissible deductions through an AD.[4] On closure, the office should reconcile inward remittances against expenditure before asking its AD to return any unspent balance, because that reconciliation is what the bank and FEID will test.

Bangladesh Bank approval — foreign company branch office meeting on remittances
Invest Bangladesh permits the office; Bangladesh Bank follows the money

How to apply for Bangladesh Bank approval through an authorised dealer

Every application follows the same route, whatever the transaction. The applicant prepares the file; the AD checks it against the circular, attests the documents and adds its recommendation; Bangladesh Bank decides; and the AD executes and reports.[2] The sequence below is the one that avoids returned files.

Step 01

Identify the transaction head

Find the paragraph of the current consolidated circular that governs the payment, transfer or guarantee, and confirm whether it is within AD authority.

Step 02

Check the right regulator

Confirm whether Invest Bangladesh, Bangladesh Bank, BSEC or another body must approve first, and in what order.

Step 03

Nominate one AD branch

Choose the bank branch that will carry the transaction and its later remittances, and notify FEID where the circular requires it.

Step 04

Build the evidence file

Assemble agreements, audited accounts, tax certificates, valuations, encashment certificates and board resolutions in the form the circular lists.

Step 05

Submit through the AD

Let the AD attest the papers and forward them with its recommendation; never write to Bangladesh Bank directly.

Step 06

Track the decision

Answer queries promptly and record the approval date, because most approvals lapse after 45 days.

Step 07

Execute and report

Complete the transaction within the approved terms and make sure the AD files the post-facto report on time.

Two practical points recur. First, nominate one AD branch for each regulated stream, such as dividends or loan repayments, and keep it, because the circulars tie many permissions to the bank through which the original inflow was received. Second, diary the 45-day validity of any approval: an expired approval has to be revalidated, and revalidation is not automatic.[2]

How to read BRPD, FEPD and FEID circulars

Most of the rules that bind banks and their customers day to day are not in any statute. They are in circulars, and a legal opinion on a Bangladesh Bank requirement is only as good as the circular it cites. Reading them well means knowing which department issued the instruction, which statute it rests on, and whether it is still in force.

Who issues what

The Banking Regulation and Policy Department (BRPD) issues prudential rules for banks, including loan classification and provisioning, and handles change-of-control filings for banks.[5] The Foreign Exchange Policy Department, which issues its consolidated circulars under the FEPD-1 designation, sets the rules on trade, remittances, loans and guarantees, while the Foreign Exchange Investment Department (FEID) handles foreign investment and share transfers.[1] [3] The Credit Information Bureau issues its own CIB circulars and circular letters, signed by its director.[6]

Prudential

Banking Regulation and Policy Department (BRPD)

Loan classification, provisioning, bank governance and change-of-control filings for banks.

Foreign exchange policy

Foreign Exchange Policy Department (FEPD)

Consolidated circulars on trade, remittances, loans, guarantees and accounts, issued under section 20(3).

Investment

Foreign Exchange Investment Department (FEID)

Share transfers, repatriation of sale proceeds and post-facto checks on dividends and branch profits.

Credit data

Credit Information Bureau (CIB)

Monthly loan reporting by every bank and finance company, and the CIB report lenders rely on.

Resolution

Bank Resolution Department

Administrators, transfers, bridge banks and mergers under the Bank Resolution Act 2026.

Investment authority

Invest Bangladesh

Office permissions, most foreign loans and royalty approvals, alongside Bangladesh Bank.

How circulars are numbered

Each circular carries the issuing department's code, a serial number that restarts each year, and a date: FEPD-1 Circular No. 32 of 2 September 2026, FEID Circular No. 01 of 8 March 2026 or BRPD Circular No. 15 of 2024 on loan classification.[1] [3] A "circular letter" is a shorter instrument that typically amends or clarifies an existing circular, as CIB Circular Letter No. 01 of 2026 did for CIB service charges.[6] Before 2026, foreign exchange circulars were numbered as FE Circulars, so FE Circular No. 34 of 2025 and FEPD-1 Circular No. 32 of 2026 are two editions of the same consolidated rulebook.[1]

Where circulars are published

Bangladesh Bank publishes circulars on its website, bb.org.bd, under the circulars section of its media room, organised by department, with each circular posted as a PDF whose file name combines the date and the department, which makes the archive searchable. Master circulars consolidate a subject; individual circulars amend it; and each consolidated foreign exchange circular states its own validity and the earlier instructions it repeals.[1] [2]

Tracking changes in practice

Compliance teams should keep a register of the circulars that govern each regulated activity, with the anniversary dates of the one-year consolidated circulars, and check the department pages at least monthly. Keep the original circulars on file, because a consolidated text that conflicts with a newly incorporated provision is read against the original.[1] Where a circular appears to exceed Bangladesh Bank's statutory power or conflicts with its parent Act, it can be challenged by writ in the High Court Division; our guide to banking litigation in Bangladesh covers how those challenges fare.

CIB circulars and the CIB report

The Credit Information Bureau is the part of Bangladesh Bank that turns a single bank's problem loan into a system-wide fact. It is the central register of borrowers from banks and finance companies. Every bank and finance company reports to it, and every lender reads from it before sanctioning, renewing or enhancing credit.

What lenders must report

Banks and finance companies must report monthly data on all loans to the CIB within 15 days of the following month. They may correct, exclude or add records and re-upload an error-free file within seven working days of the first upload. An institution that cannot submit error-free data must explain why on a prescribed form, and if the bureau is not satisfied it faces a penalty of up to Tk 5 lakh, deducted from its account at Bangladesh Bank, with disciplinary action against responsible officials.[7]

The CIB report in lending and fit and proper checks

For a borrower, the CIB report is the document that decides whether new credit is possible. It shows each reported facility, its classification and the borrower's links to guarantors and related companies. The same database is used in fit and proper screening of bank directors, because banks must report the liability status of significant shareholders and affiliated entities.[5] A borrower that believes its record is wrong should raise it with the reporting bank, because the database reflects what that bank uploads. Our guide for a loan defaulter in Bangladesh explains how listings are cleared or challenged.

CIB Circular Letter No. 01 of 2026

The most recent CIB instruction is administrative but strict. CIB Circular Letter No. 01 of 2026, issued on 23 July 2026 under Article 44(1) of the Bangladesh Bank Order 1972, moved the deadline for banks' applications for exemption from CIB service charges to the 10th of the following month, set a 10-day window for objections to charges already deducted, and gave a one-time window to 7 August 2026 for outstanding exemption claims up to 30 June 2026.[6] The remaining provisions of section 2 of CIB Circular No. 02 of 2011 continue in force.[6]

Private credit bureaus

The CIB's monopoly is ending. In September 2025 it issued letters of intent to five: Credit Info BD Credit Bureau, TransUnion Credit Bureau, bKash Credit Bureau, City Credit Bureau and First National Credit Bureau, chosen from 22 applications. Bureaus need Tk 10 crore paid-up capital, may have foreign investors, and will use CIB data with the borrower's permission.[8]

Bangladesh Bank approval — credit analyst checking a CIB report before lending
Every lender reads the CIB before it lends

Defaulter classification in 2025 and 2026

Classification is where BRPD circulars bite hardest, because a loan's category decides provisioning, CIB status and, in time, statutory defaulter status. Bangladesh Bank's November 2024 master circular on loan classification and provisioning, BRPD Circular No. 15 of 2024, tightened the rules to meet IMF conditions with effect from April 2025.[9]

The thresholds since April 2025

A loan is now substandard at three to six months overdue, doubtful at six to twelve months and bad or loss at twelve months or more, on a single schedule for all loan types. The longer tenures for cottage, micro, small and medium enterprise loans were cancelled. Provisioning rates were left unchanged at 20 per cent for substandard, 50 per cent for doubtful and 100 per cent for bad or loss loans.[9]

What it means for borrowers

The practical effect is less time. A borrower that once had nine months of grace before a loan became doubtful now has six, and an SME that relied on its longer schedule has lost it entirely. Rescheduling, restructuring and exit windows issued in 2025 and 2026 offer routes back, but they are separate circulars with their own deadlines. We track those in our guide for a loan defaulter in Bangladesh and the statutory defaulter and wilful defaulter regime in our guide to the Bank Company Act 1991.

Banking licence in Bangladesh: section 31 and new bank licences

A banking licence is the largest Bangladesh Bank approval of all. Section 31 of the Bank Company Act 1991 provides that no entity can carry on banking business without a licence from Bangladesh Bank.[5] The statute sets the conditions; the process and the capital figures come from Bangladesh Bank's practice and circulars. Our Bank Company Act guide analyses section 31 and the cancellation and review provisions in detail.

The licensing process

Sponsors first obtain name clearance and incorporate a public limited company with the RJSC. They then apply to Bangladesh Bank with the memorandum and articles, a feasibility study and financial projections, and a non-refundable fee of about Tk 10 lakh. Bangladesh Bank reviews the application in a non-public process that includes fit and proper checks on sponsors and management, and if satisfied grants the licence, after which the bank is scheduled under the Bangladesh Bank Order 1972.[5]

Capital and timing

Minimum paid-up capital for a new commercial bank is Tk 500 crore, to be placed under lien to Bangladesh Bank in liquid, unencumbered form. There is no statutory timeline, and the process typically takes 18 to 24 months or more.[5] A foreign bank opening a branch needs both investment authority approval and a Bangladesh Bank licence, while a foreign-owned subsidiary must meet the same capital and licensing requirements as a domestic bank.[5]

Change of control and sponsor shares

An existing bank's shares are also subject to Bangladesh Bank approval. Its prior permission is required for transactions that affect control, any person, company or family is capped at 10 per cent of share capital, and sponsors' shares cannot be transferred for three years without explicit permission.[5] The filing goes to BRPD with fit and proper documents, evidence of source of funds, the target board's resolution, Form 117 and, for unlisted shares, a valuation; a no-objection certificate is needed before registration.[5]

Digital banks in 2026

Digital banks are licensed as banks, not payment companies. On 24 September 2026 the Bangladesh Bank board, chaired by Governor Md Mostaqur Rahman, approved letters of intent for five proposed digital banks: DK Digital Bank, bKash Digital Bank, Nova Digital Bank, Boost Digital Bank and Kori Digital Bank, chosen from 12 second-round applicants.[10] Minimum paid-up capital is Tk 300 crore after an August 2025 revision. Digital banks may not have branches or over-the-counter services, issue physical cards, open letters of credit or lend to large or medium industries, and each must list within five years. A letter of intent is not a licence.[10] Our guide to the PSO and PSP licence covers payment licences.

Who approves what: common transactions in 2026
TransactionDecision-makerBangladesh Bank roleGoverning rule
Outward service or dividend paymentAD bank within limitsApproval above limits; post-facto checksFEPD-1 Circular No. 40 of 2026
Guarantee for a non-resident's obligationBangladesh BankPrior approval outside AD authorityFEPD-1 Circular No. 32 of 2026
Foreign loan for an industrial enterpriseInvest Bangladesh Scrutiny CommitteeApproves certain zone and finance company casesFEPD-1 Circular No. 32 of 2026
Share transfer to a non-residentAD bank at fair valueFEID approval above repatriation thresholdsFEID Circular No. 01 of 2026
Branch or liaison officeInvest BangladeshSection 18B report; branch profit checksFER Act 1947 and Circular No. 40
New bank or change of controlBangladesh BankLicence under section 31; BRPD approvalBank Company Act 1991

Banking sector reforms in Bangladesh, 2024 to 2026

The approvals described above sit inside a banking system under repair. Since August 2024 the reform agenda has moved through diagnosis, legislation and the first forced merger, and the elected government that took office in 2026 has continued parts of it while revising others. What follows is a neutral account of where each strand stands in October 2026.

The task force and the diagnosis

On 11 September 2024 Bangladesh Bank formed a six-member task force, including former deputy governor Muhammad A (Rumee) Ali and former World Bank lead economist Zahid Hussain, to assess the sector's financial condition, estimate distressed assets and review weak banks' loans, provision deficits, capital, asset values and liquidity.[11]

Asset quality reviews

Asset quality reviews followed. Ernst & Young and KPMG reviewed the first six banks, which were found to be in a dire state, with non-performing loans about four times higher than previously reported. In July 2025 eleven more banks were added, including Islami Bank Bangladesh, United Commercial Bank and Premier Bank, with Deloitte Malaysia reviewing IFIC, National Bank and AB Bank and the Asian Development Bank and World Bank providing funding.[12] The reviews cover classification, rescheduled loans, large-loan limits, major defaulters and accounting policies.[12]

The Bank Resolution Act 2026

The Bank Resolution Ordinance 2025 was re-enacted by Parliament as the Bank Resolution Bill 2026, passed by voice vote on 10 April 2026. It lets Bangladesh Bank suspend a weak bank's business, limit shareholder rights, appoint administrators, dissolve boards, transfer or merge a bank and use a bridge bank, and it creates a Bank Resolution Department and Resolution Fund. Individuals can be held personally liable, with penalties of up to Tk 50 lakh plus daily fines, while shareholders are compensated if resolution leaves them worse off than liquidation and depositors have priority.[13]

The September 2026 amendment

One addition proved contentious. Section 18A, inserted when the ordinance was re-enacted, let former shareholders of a bank in resolution apply to reacquire its shares, assets and liabilities. Parliament repealed it through the Bank Resolution (Amendment) Bill 2026 on 9 September 2026; the Finance Minister, Amir Khosru Mahmud Chowdhury, told the House that no applicant had met its conditions.[14]

Merger of weak banks: Sammilito Islami Bank

Five Shariah-based banks, Social Islami Bank, First Security Islami Bank, Union Bank, Global Islami Bank and EXIM Bank, were merged into Sammilito Islami Bank in 2025. Bangladesh Bank declared their share net asset value zero in November 2025 and classed them as non-viable. The planned paid-up capital is Tk 350 billion, of which the government has injected Tk 200 billion.[15] In May 2026 the bank was emerging from more than two months of stalemate, with managing director interviews under way and the buyback provision, later repealed, cited as a concern by the IMF.[15] Our banking law guide explains what the merger means for depositors and borrowers.

The Bank Company (Amendment) draft

The interim government's proposals to cut family directors to two and tenure to six years were not enacted. A revised draft reviewed on 20 September 2026 keeps up to three family members on a board, with the Financial Institutions Division initially favouring a nine-year tenure, caps independent directors at three, drops the proposal to remove a director whose associated company defaults, and may let Bangladesh Bank appoint an administrator without dissolving a board.[16] As of mid-October 2026 nothing was final: the draft must return to Bangladesh Bank and then go to Cabinet. Critics, including former governor Ahsan H Mansur, called it a retreat from reform.[16]

Bangladesh Bank approval — bank building representing banking sector reforms
Resolution, mergers and governance reform reshape the sector

Mistakes to avoid when seeking Bangladesh Bank approval

Applying to the wrong regulator. Office permissions, royalty approvals and most foreign loans now sit with Invest Bangladesh; Bangladesh Bank handles the money flows that follow.[4] Filing with the wrong body costs weeks.

Approaching Bangladesh Bank directly. Applications for Bangladesh Bank approval must come through the AD with its recommendation; a customer letter sent straight to the central bank is not an application.[2]

Assuming a share transfer still needs approval, or that it never does. Since March 2026 fair-value transfers to non-residents are approval-free, but repatriation above the thresholds still goes to FEID, and an undervalued or overvalued price can be reassessed.[3]

Missing the section 18B report. A branch that never reported its establishment to Bangladesh Bank will struggle when it first tries to remit profits.[4]

Relying on an expired circular. Consolidated foreign exchange circulars last one year and are amended in between; cite the edition in force on the transaction date.[1]

Ignoring the CIB until a facility is refused. Check the group's CIB position before a renewal, a guarantee or a director appointment, not after.

What to watch for the rest of 2026

Four developments will shape Bangladesh Bank approval practice into 2027. First, the consolidated foreign exchange circulars on loans and guarantees and on outward remittances, both issued in September 2026, fall due for reissue in September 2027, and each round has changed limits.[1] [2] Second, the Bank Company (Amendment) draft must still pass Cabinet and Parliament.[16] Third, the five digital banks and the private credit bureaus must convert letters of intent into licences.[8] [10] Fourth, the integration of Sammilito Islami Bank will test the resolution framework.[15]

TRW's banking and finance practice prepares Bangladesh Bank and Invest Bangladesh applications, advises on circular interpretation and share transfer valuations, and acts for sponsors on bank licensing and change of control. Our branch and foreign company establishment team handles office permissions and remittances, and our banking and finance litigation team acts in CIB and regulatory disputes. For the regulatory overview, see our guide to banking regulations in Bangladesh in 2026.

Frequently asked questions

When is Bangladesh Bank approval required?

When a foreign exchange transaction falls outside the general permissions that authorised dealer banks can apply under the consolidated circulars, and for prudential matters such as banking licences and changes of control in banks. The application always goes through the bank.[2] [5]

Can I apply to Bangladesh Bank directly?

No. Requests for prior approval must be submitted through an authorised dealer, not by the customer directly. An approval is generally valid for 45 days unless it states otherwise or is revalidated.[2]

Does a share transfer to a foreign investor need Bangladesh Bank approval?

Not if it is made at fair value in an unlisted company, under FEID Circular No. 01 of 2026. A valuation report is needed above Tk 10 million, and the AD must report the transfer to FEID within 14 days.[3]

Who approves a branch office in Bangladesh?

Invest Bangladesh grants the permission through its One-Stop Service. The office must then notify Bangladesh Bank through its bank within 30 days under section 18B of the Foreign Exchange Regulation Act 1947.[4]

Can a branch remit profits without Bangladesh Bank approval?

Yes. The nominated AD remits branch profits on audited accounts and tax documents, then sends the papers to FEID for post-facto checking within one month.[2]

What is a BRPD circular?

An instruction from Bangladesh Bank's Banking Regulation and Policy Department, usually on prudential matters such as loan classification, provisioning and bank governance. It is cited by department, number, year and date, such as BRPD Circular No. 15 of 2024.[5] [9]

What is the CIB in Bangladesh?

The central credit database run by Bangladesh Bank's Credit Information Bureau. Lenders report monthly data on all loans to it within 15 days of the following month and check it before lending.[7]

When does a loan become classified in Bangladesh?

Since April 2025, at three months overdue as substandard, six months as doubtful and twelve months as bad or loss, for all loan types.[9]

How much capital does a new bank need?

Tk 500 crore paid-up capital for a commercial bank, and Tk 300 crore for a digital bank. Licensing typically takes 18 to 24 months or more.[5] [10]

Has the Bank Company Act been amended in 2026?

Not as of October 2026. A revised draft reviewed on 20 September 2026 must return to Bangladesh Bank and then go to Cabinet. The separate Bank Resolution Act 2026 was passed on 10 April 2026 and amended on 9 September 2026.[16] [13] [14]

Source register

Primary legal and regulatory sources

Materials checked on 20 October 2026. Confirm the current official text before relying on any provision.

  1. Bangladesh Bank, FEPD-1 Circular No. 32 (2 September 2026) — Consolidated circular on loans, overdrafts, guarantees and external borrowings
  2. Bangladesh Bank, FEPD-1 Circular No. 40 (30 September 2026) — Consolidated circular on outward current account remittances
  3. Bangladesh Bank, FEID Circular No. 01 (8 March 2026) — Master circular on transfer of shares and repatriation of sale proceeds
  4. Invest Bangladesh — Frequently asked questions: branch, liaison and project offices, foreign loans and royalty
  5. Chambers Global Practice Guides — Banking Regulation 2026: Bangladesh
  6. BSS, 23 July 2026 — BB extends CIB service charge exemption deadline, tightens compliance rules
  7. The Financial Express, 5 March 2025 — Update CIB on all loans duly or pay penalty
  8. The Daily Star, 3 September 2025 — City Bank, bKash, TransUnion get primary nod for private credit bureaus
  9. The Daily Star, 27 November 2024 — BB tightens loan classification rules to meet IMF conditions
  10. The Business Standard, 25 September 2026 — 5 digital banks, including bKash and Robi-backed ventures, get BB approval
  11. Dhaka Tribune, 11 September 2024 — BB forms taskforce to reform banking sector
  12. The Daily Star, 20 August 2025 — Three more banks face asset quality review
  13. The Business Standard, 10 April 2026 — Bank Resolution Bill passed in parliament
  14. The Financial Express, 9 September 2026 — Parliament scraps controversial bank ownership provision
  15. The Financial Express, 11 May 2026 — Sammilito Islami Bank sees fresh momentum
  16. Prothom Alo, 15 October 2026 — New draft law retains scope for family control of banks

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TRW prepares Bangladesh Bank and Invest Bangladesh applications, advises on circulars, share transfer valuations, branch remittances, bank licensing and CIB disputes. Explore our banking and finance practice or contact TRW to discuss your transaction.

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