Blockchain Law in Bangladesh 2026: Crypto Status, Smart Contracts, Tokenisation and Technology Transfer

Blockchain law Bangladesh: the 2026 legal framework

Blockchain law Bangladesh businesses must work with in 2026 is not found in a single statute. It is assembled from a foreign exchange law of 1947, Bangladesh Bank circulars that prohibit dealing in virtual assets, money laundering and anti-terrorism legislation, the new Cyber Security Act 2026, a nineteenth-century Contract Act, an Evidence Act modernised for digital records in 2022, securities law that predates the internet, and a national strategy that has never been turned into legislation. The result is a sharp line: distributed ledger technology is lawful and actively encouraged, while cryptocurrency and other virtual assets remain outside the law.

This guide maps that line for founders, banks, software houses, investors and in-house counsel. It covers the status of crypto and virtual assets, the National Blockchain Strategy 2020, smart contracts and on-chain evidence, tokenisation and the Bangladesh Securities and Exchange Commission (BSEC), and the cyber and data rules that shape blockchain design. Because most blockchain capability reaches Bangladesh through licences from abroad, it also covers technology transfer Bangladesh rules in full: licensing agreements, Invest Bangladesh Authority endorsement, royalty and technical fee caps under the 30 September 2026 consolidated circular, withholding tax and VAT, and protection of the intellectual property being transferred.

Summary: Bangladesh separates the technology from the asset. Building and using permissioned blockchain systems is lawful, and smart contracts can be enforced through the Contract Act 1872, the ICT Act 2006 and the 2022 Evidence Act amendments. Buying, selling, holding or facilitating cryptocurrency and other virtual assets is treated as a breach of the Foreign Exchange Regulation Act 1947 under Bangladesh Bank's FE Circular No. 24 of 2022, with exposure under money laundering and cyber security law. Licensing blockchain or other technology from abroad is a regulated technology transfer: fees above set caps need Invest Bangladesh Authority approval, and every remittance must clear tax and VAT.

Key point: Bangladesh Bank has directed every individual, entity and institution in Bangladesh to refrain from dealing in virtual assets and from facilitating their exchange, transfer or trading. A blockchain product that needs users or the company to acquire tokens, including gas fees on a public chain, will usually breach that direction; a permissioned ledger without a native token will not.

At a glance

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Table of Contents

What blockchain law Bangladesh covers in 2026

A blockchain is a shared ledger in which records are grouped into blocks, chained together cryptographically and validated by a network of nodes rather than a single administrator. The law does not regulate that architecture as such. It regulates what the ledger records and what moves across it: money, foreign exchange, securities, personal data, evidence and contractual promises. Blockchain law Bangladesh practitioners apply is therefore the sum of the rules governing each of those things, read against the technical design of the system in question.

Five bodies of law do most of the work: foreign exchange and banking regulation (can a token be bought or used to pay?), criminal statutes on laundering, terrorism and cyber offences, contract and evidence law (do smart contracts bind, and how are on-chain records proved?), securities law (is the token an investment product?), and the investment and tax rules that govern licensing blockchain technology from overseas.

Why there is no single blockchain statute

Bangladesh chose policy before legislation. The ICT Division published a National Blockchain Strategy in March 2020 that set a goal of blockchain-friendly legal and policy frameworks, but it did not create rights or obligations.[5] Regulators have filled the gap with prohibitions on virtual assets rather than permissive licensing regimes. A 2026 Legal 500 guide to Bangladesh banking law expects the restrictive position to continue over the following twelve to eighteen months, with any opening likely to come through controlled, regulator-led frameworks.[4]

Cryptocurrency and virtual assets: the legal position in 2026

The core of blockchain law Bangladesh enforces today is a prohibition, not a licensing regime. There is no exchange, custody or service-provider licence. The prohibition was built in stages by Bangladesh Bank and rests on the Foreign Exchange Regulation Act 1947 (FERA), with the money laundering and anti-terrorism statutes in support.

From early warnings to a formal prohibition

Bangladesh Bank issued cautionary notices on virtual currencies in 2014 and 2017.[4] The position hardened after a period of confusion in 2021, when a central bank letter to the Criminal Investigation Department in May had suggested that holding cryptocurrency was not a crime. On 29 July 2021 Bangladesh Bank clarified that transacting in and promoting cryptocurrencies such as Bitcoin and Ethereum were illegal, stated that they were not legal tender, and identified offences under FERA, the Anti-Terrorism Act 2009 and the Money Laundering Prevention Act 2012.[3]

FE Circular No. 24 of 2022: what it prohibits

The governing instrument is FE Circular No. 24, issued by the Foreign Exchange Policy Department on 15 September 2022 under section 20(3) of FERA. It records that virtual currencies are not recognised as foreign exchange or as an approved form of transaction or investment, have no embedded financial claim, are not issued or guaranteed by any sovereign and are highly volatile.[2] Its operative provisions are blunt:

• transactions in, from or to Bangladesh to obtain virtual assets or virtual currencies are not permitted;[2]
• providing any facilitation for businesses or activities involving the exchange, transfer or trading of virtual assets is not permitted;[2]
• retaining export proceeds abroad in any form, including by buying virtual assets or keeping accounts in cryptocurrency, is a contravention of FERA;[2] and
• all individuals, entities and institutions operating in Bangladesh must refrain from dealing in virtual assets or facilitating such dealing.[2]

The circular uses the Financial Action Task Force concept of a virtual asset, which is wide enough to cover stablecoins, utility tokens and most non-fungible tokens used for payment or investment. Banks were then told, through BRPD Circular Letter No. 40 of 12 October 2022, to monitor and prevent transactions linked to virtual asset service providers.[4]

The FERA basis and the penalty

FE Circular No. 24 characterises a violation as a breach of section 5(1)(e) of FERA, which bars a person in or resident in Bangladesh from making a payment, without permission, in connection with acquiring property or a right to payment outside Bangladesh.[1] [2] Section 23(1) makes contravention punishable with imprisonment of up to seven years, a fine or both, and allows the tribunal to confiscate the property involved; the maximum term was raised from four years in 2015.[1] Our guide to foreign exchange regulations in Bangladesh explains how FERA and the consolidated circulars operate more generally.

Money laundering, terrorist financing and cyber offences

Crypto rarely appears alone in a prosecution. Investigators treat virtual assets as a channel for laundering, hundi and fraud, and Bangladesh Bank has expressly linked them to offences under the Money Laundering Prevention Act 2012 and the Anti-Terrorism Act 2009.[3] Our guide to the anti-money laundering law of Bangladesh covers the predicate offences, penalties and reporting duties that follow.

The Cyber Security Act 2026, Act No. 81 of 2026 dated 10 April 2026, adds a further layer. Section 21 makes cyber forgery an offence punishable with up to two years' imprisonment, a fine of up to Tk 20 lakh or both, and its explanation includes producing digital money, electronic currency or cryptocurrency without right or in excess of authority.[6] The definitions of cyberspace and related terms also expressly mention blockchain.[6] Our cyber law guide explains how the Cyber Tribunal, investigation timelines and bail work.

What changed in 2025 and 2026

Nothing that relaxes the prohibition. Neither the interim government nor the elected government that took office after the February 2026 elections has issued a virtual asset statute, a licensing framework or a Bangladesh Bank circular withdrawing FE Circular No. 24. Bangladesh Bank's position remains prohibitive, cryptoassets are not deposits or protected funds, and banks may not hold or deal in them.[4] The 2026 change that matters is indirect: a new cyber security statute that names cryptocurrency. For businesses, the practical message of blockchain law Bangladesh in 2026 is unchanged: build without tokens, or build offshore for offshore users only, with advice.

Blockchain without cryptocurrency: what is lawful

The prohibition is aimed at virtual assets, not distributed ledgers. Nothing in FERA, FE Circular No. 24 or the Cyber Security Act 2026 prevents a bank, manufacturer, logistics company or government agency from operating a ledger that records documents, title, provenance or contractual events, provided it does not create or move a virtual asset.

Permissioned ledgers and enterprise use

Permissioned networks, in which known participants run the nodes and there is no native coin, sit comfortably within the law. Bangladesh's first blockchain-enabled letter of credit was executed in August 2020 on Contour, a trade network built on R3's Corda platform, with Standard Chartered acting as issuing and advising bank for a transaction applied for by Viyellatex.[12] Similar architecture suits supply-chain traceability, certificate verification, land and registry pilots, insurance claims and inter-bank reconciliation, all of which the National Blockchain Strategy identifies as priority domains.[5]

Public chains, gas fees and the foreign exchange problem

Public blockchains create a difficulty that is easy to miss. Writing to Ethereum or a similar network requires paying transaction fees in the network's native token. A Bangladeshi company that buys that token, or pays a provider to do so on its behalf, is arguably obtaining a virtual asset through a transaction from Bangladesh, which FE Circular No. 24 does not permit.[2] The same applies to staking, minting NFTs for customers and integrating crypto wallets into an app. Before choosing a public chain, a Bangladesh-facing business should confirm that no person in Bangladesh will need to acquire, hold or transfer a token at any stage.

Developers, freelancers and offshore structures

Bangladeshi developers often work for foreign Web3 projects. Accepting payment in cryptocurrency is the high-risk point: FE Circular No. 24 treats keeping export proceeds abroad in cryptocurrency as a contravention of FERA.[2] Software houses should invoice in fiat through an authorised dealer bank. Founders who set up an offshore entity to run a token project should assume that Bangladesh-resident shareholders, staff and users remain subject to Bangladeshi law, and that capital sent abroad to fund that entity needs its own approval.

The National Blockchain Strategy 2020

The ICT Division's National Blockchain Strategy, subtitled "Pathway to be a Blockchain-enabled Nation", was published in March 2020.[5] It remains the government's only dedicated statement on blockchain and the starting point for any discussion of blockchain law Bangladesh policy-makers might adopt.

A "curious-but-cautious" approach

The strategy acknowledges that Bangladesh had explicitly banned Bitcoin and other cryptocurrencies, but also observes that a ban prevents local software firms from exploring a lucrative domain. It recommends a "curious-but-cautious" approach, with permissioned systems for government use and further study of public blockchains.[5]

Legal and policy goals

Among its short-term goals is developing blockchain-friendly legal and policy frameworks. Its action points assign a blockchain regulatory framework to the Cabinet Division and the ICT Division, a policy framework to the ICT Division, and studies on opening up cryptocurrency in a restricted fashion without enabling criminal activity. Mid-term goals, framed for achievement by 2025, included a national blockchain platform and integrating at least half of relevant government services with it.[5]

Where the strategy stands

The strategy is policy, not law, and its 2025 milestones have passed without a blockchain statute or regulatory framework. Its value today is interpretive: it confirms that the state distinguishes ledger technology from virtual assets, and it gives procurement teams and regulators a reference point when assessing a blockchain proposal. Projects that align with its priority domains, such as identity, land records, judicial evidence and supply chains, are easier to explain to government counterparties.[5]

Smart contracts under Bangladeshi law

A smart contract is code deployed on a ledger that executes automatically when defined conditions are met. Whether it is a legal contract depends not on the code but on whether the parties' arrangement satisfies the Contract Act 1872, and whether the records it produces can be proved in court. Blockchain law Bangladesh courts would apply here is ordinary contract and evidence law, adapted by the ICT Act 2006 and the 2022 Evidence Act amendments.

Is a smart contract a contract?

Section 10 of the Contract Act makes an agreement a contract if it is made by the free consent of competent parties, for a lawful consideration and with a lawful object.[7] Code can evidence offer and acceptance, and clicking to deploy or sign a transaction can show consent. The decisive question in Bangladesh is usually lawfulness. Section 23 makes a consideration or object unlawful if it is forbidden by law or would defeat the provisions of any law.[7] Because dealing in virtual assets breaches FERA, a smart contract whose consideration is paid in cryptocurrency, or whose object is a token trade, is exposed to being void as well as illegal.

Electronic records and signatures under the ICT Act 2006

The ICT Act 2006 recognises electronic records where another law requires writing, if they remain accessible (section 6), and electronic signatures applied in the prescribed manner (section 7). Section 9 permits electronic retention, and sections 13 to 15 deal with attribution, acknowledgement and the time and place of dispatch and receipt. Section 3 gives the Act overriding effect.[8] A well-designed smart contract system can therefore meet formal requirements in most commercial contexts.

Proving on-chain records in court

The Evidence (Amendment) Act 2022, Act No. 20 of 2022, brought digital records into the definition of "document" and inserted sections 65A and 65B, which allow digital records to be proved through computer output, without the original, if conditions on regular use and proper operation are certified by a responsible official.[9]

New presumptions follow: section 85A presumes that a digital agreement bearing the parties' digital signatures was concluded by them, section 85B presumes that a secure digital record has not been altered, and section 88A presumes that a received digital message matches what was sent, but not who sent it.[9]

For blockchain evidence, the practical lesson is to plan proof at the design stage. Node operators should keep logs, hash records and system documentation that let a responsible official give the section 65B certificate, and parties should use digital signatures that attract the statutory presumptions.

Drafting a smart contract that a court will enforce

Code cannot carry all the legal terms. The robust approach is a written master agreement, signed by the parties, that incorporates the code by reference and governs when they conflict. It should state the governing law and forum, describe each automated function in plain language, allocate risk for bugs, oracle failures and network outages, set an override or pause mechanism, and provide for reversal or compensation when code executes wrongly. Our guides to contract law in Bangladesh and breach of contract explain the remedies a court can grant when automation goes wrong.

Tokenisation, securities and the BSEC

Tokenisation means representing an asset or right, such as a share, bond, receivable or interest in property, as a digital token. Under blockchain law Bangladesh regulators apply, the asset's existing legal regime continues to govern it, and the token adds a second question: is it a virtual asset that Bangladesh Bank prohibits, a security that the BSEC regulates, or both?

When a token is a security

Section 2(l) of the Securities and Exchange Ordinance 1969 defines securities widely. The definition covers shares, scrip, debentures, bonds and notes, and also any "investment contract", derivatives and "in general, any interest or instrument commonly known as a security", together with any certificate of interest or participation in them.[10] A token that gives holders a share of profits, revenue or asset value is very likely to fall within that definition.

Section 2A then requires the BSEC's consent before any issuer, whether incorporated in Bangladesh or not, makes an issue of capital in Bangladesh or a public offer of securities for sale in Bangladesh, and before a Bangladeshi company issues capital outside Bangladesh.[10] An unapproved token offering to Bangladeshi investors is therefore likely to be an unauthorised public offer, separate from any foreign exchange breach. Our guide to BSEC compliance covers the consent and disclosure regime.

Real-world asset tokenisation

Tokenising land, receivables or commodities does not change how title passes. Immovable property still transfers by registered instrument, receivables by assignment, and goods by delivery or documents of title. A token recorded on a ledger is at most evidence of an entitlement under a contract, and unless the underlying legal transfer is completed, the token holder may have only a personal claim against the issuer. Any token that is freely transferable and paid for in, or exchangeable into, a virtual asset meets the FE Circular No. 24 problem as well.

Sandboxes and the regulatory perimeter

There is no BSEC rulebook for tokenised securities and no token sandbox. Bangladesh Bank's Regulatory FinTech Facilitation Office, introduced in 2019, can support case-by-case pilot testing of fintech propositions, but it is a supervisory tool rather than an alternative licence.[4] A tokenisation project that touches payments must also clear the Payment and Settlement Systems Act 2024 perimeter discussed in our technology law guide. The realistic route today is a permissioned ledger used as back-office infrastructure for conventional, BSEC-approved instruments, with settlement in taka through regulated channels.

Data protection and cyber security in blockchain design

Immutability, the feature that makes blockchains attractive, conflicts with data protection law. The Personal Data Protection Act 2026 gives individuals rights to correction and objection that a permanent public ledger cannot easily honour. The standard engineering response is to keep personal data off-chain, write only hashes or pseudonymous references to the ledger, and design deletion of the off-chain record so that the on-chain hash becomes meaningless. Our guide to Bangladesh data protection law in 2026 covers the lawful bases, data subject rights and cross-border transfer rules.

Node operators and platform providers also fall within the Cyber Security Act 2026, whose definition of cyberspace expressly includes blockchain computing.[6] Unauthorised access to a node or malicious code in a smart contract can engage its offences, so incident plans should treat a ledger compromise as a cyber incident and preserve evidence in a form the 2022 Evidence Act accepts.

Technology transfer Bangladesh rules for licensing blockchain and other technology

Most blockchain systems used in Bangladesh are licensed from foreign developers, platform owners or group companies, so technology transfer Bangladesh rules are as much a part of blockchain law Bangladesh practice as the crypto prohibition. The same rules govern a pharmaceutical formulation licence, a process transfer, a software platform licence and a franchise, combining investment-authority approval, remittance controls, tax and VAT at source, and intellectual property registration.

What counts as technology transfer

The Invest Bangladesh Authority guidelines on outward remittances, first issued by BIDA in 2020 and circulated on 3 March 2021, deal with four types of payment: royalty, technical knowledge or technical know-how fees, technical assistance fees and franchise fees.[11] In broad terms, royalty pays for the use of a patent, brand name or similar right, know-how fees for transferred knowledge, technical assistance fees for help in applying it, and franchise fees for the right to operate under another's system.[11] Classification matters, because each payment type carries different caps, documents and withholding rates.

Approval under the Invest Bangladesh Act 2026

The Invest Bangladesh Act 2026 replaced BIDA and BEZA with the Invest Bangladesh Authority, and Bangladesh Bank's circulars now refer to the Authority in their place. Section 27 of the Act requires approved industrial enterprises to apply to the Authority, in the prescribed manner, for payment of royalty, technical knowledge or assistance fees and franchise fees to foreign persons or institutes, and Bangladesh Bank's 30 September 2026 consolidated circular confirms that private sector industrial enterprises need the Authority's approval for these remittances.[11] Our guide to investment approvals in Bangladesh covers registration with the Authority.

Under the guidelines, a contract must be submitted for endorsement immediately after signing and before any remittance. The designated official signs and seals every page and issues a letter stating the fee titles, limits, timeframes, conditions and payment schedule; the Authority may require revisions first. One endorsement covers multiple remittances within the endorsed schedule, but any later change to the contract needs re-endorsement.[11]

Remittance caps under the 30 September 2026 consolidated circular

FEPD-1 Circular No. 40 of 30 September 2026 consolidates the rules on outward current account remittances, is valid for one year and incorporates the Authority's guidelines.[11] Schedule 1 to those guidelines sets the amounts that may be remitted on an endorsed contract without the Authority's approval:

• Projects under implementation: royalty, technical know-how and technical assistance fees up to 6% of the accumulated C&F value of imported machinery before commercial operation.[11]
• Projects in commercial operation: up to 6% of the previous year's sales, excluding VAT, as declared in the income tax return.[11]
• Franchise fees: fees above USD 0.1 million are remitted in instalments of 50%, 30% and 20% over three years.[11]
• Above the cap: prior approval is required, even if the contract has been endorsed, and is granted for proposals with significant economic impact, employment, advanced technology transfer or skills development.[11]

The no-approval route applies only after the service has been delivered and against a service completion certificate from the foreign beneficiary. The authorised dealer bank must be the one nominated by the remitter, must confirm that taxes, VAT and other levies have been deducted and paid, and sends the file to the Authority for post-facto verification.[11]

Advance payments

Advance fees always need the Authority's prior approval. Technical know-how or assistance fees of up to USD 10,000 per agreement may be advanced once a year; larger advances follow the endorsed contract and must be backed by a bank guarantee, affidavit or similar security.[11] Advances must later be adjusted against the 6% headroom, but the guidelines refer to adjustment within two years of commercial operation in one paragraph and within one year in Schedule 1, so the adjustment timetable should be fixed with the Authority when approval is sought.[11]

Economic zones and Hi-Tech Parks

Enterprises in the Export Processing Areas of the Invest Bangladesh Authority (formerly BEZA) and in Hi-Tech Parks may remit royalty, technical know-how and assistance fees from their foreign currency accounts without prior permission up to 6% of imported machinery cost for new projects or 6% of the previous year's sales for ongoing concerns. Enterprises in Domestic Processing Areas and Hi-Tech Parks without foreign currency income may remit within the same limits from taka accounts. Anything above the limits, and other similar expenses of any amount, needs prior approval from the Authority or the Bangladesh Hi-Tech Park Authority.[11]

Software, SaaS and cloud fees are not royalties

Circular No. 40 treats several technology payments separately. Banks may remit software maintenance and support fees and usage fees for cloud services, IT infrastructure and remote applications against a legitimate licence, a valid agreement, invoices and an undertaking to repatriate funds if services are not received.[11]

Training and consultancy costs may be remitted up to 1% of the previous year's sales or USD 100,000, whichever is higher.[11] IT and software firms recommended by BASIS have a USD 40,000 annual facility for registration, hosting and similar fees, but this facility expressly does not cover royalty, technical fee or franchise payments.[11] Structuring a blockchain-as-a-service arrangement as a genuine service subscription rather than a technology licence can therefore change which rules apply.

The table below compares the main routes. On a phone, scroll it sideways.

Withholding tax and VAT on royalties and technical fees

Tax must be settled before money leaves Bangladesh. Under the Income Tax Act 2023, payments to non-residents for royalties, licence fees and intangibles attract withholding at 20%, and technical services, know-how or assistance fees attract 20% for individuals and 10% for other recipients.[13] Double taxation agreements commonly cap withholding on royalties at 10%, including the treaties with China, Germany, Japan, Singapore, the United Kingdom and the United States, but relief must be claimed in the prescribed way.[13] Our guide to withholding tax in Bangladesh explains treaty certificates and grossing up.

Imported services, which in practice include most licence and technical services from abroad, carry 15% VAT on a reverse-charge basis. The importer owes the VAT, and the bank remitting the payment abroad deposits it through a treasury challan that serves as the tax invoice and supports input tax credit where available.[14] Contracts should say clearly whether fees are gross or net of Bangladeshi tax and VAT, because a "net" clause makes the local company bear both.

Transfer pricing and value addition

The guidelines direct the Authority to assess proposals by their value addition and to discourage transactions with little value addition, transactions not at arm's length and rudimentary arrangements.[11] Intra-group royalties face the same scrutiny from the National Board of Revenue. Keep a benchmarking file showing what the licensee receives and why the rate is commercial. Our guide to transfer pricing in Bangladesh covers documentation and audits.

Protecting the intellectual property being transferred

A licence is only as strong as the rights behind it. Patents and utility models are registered under the Bangladesh Patent Act 2023 and designs under the Design Act 2023; our guide to patent registration in Bangladesh explains recordal of licences and restrictive terms. A trademark licensee should be recorded as a registered user under the Trademarks Act 2009, and software, including smart contract code, is protected under the Copyright Act 2023.

Know-how that is not patented is protected only by contract, so confidentiality, access controls and post-termination restrictions carry the weight. Our guide to intellectual property law in Bangladesh covers enforcement.

Key terms in a technology transfer agreement

The guidelines require the endorsed contract to define the scope of services, the payment amount and its basis, the payment schedule and other conditions, and remittances must match those terms.[11] Beyond that, a well-drafted technology transfer Bangladesh licence should cover the licensed rights and field of use, territory, exclusivity, improvements and grant-backs, quality control, local regulatory licences, data handling, audit rights, the fee formula tied to declared sales, tax gross-up, termination and transition, and dispute resolution. Our joint ventures and strategic alliances practice drafts and negotiates these agreements.

Blockchain law Bangladesh compliance: step by step

Whether the project is a permissioned ledger built in-house or a platform licensed from abroad, the same sequence avoids most of the problems we see under blockchain law Bangladesh regulators enforce.

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Who regulates blockchain and technology transfer

No single regulator owns blockchain. Responsibility follows the asset, the payment or the data involved.

Common mistakes to avoid

• Assuming "utility" tokens are outside the ban: FE Circular No. 24 uses a wide virtual asset concept and prohibits facilitation as well as dealing.[2]
• Choosing a public chain without a gas-fee plan: any step that requires a Bangladesh resident to acquire a token reintroduces the prohibition.
• Accepting crypto for software exports: holding export proceeds abroad in cryptocurrency is a FERA contravention.[2]
• Relying on code alone: without a signed master agreement, governing law and an error mechanism, a smart contract dispute becomes a dispute about what the parties meant.
• Remitting before endorsement: the contract must be endorsed by the Invest Bangladesh Authority before the first royalty or technical fee leaves the country.[11]
• Mislabelling payments: calling a royalty a service fee to avoid the cap invites refusal at the bank and penalties on post-facto verification.[11]
• Ignoring VAT on imported services: the 15% reverse charge applies even when the licensor is in a treaty country.[14]
• Putting personal data on-chain: immutability makes correction and erasure requests impossible to honour.

Blockchain law Bangladesh: what to watch in 2026 and 2027

Four developments will shape the next year. First, Circular No. 40 expires on 30 September 2027, and each annual reissue has brought substantive change to remittance rules.[11] Second, the Invest Bangladesh Authority is still bedding in; revised guidelines replacing the 2020 BIDA text would directly affect royalty caps and procedure. Third, any shift on virtual assets is likely to start with a regulator-led sandbox or a central bank digital currency study rather than open crypto trading.[4] Fourth, enforcement under the Cyber Security Act 2026 will show how widely section 21's reference to cryptocurrency is read.[6]

For any blockchain build, token proposal or technology licence, the earliest decisions carry the most weight: the ledger design, the payment flows, the contract structure and the approvals sequence. Our corporate and commercial advisory practice and banking and finance practice advise on both sides of that line. Contact TRW to discuss your project.

Frequently asked questions

Is cryptocurrency legal in Bangladesh in 2026?

No. Bangladesh Bank's FE Circular No. 24 of 15 September 2022 states that virtual assets are not permitted, bars transactions in, from or to Bangladesh to obtain them, and directs everyone in Bangladesh to refrain from dealing in or facilitating them. No 2025 or 2026 instrument has relaxed that position.[2] [4]

What is the penalty for dealing in crypto in Bangladesh?

Bangladesh Bank treats it as a breach of section 5(1)(e) of the Foreign Exchange Regulation Act 1947, punishable under section 23(1) with up to seven years' imprisonment, a fine or both, and confiscation. Money laundering, anti-terrorism and cyber security offences may also apply.[1] [2] [3]

Is blockchain technology itself legal in Bangladesh?

Yes. The prohibition targets virtual assets, not distributed ledgers. The National Blockchain Strategy 2020 promotes blockchain for government and private services, and permissioned ledgers without a native token are widely usable.[5]

Are smart contracts enforceable in Bangladesh?

They can be, if the arrangement satisfies section 10 of the Contract Act 1872 and has a lawful object and consideration. A smart contract paid in cryptocurrency risks being void under section 23. Electronic records and signatures are recognised by the ICT Act 2006.[7] [8]

How are blockchain records proved in a Bangladeshi court?

Through sections 65A and 65B of the Evidence Act 1872, inserted in 2022, which allow computer output to be admitted with a certificate from a responsible official. Presumptions under sections 85A, 85B and 88A support digitally signed agreements, secure records and received messages.[9]

Does the BSEC regulate tokens?

There is no token-specific BSEC regime, but a token representing shares, debt or an investment contract is a security under section 2(l) of the Securities and Exchange Ordinance 1969, and section 2A requires BSEC consent for an issue of capital or public offer in Bangladesh.[10]

How much royalty can be remitted from Bangladesh without approval?

On a contract endorsed by the Invest Bangladesh Authority, royalty, technical know-how and technical assistance fees up to 6% of the previous year's sales (excluding VAT), or 6% of imported machinery value for projects under implementation. Anything above needs the Authority's prior approval.[11]

Do technology transfer agreements need government approval?

Royalty, technical fee and franchise agreements must be endorsed by the Invest Bangladesh Authority before any remittance, and section 27 of the Invest Bangladesh Act 2026 requires approved industrial enterprises to apply to the Authority for these payments.[11]

What tax applies to royalties paid abroad?

Withholding tax at 20% on royalties to non-residents, and 20% or 10% on technical fees depending on the recipient, subject to treaty caps that are often 10%. Imported services also carry 15% reverse-charge VAT, deposited by the remitting bank.[13] [14]

Can a Bangladeshi freelancer be paid in cryptocurrency?

It is high risk. FE Circular No. 24 treats keeping export proceeds abroad in cryptocurrency as a contravention of the Foreign Exchange Regulation Act 1947. Invoice in fiat currency and receive payment through an authorised dealer bank.[2]