TRW Insight / Bangladesh
Bangladesh has no framework climate act. One finance statute, a 2009 strategy, an adaptation plan to 2050 and a Paris Agreement pledge for 2035 do the work, and the 2025 to 2026 reforms of the Climate Change Trust have changed how its money is spent.
Climate change law Bangladesh has built: the 2026 framework
Climate change law Bangladesh has built is not a single code. It is a layered system: one dedicated statute, the Climate Change Trust Act 2010, which created a statutory trust and a fund paid for from the national budget; a strategy, the Bangladesh Climate Change Strategy and Action Plan 2009, which that Act still names as the basis for every funded project; a National Adaptation Plan running to 2050; and a third nationally determined contribution submitted under the Paris Agreement in September 2025. Around that core sit the climate budget, an emerging carbon market framework, the international loss and damage fund and a small but growing body of rights-based litigation.
This guide explains how those layers fit together in October 2026 and what they require in practice. It covers the Trust Act section by section, the status of the BCCSAP and the Mujib Climate Prosperity Plan, Bangladesh's obligations under the Paris Agreement and NDC 3.0, the National Adaptation Plan, climate finance and carbon markets, loss and damage, climate litigation, and the 2025 to 2026 governance reforms that followed findings of large-scale losses from the Trust Fund. General environmental regulation, environmental clearance and renewable energy licensing are covered in companion TRW guides, and are linked rather than repeated here.

Summary: Climate change law Bangladesh relies mainly on policy instruments backed by one finance statute. The Climate Change Trust Act 2010 sets up a statutory trust whose board approves projects prepared under the BCCSAP 2009 and may spend up to 66 per cent of the fund on them while keeping the rest invested. Internationally, Bangladesh is bound by the Paris Agreement, which it ratified in 2016, and has committed in NDC 3.0 to cut 2035 emissions below business as usual, with deeper cuts conditional on international finance. The National Adaptation Plan sets 113 adaptation actions to 2050.
Key point: The Climate Change Trust Act is a funding statute, not a regulatory one. It imposes no emissions limits or climate duties on companies. For businesses, the legal pressure comes instead from the NDC sector measures, environmental clearance, Bangladesh's Article 6 carbon framework, export-buyer requirements and writ litigation invoking the Paris Agreement and the right to life.
At a glance
One statute
The Trust Act of 2010 (Act No. 57 of 2010) creates a statutory trust and fund outside the regular budget.
66 / 34 rule
Up to 66 per cent of government grants may be spent on projects each year; at least 34 per cent is kept in the fund.
NDC 3.0
Submitted on 28 September 2025: a 6.39 per cent unconditional and 13.92 per cent conditional cut below 2035 business as usual.
Adaptation plan
The National Adaptation Plan 2023 to 2050 lists 113 actions and an estimated cost of about US$230 billion.
2026 reforms
After a 2025 TIB study alleged Tk 2,110.6 crore lost from the fund, the ministry moved approvals online and revised the fund usage policy.
Table of Contents
How climate change law Bangladesh applies is structured
Bangladesh has no framework climate act of the kind adopted in the United Kingdom or Kenya. There is no statutory carbon budget, no climate commission with enforcement powers, and no general duty on public bodies to act consistently with the national climate targets. The legal architecture is instead built in four layers, each with a different legal character.
Layer one: a finance statute
The only primary legislation dedicated to climate change is the Climate Change Trust Act 2010. It establishes the Climate Change Trust as a statutory body with perpetual succession, able to hold property and to sue and be sued, and it creates a trust fund to finance climate projects outside the government's regular development and non-development budgets.[1] The Act is Bengali-language legislation: section 24 provides that if the Bengali text and an authorised English translation conflict, the Bengali text prevails.[1]
Layer two: national policy instruments
Strategy is set by policy documents: the BCCSAP 2009, the National Adaptation Plan, the nationally determined contributions, the Locally Led Adaptation Framework and, in the Department of Environment's current work programme, a long-term low emission development strategy.[2] [7] These documents are not laws. They bind ministries as government policy and guide budget allocation, but they confer no directly enforceable rights and impose no obligations on private parties.
Layer three: international obligations
Bangladesh signed the Paris Agreement on 22 April 2016 and ratified it on 21 September 2016.[3] Its procedural obligations, to prepare, communicate and maintain successive NDCs and to report on them, are binding as a matter of international law. Bangladesh follows a dualist approach, so the Agreement is not part of domestic law unless legislation incorporates it, but courts may still refer to it when interpreting statutes and constitutional rights.
Layer four: general environmental law
Most of the rules that actually constrain emitting activity, from environmental clearance categories to brick kiln technology and air quality rules, sit in general environmental law rather than in a climate statute. That framework is explained in our guide to environmental law in Bangladesh, and the core statute in our analysis of the Bangladesh Environment Conservation Act. This article concentrates on the climate-specific layers.
The Climate Change Trust Act 2010 at the core of climate change law Bangladesh
The Trust Act was passed as Act No. 57 of 2010 and came into force immediately.[1] It was a deliberate choice to finance climate action from Bangladesh's own revenue, rather than wait for international funds, and the fund it created is commonly called the Bangladesh Climate Change Trust Fund. Its head office is in Dhaka, and the board may open branch offices elsewhere with prior government approval.[1]
Objectives and purposes
Section 5 sets the Trust's aims around helping vulnerable communities adapt, improving livelihoods and planning for long-term climate risk, across adaptation, mitigation, technology and finance. Section 6 lists the purposes for which the fund may be used, including action plans, grassroots capacity building, adaptation and mitigation research, support for climate cells and focal points in ministries, public awareness and emergency assistance after disasters.[1] The post-disaster purpose is significant: it is the closest the statute comes to a domestic loss and damage mechanism.
Projects must be additional and BCCSAP-based
Section 7 sets the core project rules. Funded projects must be additional to existing government programmes, must be prepared under the Bangladesh Climate Change Strategy and Action Plan 2009 and submitted to the board, and must follow climate change guidelines and board directions.[1] Any applicant for funding therefore has to show two things: that the project would not otherwise be financed from the regular budget, and that it fits a BCCSAP programme.
The board of trustees
Overall management rests with a board of trustees under sections 8 and 9. The minister in charge of the environment ministry chairs it. Its members include the ministers or state ministers for finance, agriculture, food and disaster management, foreign affairs, women and children affairs, water resources, shipping, health and local government, together with the Cabinet Secretary, the Governor of Bangladesh Bank, the Finance Secretary, a member of the Planning Commission and two government-nominated climate experts. The environment secretary is member-secretary.[1]
The board must meet at least once every three months, with a quorum of one-third of its members and a casting vote for the chair. Its functions under section 10 include final approval of projects, investment of the reserve, directions to the technical committee on annual plans and budgets, and the formation of evaluation teams, with an evaluation report to be approved at least once a year.[1]
The technical committee
Section 12 creates a technical committee chaired by the environment secretary, with representatives of sector ministries and the Planning Commission, Department of Environment experts, two NGO or expert members, a representative of the Center for Environmental and Geographic Information Services and a Forest Department representative. Under section 13 it prepares annual budgets and action plans for the board and screens and recommends projects submitted by ministries.[1] In practice this committee is the real gatekeeper for any project proposal.
The fund and the 66 / 34 rule
Section 15 lists the sources of the fund: allocations from the national budget, government-approved donor agencies, other domestic and foreign sources, investment returns and other approved sources. Money must be held in a scheduled bank in the Trust's name. Up to 66 per cent of government grants may be spent on projects in a year, and at least 34 per cent, together with any unspent money, goes into the fund. Interest and returns on the reserve may be released for approved projects.[1]
The rule was designed to build a permanent corpus that would outlive annual budget cycles. Its weakness is that the corpus depends on the size of the annual grant. For FY2026-27 the government proposed Tk 100 crore for the Trust, while the environment ministry as a whole was allocated Tk 2,240 crore.[11]
Audit, reporting and protection
The Comptroller and Auditor General must audit the Trust's accounts every year, with power to examine all records, cash, deposits and property, and the board must submit an annual report of its activities to the government.[1] Section 21 protects the board, its members, the managing director and staff from civil or criminal proceedings for acts done in good faith under the Act. That immunity does not cover acts done in bad faith, so it is no bar to the investigation the Anti-Corruption Commission is now conducting into Trust Fund projects.[8]

The BCCSAP 2009: a strategy that outlived its term
The Bangladesh Climate Change Strategy and Action Plan was issued by what was then the Ministry of Environment and Forests in 2009 as a ten-year plan for 2009 to 2018. It is organised around six pillars: food security, social protection and health; comprehensive disaster management; infrastructure; research and knowledge management; mitigation and low carbon development; and capacity building and institutional strengthening. Under those pillars sit 44 programmes, divided into immediate, short, medium and long-term actions.[2]
Why it still matters legally
Although its planning period ended in 2018, the BCCSAP has not lost its place in climate change law Bangladesh applies today. Sections 7 and 10 of the Trust Act tie project approval to the "Bangladesh Climate Change Strategy and Action Plan 2009" by name, so every Trust Fund project must still be framed as delivering a BCCSAP programme.[1] The national climate budget also continues to classify spending by the BCCSAP pillars: in the FY2026-27 budget, food security, social protection and health took 42.26 per cent of climate-relevant spending, infrastructure 24.47 per cent and mitigation and low carbon development 19.18 per cent.[10]
The case for an update
Transparency International Bangladesh concluded in November 2025 that both the BCCSAP and the 2010 Act were outdated and that there were no clear fund management rules, and recommended updating the BCCSAP and amending the Act.[9] Any replacement strategy will need a consequential amendment to the Act, otherwise new projects would have to be shoehorned into a 2009 framework. Applicants should, for now, map proposals both to a BCCSAP programme and to the more current NAP and NDC priorities.
The Mujib Climate Prosperity Plan after 2024
The Mujib Climate Prosperity Plan 2022 to 2041 was the previous government's attempt to recast climate policy as an economic growth strategy built on renewable energy, resilience and climate finance. Unlike the BCCSAP, it was never given statutory status. In December 2024 the High Court Division described it, in a rule issued on a writ petition, as a government-approved strategy, and asked why the respondents should not be directed to consider and implement it.[14]
Status in 2026
We have found no gazetted withdrawal of the plan. It has, however, fallen out of the government's own account of climate policy. When the Minister of Environment, Forest and Climate Change, Abdul Awal Mintoo, set out the government's climate measures in Parliament in April 2026, he referred to the BCCSAP, the Trust Fund, the NAP, the NDC, the Locally Led Adaptation Framework, the Bangladesh Climate Development Partnership, the long-term low emission strategy and an Article 6 carbon framework, but not to the Prosperity Plan.[7] The practical position is that the plan carries no operative weight in funding decisions, while the pending writ means its legal status has not been finally settled.
Paris Agreement obligations and NDC 3.0
The Paris Agreement gives Bangladesh a mix of binding procedural duties and softer substantive commitments. Article 4(2) requires each party to prepare, communicate and maintain successive nationally determined contributions and to pursue domestic mitigation measures to achieve them. Article 4(9) requires a new NDC every five years. Article 7(9) requires each party, as appropriate, to engage in adaptation planning, and Article 13(7) requires regular reporting of a greenhouse gas inventory and progress on the NDC.[4]
For a country with very low historical emissions, the finance provisions matter as much as the mitigation duties. Article 9(1) provides that developed country parties shall provide financial resources to assist developing country parties with both mitigation and adaptation, and Article 8(1) recognises the importance of averting, minimising and addressing loss and damage.[4] Bangladesh's conditional targets are built on that bargain.
What NDC 3.0 commits to
Bangladesh submitted NDC 3.0 to the UNFCCC on 28 September 2025. It uses 2022 as the base year, when emissions stood at 252.04 MtCO2e, and projects business-as-usual emissions of 418.40 MtCO2e by 2035. Against that projection it commits to an unconditional reduction of 26.74 MtCO2e, or 6.39 per cent, and a conditional reduction of 58.23 MtCO2e, or 13.92 per cent, dependent on international finance.[5]
The NDC 3.0 measures cover renewable generation and storage, lower grid losses, replacement of liquid-fuel peaking plants, electric vehicles and electric traction, industrial energy efficiency, cleaner brick technology, clean cooking, rooftop solar, solar irrigation, and agricultural measures such as alternate wetting and drying and manure management.[5] The government's own costing puts implementation at about US$116 billion to 2035, of which US$90.23 billion is expected from international support.[10]
Is NDC 3.0 legally binding?
The targets are not enforceable obligations of result under the Paris Agreement, and nothing in climate change law Bangladesh has enacted gives them domestic force. That does not make them legally irrelevant. In its advisory opinion of 23 July 2025, the International Court of Justice said that states must exercise stringent due diligence in preparing and implementing their NDCs, that NDCs must be ambitious and progressive and effectively implemented, and that they are not subject to a state's unlimited discretion.[13] Domestically, the NDC is the benchmark against which a court in a writ petition is likely to measure whether a government plan is rational and consistent with stated policy.
What NDC 3.0 means for business
The NDC creates no direct compliance obligation for companies, but it drives the regulation that does. Brick kiln, transport, power and industrial efficiency rules are the main channels. For power developers, the energy measures and their link to the Renewable Energy Policy 2025 are analysed in our guide to renewable energy law in Bangladesh, and the wider sector regulation in our guide to energy law in Bangladesh.
The National Adaptation Plan 2023 to 2050
Adaptation is where climate change law Bangladesh has developed most deeply in policy terms, because adaptation is where its exposure lies. The National Adaptation Plan for 2023 to 2050 was submitted to the UNFCCC on 31 October 2022. It identifies 113 adaptation actions, of which 80 are rated high priority, addresses 14 types of climate-related disaster across 11 climate stress regions, and estimates that implementation to 2050 will cost about US$230 billion.[6]
Legal character of the NAP
The NAP is Bangladesh's response to the adaptation-planning duty in Article 7(9) of the Paris Agreement.[4] Like the NDC, it is policy rather than law. The government describes both as being executed through the relevant ministries, divisions and agencies, which means each NAP action has to find its way into a ministry's development projects and budget.[7] The FY2026-27 climate budget is heavily weighted to adaptation, which took Tk 38,906 crore, or 75.2 per cent of climate-relevant spending.[10]
Locally led adaptation
The government has added a Locally Led Adaptation Framework intended to bring grassroots communities and local government into adaptation planning and delivery.[7] For NGOs and community organisations, this framework, together with the Trust Fund's non-government project stream, is the most direct route into publicly funded adaptation work.

Climate finance: the domestic and international routes
Climate finance in Bangladesh moves through three channels: the national budget, the Climate Change Trust, and international public and private funds. Each has its own entry point and its own compliance demands.
The climate budget
The national budget tags climate-relevant spending across 25 ministries and divisions. For FY2026-27 the proposed figure was Tk 51,746 crore, up 25.57 per cent from Tk 41,208.97 crore in FY2025-26. Mitigation accounted for Tk 9,925 crore, or 19.2 per cent. The Annual Development Programme includes 522 climate-related projects worth Tk 37,132.43 crore.[10] Contractors and consultants on those projects work under ordinary public procurement law, but climate tagging increasingly brings additional monitoring and reporting requirements.
The Climate Change Trust Fund in numbers
Total allocations to the Trust from FY2009-10 to FY2025-26 were Tk 4,151.71 crore, about US$495 million. As of March 2026, about Tk 4,383.95 crore had been earmarked for 985 projects, 924 of them government projects and 61 non-government. 828 projects had been completed and 153 government projects were under implementation, all at district and upazila level.[7]
International climate finance
International finance is now coordinated through the Bangladesh Climate Development Partnership, which the government describes as a platform to increase international climate finance, build project development capacity and improve coordination with partners.[7] Conditional NDC delivery depends on that channel: of the roughly US$116 billion NDC cost, US$90.23 billion is expected from international support.[10] Lenders' environmental and social standards then become the operative compliance rules for the projects they finance, which is why sponsors should read climate finance together with our guide to project finance in Bangladesh.
Article 6 and carbon markets
Article 6 of the Paris Agreement allows countries to transfer mitigation outcomes and to generate credits through a UN-supervised mechanism. The government reports that it has developed a comprehensive Article 6 framework to ensure transparent participation in international and voluntary carbon markets.[7] The FY2026-27 budget said that 11 new carbon trading projects had been started under Article 6 and set an aim of bringing 50 per cent of coastal mangrove forests under carbon trading activities.[11]
The framework is not yet a statute, and there is no domestic compliance carbon market. Developers should treat a government letter of authorisation as the critical document, because without it credits cannot be counted as internationally transferred, and should negotiate the government's share of proceeds, corresponding adjustment and the treatment of credits against the NDC in writing before investing.
Governance failures and the 2025 to 2026 reforms
The single most important development for the Trust since 2010 came in November 2025, when Transparency International Bangladesh published a study of government-funded climate projects from 2010 to 2024. It found that 891 projects had been approved with allocations of about Tk 3,896 crore, and estimated that Tk 2,110.6 crore, or 54 per cent, had been lost to corruption across approval, contracting, implementation and supervision.[9]
The study singled out solar streetlight projects: between 2019 and 2023, 216 of 373 approved projects involved solar streetlights, with equipment costs inflated by an estimated 47.1 to 57.1 per cent.[9] TIB recommended amending the Act so the Trust could access international climate funds and carbon revenue, prioritising funding by geography and vulnerability, prosecuting those involved and creating an independent monitoring body.[9]
What the government has changed
In Parliament on 31 March 2026, the environment minister said the Anti-Corruption Commission was investigating the allegations and had been given project data from 2009-10 to 2023-24. He listed the reforms: an online process for project adoption and implementation, with projects entered in the PPS software; guidelines for choosing projects in affected areas; a 12-member technical sub-committee; a digital monitoring system for approved projects; a revised Trust Fund usage policy issued in 2025; and guidelines for managing the permanent fund deposits.[8]
Consequences for implementing agencies and contractors
These are administrative reforms, not amendments to the Act, but they change the risk profile. Contractors and NGOs on Trust-funded projects should expect document requests from the Commission, audit queries going back years, and stricter cost benchmarking. Inflated procurement, as alleged for solar streetlights, exposes suppliers as well as officials to criminal liability under anti-corruption and penal law.
Loss and damage: international entitlement, domestic gap
Loss and damage refers to climate harm that adaptation cannot prevent: land lost to erosion and sea-level rise, salinity that ends farming, and displacement. Article 8 of the Paris Agreement recognises it but creates no liability or compensation.[4] The Fund for responding to Loss and Damage, operationalised at COP28 and hosted by the World Bank as an interim financial intermediary fund, has pledges of about US$786 million. Its first call for funding requests, under the Barbados Implementation Modalities, was launched after COP30 with an initial pool of US$250 million for 2025 to 2026, and replenishment talks are planned for 2027.[12]
The ICJ opinion and state responsibility
The ICJ advisory opinion strengthened the legal case that loss and damage is a matter of entitlement rather than charity. The Court found that a state's failure to take appropriate action to protect the climate system may constitute an internationally wrongful act, and that injured states may seek cessation, assurances of non-repetition and reparation.[13] Turning that into money for Bangladesh still depends on diplomacy and fund rules rather than litigation.
No domestic loss and damage framework yet
Domestically, there is no statute dealing with climate displacement, relocation or compensation for slow-onset loss. The Trust Act's post-disaster emergency assistance purpose and general disaster management law are the nearest substitutes.[1] A national mechanism to channel international loss and damage grants, with clear eligibility, safeguards and grievance routes, is one of the clearest gaps in climate change law Bangladesh will need to close as fund money starts to flow.
Climate litigation and rights-based claims
Bangladesh's courts have a long record of environmental public interest litigation, built on reading the constitutional right to life to include a healthy environment and on Article 18A of the Constitution. That body of case law, and the writ procedure, are covered in our guides to environmental law in Bangladesh and writ petitions in Bangladesh. Climate-specific litigation is the newest strand of climate change law Bangladesh courts are developing.
The IEPMP challenge
On 3 December 2024 a High Court Division bench of Justice Fahmida Quader and Justice Mubina Asaf issued a rule on a writ petition by Lawyers for Energy Environment and Development, a social enterprise, against the Integrated Energy and Power Master Plan 2023. The rule asked the government and the power ministry to show cause why the master plan should not be reconsidered with input from the environment ministry, and why they should not be directed to consider and implement the Climate Prosperity Plan.[14]
The petition relied on the constitutional commitment to a healthy environment, the Paris Agreement and the Sustainable Development Goals, while critics of the master plan pointed to its reliance on coal and LNG and on unproven hydrogen and ammonia technologies.[14] A rule is a preliminary order, not a judgment, and we are not aware of a final decision. Its importance is that a Bangladeshi court has agreed that a national energy plan's consistency with climate commitments raises an arguable public law question.
How the ICJ opinion may be used
The ICJ linked states' climate obligations directly to international human rights law.[13] Advisory opinions do not bind domestic courts, but petitioners can now cite an authoritative statement that NDCs must reflect stringent due diligence. Expect future writ petitions against fossil-fuel projects, master plans and clearance decisions to argue that a decision inconsistent with NDC 3.0, without reasons, is irrational or violates the right to life.
Litigation risk for project sponsors
For sponsors, the practical risk is a writ that delays a project at clearance or financing stage rather than a damages claim. Mitigation lies in a clean record: a climate and emissions analysis in the environmental impact assessment, documented consultation and a clear explanation of how the project fits national policy. TRW's constitutional and writ litigation practice acts for both petitioners and respondents in these cases.

Where renewable energy policy fits
Energy accounts for the largest share of planned mitigation in NDC 3.0, so the Renewable Energy Policy 2025, SREDA, tariff rules and the solar procurement rounds are where climate commitments meet investment decisions.[5] Those rules are set out in full in our guide to renewable energy law in Bangladesh. Two points connect them to the climate framework discussed here.
First, conditional NDC delivery depends on international finance, so the bankability of renewable projects directly affects whether Bangladesh can meet its conditional target.[10] Second, renewable projects are natural candidates for the Article 6 framework.[7] Because a credit sold abroad cannot also be counted toward Bangladesh's own target, developers should settle the carbon position with the Department of Environment before signing offtake or credit purchase agreements.
A step-by-step process for compliance and participation
The steps below apply to a sponsor, NGO or company that wants to access climate finance, develop a carbon project or reduce climate-related legal risk under climate change law Bangladesh currently applies. Swipe or scroll through the sequence.
Map the instrument
Identify whether the project or risk engages the Trust Act, the NAP, NDC 3.0, the Article 6 framework or general environmental law.
Fit national priorities
Link the proposal to a BCCSAP programme and to the relevant NAP action or NDC 3.0 sector measure, with evidence.
Show additionality
Document why the project would not be financed from the regular budget or would not happen without carbon revenue.
Choose the funding route
Apply through the sponsoring ministry, the Trust's non-government stream, a GCF or development-bank channel, or a carbon buyer.
Secure clearance and authorisation
Obtain environmental clearance and, for carbon projects, a written government authorisation before committing capital.
Build the integrity file
Keep procurement records, cost benchmarks and site-selection evidence ready for audit and Anti-Corruption Commission review.
Report and monitor
Meet the Trust's digital monitoring requirements and any lender or buyer reporting on emissions and outcomes.
Manage litigation risk
Record consultation and the project's consistency with climate policy so it can withstand a writ challenge.
For Trust Fund applicants
Government agencies submit proposals through their ministry to the technical committee, which screens them and recommends approved projects to the board.[1] Non-government organisations have a separate stream: 61 of the 985 projects earmarked by March 2026 were non-government.[7] Every proposal must show additionality and a BCCSAP programme, and should now also demonstrate vulnerability-based site selection under the 2025 guidelines.[8]
For exporters and corporates
No Bangladeshi law yet requires general corporate climate disclosure or emissions limits. The pressure comes from buyers and lenders. Export manufacturers should build an emissions inventory, link energy-efficiency and rooftop solar investment to the NDC measures, and keep evidence of compliance with clearance conditions. The compliance routine for environmental permits is explained in our guide to environmental compliance in Bangladesh.
Regulators and institutions
Climate responsibilities are spread across several bodies. The cards below identify who does what.
Ministry of Environment, Forest and Climate Change
Owns climate policy, the NAP and NDC process, and provides the Trust's secretariat.
Climate Change Trust
Board of trustees and technical committee approve and screen projects under the 2010 Act.
Department of Environment
Prepares the NDC and long-term low emission strategy, runs environmental clearance and Article 6 work.
Comptroller and Auditor General
Audits the Trust's accounts every year under section 18 of the Act.
Anti-Corruption Commission
Investigating allegations of losses from Trust Fund projects since the 2025 TIB study.
High Court Division
Hears writ petitions challenging plans and projects on environmental and climate grounds.
Comparing the climate instruments
The table below compares the main instruments by legal force and practical effect. On a phone, scroll it sideways.
| Instrument | Legal character | Period | Key content | Practical effect |
|---|---|---|---|---|
| Climate Change Trust Act 2010 | Statute (Act No. 57 of 2010) | Since 2010 | Trust, board, fund, 66 / 34 rule | Governs domestic climate project funding |
| BCCSAP 2009 | Policy, referenced by statute | 2009 to 2018 | Six pillars, 44 programmes | Every Trust project must fit a programme |
| National Adaptation Plan | Policy, UNFCCC submission | 2023 to 2050 | 113 actions, about US$230 billion | Guides ministry adaptation budgets |
| NDC 3.0 | International commitment | To 2035 | 6.39% unconditional, 13.92% conditional cut | Drives sector regulation and finance |
| Mujib Climate Prosperity Plan | Policy, not statutory | 2022 to 2041 | Growth-led climate strategy | No operative weight; raised in pending writ |
| Paris Agreement | Treaty, ratified 2016 | Ongoing | NDC, adaptation, transparency duties | Binding internationally; persuasive in courts |
Climate change law Bangladesh: what to watch in 2026 and 2027
Five developments will shape the next phase. First, whether the government amends the Climate Change Trust Act, as TIB recommended, to let the Trust receive international funds and carbon revenue and to put the 2025 usage policy on a statutory footing.[9] Second, whether a replacement for the BCCSAP is adopted, which would require the Act's references to the 2009 plan to be updated. Third, the outcome of the Anti-Corruption Commission investigation into Trust Fund projects.[8]
Fourth, the conversion of the Article 6 framework into binding rules on authorisation, registries and benefit sharing, and the first internationally transferred credits from Bangladeshi projects.[7] [11] Fifth, Bangladesh's first funding requests to the loss and damage fund ahead of the 2027 replenishment, and whether a domestic channel is created to receive them.[12]
TRW advises project sponsors, development organisations, lenders and NGOs on climate finance, carbon projects, Trust Fund participation and climate-related public law disputes. Our public international law practice advises on Paris Agreement and Article 6 questions, or you can contact TRW to discuss a specific project.
Frequently asked questions
Does Bangladesh have a climate change act?
Not a framework act. The only dedicated statute is the Climate Change Trust Act 2010, which creates a statutory trust and fund for climate projects. Targets and strategy sit in policy documents such as the BCCSAP, the NAP and NDC 3.0.[1]
What is the Climate Change Trust Fund?
It is the fund created under section 15 of the Climate Change Trust Act, financed mainly from the national budget and used for adaptation, mitigation, research and post-disaster projects outside the regular development budget.[1]
What is the 66 per cent rule?
Section 15(3) allows up to 66 per cent of government grants to be spent on projects each year and requires at least 34 per cent, plus unspent money, to be kept in the fund. Returns on the reserve may also be used for approved projects.[1]
Is the BCCSAP 2009 still in force?
What are Bangladesh's NDC 3.0 targets?
An unconditional cut of 26.74 MtCO2e (6.39 per cent) and a conditional cut of 58.23 MtCO2e (13.92 per cent) below 2035 business-as-usual emissions of 418.40 MtCO2e.[5]
Is the NDC binding on companies?
No. Climate change law Bangladesh has adopted does not give NDC 3.0 direct force against private parties. It shapes sector regulation, finance conditions and the arguments used in writ litigation.[13]
What does the National Adaptation Plan require?
It sets 113 adaptation actions to 2050 across 11 climate stress regions, at an estimated cost of about US$230 billion, to be delivered through ministries' development programmes.[6]
Can Bangladesh claim loss and damage compensation?
Has any Bangladeshi court ruled on climate change?
In December 2024 the High Court Division issued a rule questioning the Integrated Energy and Power Master Plan 2023 on climate grounds. It is a preliminary order; we are not aware of a final judgment.[14]
Source register
Primary legal and regulatory sources
Materials checked on 20 October 2026. Confirm the current official text before relying on any provision.
- Climate Change Trust Act 2010 (Act No. 57 of 2010) — Laws of Bangladesh
- UNEP Law and Environment Assistance Platform — Bangladesh Climate Change Strategy and Action Plan 2009
- United Nations Treaty Collection — Paris Agreement, status of signature and ratification
- Paris Agreement, authentic English text — United Nations Treaty Collection
- The Financial Express, 3 October 2025 — Bangladesh sets 2035 emission targets in NDC 3.0
- UNB, 19 February 2023 — 113 actions under the National Adaptation Plan to be implemented
- BSS, 15 April 2026 — Government takes multiple steps to combat climate change impacts: Mintoo
- Risingbd, 31 March 2026 — Minister on transparency and accountability measures in the Climate Trust (Bengali)
- Transparency International Bangladesh, 4 November 2025 — Irregularities and corruption cause over 50% loss in government-funded climate projects
- The Business Standard, 12 June 2026 — Climate budget rises 26%: where will the money be spent?
- Dhaka Tribune, 11 June 2026 — Government allocates Tk100 crore for climate trust fund
- Dhaka Tribune, 7 January 2026 — The mandate from Belém: transforming the loss and damage fund
- Jones Day, July 2025 — ICJ issues advisory opinion on states' legal obligations regarding climate change
- The Business Standard, 3 December 2024 — HC asks why Integrated Energy and Power Master Plan should not be reconsidered
Related TRW assistance
Move from information to a defined next step
TRW advises project sponsors, development organisations, lenders and NGOs on climate finance, Article 6 carbon projects, Climate Change Trust participation and climate-related writ litigation. Explore our public international law practice and constitutional and writ litigation practice, or contact TRW to discuss your project.