Labour Law Compliance in Bangladesh 2026: Registers, Deadlines, Penalties and HR Checklist

Labour law compliance Bangladesh employers must prove in 2026

Labour law compliance Bangladesh employers can defend in 2026 is a matter of calendars, registers and proof. The Bangladesh Labour (Amendment) Act 2026, Act No 43 of 2026, dated 10 April 2026, replaced the 2025 Ordinance, raised most fines, gave inspectors express power to enter without notice and now requires a safety committee in every establishment, not only every factory, with 50 or more workers.[2] [4] [6] The obligations themselves are not new. What changed is the cost of getting them wrong.

This is TRW's working checklist for HR, plant and legal teams: the registers an inspector will ask for, service rules approval, wage and leave deadlines, the participation fund, committees, accident notices, DIFE inspections, the amended penalties and the statutory returns, ending with a compliance calendar. The substance of each entitlement is covered in our companion guides, which we link rather than repeat.

Summary: Employers in Bangladesh must hold an appointment letter, identity card, service book and register entries for every worker, obtain DIFE approval before any service rules take effect, pay wages within seven working days of the wage period and final dues within thirty, run safety, participation and harassment committees where the thresholds apply, notify accidents within two working days, and file a half-yearly return by 15 July and an annual return by 15 February. Since April 2026 the general fine under section 307 is Tk 25,000 to Tk 50,000, and inspectors may enter with or without notice.

Key point: Most labour prosecutions are won or lost on documents. Section 306 makes a wilful refusal to produce a register to an inspector an offence carrying up to six months' imprisonment or a Tk 25,000 fine, and section 303 punishes false or omitted entries. A compliant practice with incomplete records will be treated as non-compliant.[1]

At a glance

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Table of Contents

What labour law compliance Bangladesh inspectors test in 2026

The Bangladesh Labour Act 2006 is the primary statute, and the Bangladesh Labour Rules 2015 prescribe the forms, registers and filing dates that make it enforceable.[1] [8] Act No 43 of 2026 repealed the Bangladesh Labour (Amendment) Ordinance 2025 (Ordinance No 65 of 2025) and deems everything done under the Ordinance to have been done under the Act.[2] Approvals, committees and notices made between November 2025 and April 2026 therefore remain valid.

Our hub on labour law in Bangladesh explains what the 2026 reforms changed. This guide asks a narrower question: what must an employer hold, file and do, and by when, to prove compliance on the day an inspector arrives.

Implementing rules are still catching up

Several 2026 provisions depend on rules not yet made. The Ministry of Labour and Employment's 22-point action plan, finalised at a workshop on 23 February 2026, targeted new labour rules by 30 June 2026 and the recruitment of 122 additional DIFE inspectors by 31 March 2026.[9] [10] In August 2026 the BGMEA president said the association was still waiting for rules under the amended law.[11] Until then, the 2015 Rules supply the forms and dates used here, read subject to the 2026 Act where they conflict.

Units inside export processing zones follow the Bangladesh EPZ Labour Act 2019 instead, so a group with plants on both sides of a zone boundary needs two compliance calendars.

Registers and records: the evidence base

Every labour law compliance Bangladesh programme starts with the registers, because an inspector or a Labour Court will judge the employer's practice by them. Section 9 requires a worker register for all workers, kept ready for inspection at all working hours, recording among other things each worker's name and date of birth, parents' names, date of appointment, nature of work, designation, department, working hours, rest intervals and weekly holiday.[1] Rule 23 prescribes Form 8, requires entries in Bangla with Gregorian dates, and accepts a printed copy of a digital register.[8]

The core registers

• Worker register: section 9 and rule 23, Form 8.[8]
• Leave register: rule 24, Form 9, recording leave under sections 115 to 117.[8]
• Wage record and wage slips: rule 111, Form 38, with a slip before payment in every wage period.[8]
• Accident and dangerous occurrence register: rule 73, Form 28.[8]
• Lay-off register: replaced section 17, which also bars parallel registers during a lay-off.[2]
• Fire drill record and safety record book: rules 55(14) and 80.[8]

Retention, display and integrity

Rule 363 requires all records kept under the Act and the Rules to be preserved for three years and produced to the inspector on demand.[8] Section 337 requires a notice summarising the important provisions of the Act and the Rules at the main entrance.[1] Section 303 punishes knowingly false entries, wilful omissions, keeping more than one copy of a register other than an office copy, and wilful failure to maintain or send any register or report, with up to six months' imprisonment or a Tk 5,000 fine, or both.[1] Duplicate attendance or wage books kept for buyer audits are exactly what that clause targets.

Service rules approval under section 3

An establishment may have its own service rules, but they cannot be less favourable to workers than Chapter II of the Act, and they must be submitted to DIFE for approval.[1] Section 3(3) is blunt: no service rules may take effect without that approval. A handbook issued without approval is not a defence in a dismissal or wage claim, and its more restrictive terms will simply be disregarded.

The 2026 timetable

Act No 43 of 2026 extended the period for the Inspector General to decide an application from ninety days to 120 days.[3] It also replaced section 3(4). If no order is made within 120 days, the employer may apply to the government within the following thirty days; if the order is unsatisfactory, it may appeal to the government within thirty days of receiving it. The government must dispose of the application or appeal within forty-five days, and its decision is final.[3] Section 3(5) exempts establishments owned, managed or controlled by the government from the approval requirement.[1]

What to put in, and what to leave out

Service rules that will be approved restate statutory minima accurately and add only more favourable terms: grades, allowances, disciplinary procedure under sections 23 and 24, grievance handling under section 33 and the 2026 harassment policy. Rules drafted against the pre-2026 text will fail on maternity benefit, festival holidays and resignation compensation.[2] Missing the thirty-day window leaves the employer without approved rules and without a statutory remedy. A labour law compliance Bangladesh review should therefore treat service rules as a filing with deadlines, not a policy document.

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Appointment letters, identity cards and service books

Section 5 prohibits appointing any worker without an appointment letter and requires a photo identity card for every worker.[1] Rule 19 lists the letter's mandatory contents: name, parents' and spouse's names, present and permanent address, designation, type of work and date of joining, class of worker, wages or pay scale with any annual increment, other financial benefits, and a statement that the terms follow the service rules and the Labour Act.[8] The identity card follows Form 6, and the issue of letters, cards and service books is recorded in Form 6(A).

Section 6 requires a service book for every worker at the employer's cost, held in the employer's custody, and rule 22 requires it to be opened within fifteen days of appointment or of completing probation.[1] [8] Drafting points for the letter itself, including probation and fixed-term risks, are covered in our guide to employment contracts in Bangladesh.

Contractor-supplied workers

Section 3A prohibits any contractor agency that supplies workers to other organisations from operating without government registration, and treats the supplied workers as the contractor's workers within the Act.[1] Under amended section 326, a contractor agency's licence now runs for one year, while factory and establishment licences are renewed every five years.[14] Check the contractor's registration and licence before engagement and at renewal, and audit its wage sheets: the 2026 definition of worker includes contractor-supplied staff.[2]

Working hours, leave and holidays: the operational checks

An adult worker may not ordinarily work more than eight hours a day, extendable to ten subject to section 108, or more than forty-eight hours a week; with overtime, total hours may not exceed sixty in any week or average more than fifty-six a week over a year.[1] Overtime is paid at twice the ordinary rate of basic wage, dearness allowance and any ad hoc or interim wage, except for piece-rated workers.[1]

Hours notices and weekly holidays

Rule 105 requires the notice of working hours for adult workers to be approved by the inspector, displayed and preserved for inspection.[8] Section 103 gives one weekly holiday in factories and one and a half days in shops and establishments.[1] A shift pattern that has drifted from the approved notice is a breach even if no worker complains.

Leave entitlements to load into HR systems

Casual leave is ten days and sick leave fourteen days a calendar year on full wages, and neither carries forward.[1] Annual leave for adult workers in shops, commercial and industrial establishments, factories and road transport accrues at one day for every eighteen days worked after a year's continuous service. The 2026 Act raised festival holidays under section 118(1) from eleven to thirteen days and set maternity leave at up to 120 days, sixty before and sixty after delivery.[2] The scope of each entitlement is explained in our guide to workers' rights in Bangladesh.

The Rules require a monthly return on workers receiving maternity benefit by the tenth day of the following month and an annual return by 15 February.[8] Since 2026 the daily rate is the worker's last monthly gross wage divided by twenty-six.[2]

Wage payment deadlines and payroll controls

Section 122 requires the wage period to be fixed and limits it to one month. Section 123 requires wages to be paid within seven working days after the end of the wage period, all dues on retirement, retrenchment, discharge, removal, dismissal, resignation or any other termination within thirty working days, and every payment on a working day.[1] Section 124 allows payment in cash, by cheque or, at the worker's request, into the worker's bank account.[1]

Rule 112 requires payment dates to be published in Bangla at the entrance at least ten days in advance.[8] Rule 111 requires two festival bonuses a year, each capped at monthly basic wage, for workers with a year's continuous service, and requires piece-rated workers to be topped up to the grade minimum.[8]

Personal liability for wages

Section 121 makes the employer responsible for paying all wages and, for directly engaged workers, also makes the chief executive, the manager or any person responsible to the employer for supervision and control liable for payment.[1] Paying below a declared minimum wage carries up to one year's imprisonment or a fine of Tk 20,000 to Tk 50,000 under section 289, and the court may order the shortfall paid to the worker.[1] Sector rates and the three-year Wage Board cycle are covered in our minimum wage guide.

WPPF, provident fund and gratuity: what to calendar

Chapter XV, on workers' participation in company profits, applies to a company or establishment whose paid-up capital is at least Tk 1 crore, or whose fixed assets are worth at least Tk 2 crore, on the last day of an accounting year.[1] Section 234 requires a participation fund and a welfare fund to be established within one month of the Chapter applying, and requires 5 per cent of the previous year's net profit to be paid, within nine months of the year end, to the participation fund, the welfare fund and the Bangladesh Shramik Kallyan Foundation Fund in the ratio 80:10:10.[1]

The 2026 Act replaced section 242(1): the whole amount credited to the participation fund each year must now be distributed in equal shares among all beneficiaries.[2] A finance team that books the WPPF accrual at year end but does not track the nine-month payment date is the most common gap we see in this area.

Provident fund and Progoti

Under replaced section 264(10), an establishment with at least 100 permanent workers must form a provident fund if two-thirds of them apply in writing, unless it enrols interested workers in the Progoti pension scheme with contributions split equally.[2] Fund rules, gratuity and tax recognition are covered in our guide to the provident fund and gratuity in Bangladesh. For the calendar, record any written demand on the date received and each worker's written opt-in or opt-out.

Safety committee and occupational safety duties after 2026

The 2026 Act replaced section 90A. Every establishment with fifty or more workers must form a safety committee in the manner prescribed by rules and keep it functioning, and the committee must inform the employer of identified risks, accidents, dangerous occurrences and diseases.[4] The threshold is fifty workers, not fifty permanent workers, so contractor and temporary staff count.

How the Rules require the committee to run

Rule 81 sets the committee at between six and twelve members with equal employer and worker representation, scaled to headcount: up to six members for 50 to 500 workers, eight for 501 to 1,000, ten for 1,001 to 3,000 and twelve above that.[8] Worker representatives are nominated by the collective bargaining agent or, if there is none, by the participation committee's worker representatives. The employer nominates within seven days after the workers' nominations, the first meeting follows within fifteen days, and the chairperson must inform the Inspector General within ten days of that meeting.[8]

Where at least one-third of the workforce is female, at least one-third of worker representatives must be women. Membership changes must be reported within fifteen days under rule 82, the committee's term is two years under rule 83, and the functions in Schedule IV require meetings at least once every three months, with written minutes ready for inspection.[8] Rule 55(14) separately requires a fire and evacuation drill every six months, notified in writing to the inspector and the nearest fire station at least fifteen days in advance.[8]

New safety rights for workers

New section 61A bars disciplinary action against a worker who withdraws from imminent and serious danger.[2] Amended section 85(3) lets an inspector who finds imminent danger prohibit use of any part, plant or work method until the danger is removed.[7] Licensing of the premises itself is covered in our guides to the factory licence and the fire licence; our occupational safety and health practice runs committee and drill audits.

Accident notices and the participation and harassment committees

Amended section 80 requires written or digital notice of an accident causing death or bodily injury, or of an explosion, fire or inrush of water or fumes, to the DIFE inspector and the relevant Department of Labour office within two working days, after immediate telephone notice to the fire service, police and DIFE.[7] Prescribed dangerous occurrences must be notified within three days under section 81, whether or not anyone is injured. Section 82 requires an occupational disease to be notified and entered in the register within two working days.[2] Rule 73 requires a half-yearly accident report to the inspector within ten working days after each six-month period.[8]

Participation committee

Section 205 requires every establishment ordinarily employing at least fifty workers to constitute a participation committee in which worker representatives are no fewer than employer representatives.[1] Rule 183 requires it within three months of starting activities, with six to thirty members, and rule 197 sets a two-year term.[8] The participation committee matters for safety compliance too, because its worker representatives nominate the safety committee where there is no collective bargaining agent.

Harassment complaint committee

Replaced section 332 requires every employer to adopt and implement a workplace policy against violence and harassment, assess and control the risks, train workers and publish the reporting and complaint procedure on the workplace website.[2] New section 332A requires a five-member complaint committee with a female majority, a woman as head and two members from organisations working on gender and sexual violence. Breach of section 332A carries a fine of Tk 20,000 to Tk 50,000 under new section 307A.[2] [5]

DIFE inspections: powers, process and response

The Department of Inspection for Factories and Establishments enforces the Act's provisions on hours, wages, safety, welfare, child labour and forced labour. New section 318A sets out the functions of the inspection system, including enforcement of legal provisions on working conditions, technical advice to employers and workers, and reporting defects the law does not specifically cover.[6] Since 2018 DIFE has recorded inspections, licensing and accident notifications in its LIMA digital system, which also hosts a complaint box for workers and employers.[12]

What changed in 2026

Amended section 319(1)(a) authorises an inspector to enter, inspect, investigate and examine any premises, vessel or vehicle used as an establishment at any reasonable time, with or without prior notice to the management, in accordance with standard operating procedures.[6] New section 319(5) allows the Inspector General, or a subordinate officer so empowered, to file a complaint in the Labour Court for any offence within DIFE's jurisdiction.[6] New section 319A requires the inspector to keep the source of any complaint entirely confidential and not to tell the employer that a visit followed a complaint; a worker who suffers discrimination or hostility for complaining may go to the Labour Court.[6]

A January 2025 CPD analysis described DIFE as short of inspectors and LIMA as under-used.[13] Employers should not read that as tolerance: unannounced visits, confidential complaints and higher fines all point to more targeted inspection.

Handling an inspection

Designate one manager per site with authority to produce registers and accompany the inspector. Never obstruct: wilful obstruction, refusing reasonable access or refusing to produce a register is an offence under section 306.[1] Log what was inspected, answer each finding in writing with evidence of correction, and send any prohibition order or threatened complaint to counsel the same day.

Offences under the Act are tried only by the Labour Court, on a complaint by an aggrieved person or union, or by an authorised officer, and a complaint must ordinarily be made within six months of the offence.[1] Our guide to the Labour Court in Bangladesh explains procedure and appeals.

Common violations and the amended penalties

The violations that reach the Labour Court are rarely exotic: missing appointment letters, unpaid overtime, late final settlements, unrecorded leave, paper committees and accident notices never sent. Act No 43 of 2026 raised most of the fines; the table collects the main penalties as amended.[1] [2]

How section 307 works

Replaced section 307 is the residual offence. Any person who contravenes or fails to comply with the Act or any rule, regulation or scheme, where no other penalty is provided, faces up to three months' imprisonment, a fine of Tk 25,000 to Tk 50,000, or both.[5] The fixed minimum fine matters. A missing hours notice, an unformed participation committee or a late return now carries a floor of Tk 25,000 for each breach, and an inspection that finds a dozen breaches can become a dozen complaints.

Death and serious injury

Section 309 applies notwithstanding anything else in the Chapter, and the court may direct that a fine be paid to the injured person or the heirs.[1] That criminal exposure sits alongside injury compensation under Chapter XII.

Labour law compliance Bangladesh calendar for 2026 and 2027

The calendar below brings the recurring and event-driven deadlines together. It assumes a calendar-year establishment outside an export processing zone; adjust the WPPF date to your own financial year.

Annual and half-yearly returns

Section 333(b) allows the government to require employers to submit periodic returns, and rule 362 requires two: a half-yearly return in Form 80 for the period ending 30 June, due by 15 July, and an annual return in Form 81 for the year ending 31 December, due by 15 February.[1] [8] Treat the figures as evidence: an annual return that contradicts the worker register or the wage record is itself a potential section 303 offence.[1]

Running a labour law compliance Bangladesh audit

A labour law compliance Bangladesh audit tests whether the documents exist, whether they match the floor, and whether the employer can prove both. We sample payroll against attendance, trace leavers to final payment, reconcile the worker register with headcount including contractor staff, and read committee minutes against the required meeting frequency.

Audit checklist

• Documents: appointment letter, ID card and service book per sampled worker; approved service rules.
• Time and pay: approved hours notice, double-rate overtime, wage slips, final dues within thirty working days.
• Committees and safety: safety, participation and harassment committees constituted and meeting; drills and accident reports on file.
• Funds and filings: WPPF paid within nine months; returns filed on time and consistent with the registers.
• Contractors: section 3A registration and a current licence for each supplier.

Where an audit identifies termination or retrenchment exposure, the exit procedure should be reviewed separately against our guides to terminating employees in Bangladesh and hiring and firing laws in Bangladesh.

When an HR compliance lawyer should be involved

Most of this checklist belongs with HR and plant management. Some moments justify an HR compliance lawyer in Bangladesh before the employer acts: a service rules submission or refusal, a written provident fund demand, a fatal accident, a prohibition order or Labour Court complaint, a harassment complaint against a senior manager, a mass retrenchment, and buyer or investor due diligence that relies on compliance representations.

TRW's employment law compliance practice runs audits against the 2026 Act, drafts and submits service rules, and builds the calendar into HR systems. Our employment litigation team acts for employers on inspection findings, criminal complaints and wage claims in the Labour Court and Labour Appellate Tribunal. Labour law compliance Bangladesh businesses can rely on is built before the inspector arrives, not after.

Frequently asked questions

Do company service rules need government approval in Bangladesh?

Yes, except for government establishments. Under section 3, service rules must be approved by DIFE before they take effect. Since 2026 the decision period is 120 days, followed by a thirty-day window to apply or appeal to the government.[1] [3]

Which registers must an employer keep under the Labour Act?

A worker register, leave register, wage record with wage slips, accident register, fire drill record and, during a lay-off, a lay-off register, each kept for three years.[1] [8]

When must wages be paid in Bangladesh?

Within seven working days after the end of the wage period, which cannot exceed one month, and all dues on any termination within thirty working days. Every payment must be made on a working day.[1]

Is a safety committee mandatory?

Yes, for every establishment with fifty or more workers under replaced section 90A, with six to twelve members meeting at least every three months.[4] [8]

Can DIFE inspect without notice?

Yes. Amended section 319(1)(a) allows entry and inspection at any reasonable time with or without prior notice, and section 319A requires the inspector to keep the source of a complaint confidential.[6]

What is the general penalty for labour law violations after 2026?

Under replaced section 307, where no specific penalty applies, up to three months' imprisonment or a fine of Tk 25,000 to Tk 50,000, or both.[5]

When is the WPPF contribution due?

Within nine months of each year end: 5 per cent of the previous year's net profit, split 80:10:10, for companies meeting the section 232 thresholds.[1]

How quickly must a workplace accident be reported?

Within two working days to DIFE and the Department of Labour, after immediate phone notice to emergency services; dangerous occurrences within three days.[7]

What annual returns must employers file?

Under rule 362 of the Labour Rules, a half-yearly return in Form 80 by 15 July and an annual return in Form 81 by 15 February, plus maternity benefit returns monthly and annually.[8]

Can managers be personally liable for unpaid wages?

Yes. Section 121 makes the chief executive, manager or person responsible for supervision and control liable, alongside the employer, for paying wages to directly engaged workers.[1]