TRW Insight / Bangladesh
A current guide to NGO registration in Bangladesh, INGO structures, foreign donations, project approval and compliance
NGO registration: a 2026 approval framework
An NGO or INGO structure needs a clear legal vehicle, an accurate foreign-donation pathway and records that remain reliable after initial registration.

As at 18 October 2026. Establishing a not-for-profit presence in Bangladesh and becoming eligible to receive foreign funding are related, but different, regulatory exercises. The distinction matters. A local society, a not-for-profit company or a social-welfare agency may be validly constituted under its own enabling law. That status does not, by itself, permit the organisation to conduct voluntary activities using foreign donations. The Foreign Donations (Voluntary Activities) Regulation Act, 2016, as materially amended by the Foreign Donations (Voluntary Activities) Regulation Amendment Act, 2026, places that activity within the NGO Affairs Bureau regime. [1] [2]
For international NGOs, foundations, charities and donor-funded programmes, the practical question is therefore not simply “how do we register an NGO?” It is: what local legal vehicle is appropriate, what NGO Affairs Bureau approval is needed for the intended funding and activities, and what controls must be in place before funds are received or spent? This guide explains the current framework in general terms. It is not legal advice, and a project’s facts, governing documents, location, proposed donors and sector-specific permissions should be reviewed before any application is made.
The 2026 amendment is particularly important. It was enacted on 10 April 2026 and is deemed effective from 11 December 2025. It changes, among other matters, the registration and renewal provisions, certain project-approval rules, small-grant treatment, foreign personnel arrangements and appeal timing. Older online guidance that only describes the 2016 wording should therefore be used with caution. [1]
Contents
Start with the funding and activity model
The starting point is the statutory trigger, not the label an organisation uses. Under the amended framework, an organisation or NGO cannot undertake and conduct voluntary activities by receiving foreign donations without NGO Affairs Bureau registration. An individual receiving foreign donations for voluntary activities does not need registration, but does need the Bureau’s approval. [1]
The Act uses broad concepts. A foreign donation includes cash, goods, or other grants, donations, aid or assistance provided by a foreign government, institution or citizen, or by a Bangladeshi citizen living abroad, for voluntary or charitable activities in Bangladesh. The original Act’s definition of voluntary activities is equally wide. It covers non-profit social, religious, cultural, economic, educational, health, water and sanitation, relief and rehabilitation, agricultural and development activities, awareness, poverty alleviation, women’s empowerment, human rights, environmental and climate work, skills development, welfare, research and other prescribed activities. [2]
A useful first exercise is to map the proposed operating model in writing:
- Will the Bangladesh entity or branch receive cash, goods or in-kind assistance from overseas?
- Who is the intended donor, and can its commitment be evidenced?
- What activities will be performed, in which districts, and through which implementing partners?
- Will the arrangement use a local entity, an overseas NGO’s Bangladesh office, or both?
- Will foreign advisers or officers be engaged, and will project funds pay for overseas travel?
These answers affect the incorporation documents, the registration submission, the project proposal, budget and compliance calendar. They also help avoid an avoidable mismatch between an organisation’s stated objects and the activity or geography later submitted to the Bureau.
The statutory definition of an “organisation” refers to a non-political, non-profit voluntary organisation, institution or body formed by a number of people for voluntary activities in Bangladesh and registered under existing Bangladesh law. “NGO” for this regime means an organisation registered by the Bureau, and includes a foreign-law NGO that is registered under the Act. In other words, ordinary use of the term “NGO” is not a substitute for identifying the relevant statutory status. [2]
Choose the right local legal vehicle
Bangladesh does not have one universal incorporation route for every charitable or public-benefit initiative. The right choice depends on governance, membership, assets, objects, the intended operations and the funding plan. The legal vehicle should be selected before the foreign-donation submission is assembled, because the Bureau’s current domestic-NGO instructions require evidence of initial registration, an approved constitution and executive-committee information. [4]
Society. Under the Societies Registration Act, 1860, seven or more persons associated for literary, scientific, charitable or other eligible purposes may form a society by subscribing a memorandum and filing it with the Registrar of Joint-stock Companies. The memorandum must state the society’s name and objects and identify the governing body; certified rules and regulations must accompany it. The Act also requires an annual filing of the current managing body. A society may be appropriate where the membership and governing-body model is central to the organisation’s design. [6]
Not-for-profit company. Section 28 of the Companies Act, 1994 provides a route for an association formed or to be formed for commerce, art, science, religion, charity or another useful object where it applies its profits or other income to those objects and prohibits dividends to members. The Government may license the association to be registered as a limited company without “Limited” in its name, subject to conditions. This route should be considered as a governance and corporate-law choice; its availability does not itself confer foreign-donation approval. [7]
Voluntary social-welfare agency. The Voluntary Social Welfare Agencies Registration and Control Ordinance, 1961 applies to a voluntary social-welfare agency established to provide services in scheduled welfare fields and relying on public subscriptions, donations or government aid. An agency must apply in the prescribed form with its constitution and other prescribed documents. The Registration Authority may investigate and either issue a certificate or reject the application with recorded reasons. Registered agencies must maintain audited accounts, submit and publish annual reports and audited accounts as prescribed, use approved bank accounts and provide records when required. [8]
These are not interchangeable shortcuts. A project may need to consider other sectoral permissions, employment, immigration, tax, land, data or fundraising issues that are not resolved by choosing a formation route. Equally, a body that is properly registered under the Societies Act, Companies Act or social-welfare framework must still assess the NGO Affairs Bureau regime before it receives foreign donations for voluntary activities. [1] [2]
Understand the foreign-donation framework
The core law is the Foreign Donations (Voluntary Activities) Regulation Act, 2016. The 2026 amending Act replaced key provisions and is deemed effective from 11 December 2025. For current planning, the amended statutory text should be read together with applicable rules, orders, prescribed forms and the Bureau’s live e-service instructions. [1]
The amended section 3 preserves the central rule: without Bureau registration under the Act, an organisation or NGO may not receive foreign donations to undertake and conduct voluntary activities. It also introduces the concept of an institutional support fund: donor funding outside project assistance that may, with Bureau permission, be used as institutional support for voluntary activities. The detailed provisions are to be prescribed by rules. Organisations should not assume that a donor’s description of funding as “core”, “overhead” or “institutional” removes the need for regulatory analysis. [1]
Registration is not the endpoint. The amended statute separates the corporate or organisational status from approvals connected to foreign-funded work. The Bureau’s role extends to registration, renewal, project approval and fund-release controls. The Bureau’s current e-service portal describes the registration application as FD-1, renewal as FD-8 and a standard project proposal as FD-6; it also publishes instructions for emergency relief and foreign-national appointments. [3]
For applicants, that produces a practical two-layer model:
- Establish or evidence the underlying organisation. A domestic applicant should ensure that its initial registration, constitution, governing body and objects are internally consistent. A foreign applicant should ensure that its home-country existence, governing approval and Bangladesh representation are documented.
- Obtain and maintain the Bureau status and activity approvals. This includes the registration certificate, any required project approval, funding and banking permissions, and the continuing reporting and audit obligations.
The amended Act provides a 10-year duration for registration and renewal certificates, measured from the date stated on the certificate. A renewal application, with the prescribed fee, must be made six months before expiry. In considering renewal, the Director General verifies the application materials and reviews the applicant’s voluntary activities over the preceding five years. If the renewal application is filed within that six-month window, the organisation may continue voluntary activities after certificate expiry until the application is decided. [1]

Register with the NGO Affairs Bureau
An applicant should use the live NGO Affairs Bureau e-service instructions as its operational checklist, while treating the statute and any applicable rules or orders as controlling. The portal is expressly described as operating in a testing phase and its instructions, forms, fees and technical workflow can change. Do not rely on a saved checklist from an earlier filing. [3]
For a domestic NGO, the Bureau’s current registration instructions call for a completed FD-1, executive-committee information, identification and photographs for committee members, copies of the initial registration certificate and approved committee list, the approved constitution, an activities report, a plan of operation and organogram, a donor commitment letter, evidence of fee payment and VAT payment where applicable, minutes of the meeting forming the executive committee, and a signed list of general members. The portal’s requirement for initial-registration evidence reinforces the need to settle the local legal vehicle before the FD-1 submission. [4]
For a foreign NGO, the published checklist includes an FD-1 signed by the chief executive in Bangladesh, the certificate of incorporation in the country of origin, constitution, activities report, plan of operation, board decision to open a Bangladesh office, appointment letter for the country representative, evidence of the applicable treasury payment and VAT, landlord agreement, foreign executive-committee list and letter of intent. The portal states that documents from abroad should be notarised by a justice of the peace or attested by the relevant Bangladesh embassy. The exact formality needed for a document should be checked against the current instructions and the document’s country of origin before legalisation steps begin. [4]
The current portal lists a registration fee of BDT 50,000 for a domestic NGO and the BDT equivalent of USD 9,000 for a foreign NGO, and states that National Board of Revenue VAT is applicable where relevant. It lists renewal fees of BDT 30,000 for domestic NGOs and the BDT equivalent of USD 6,000 for foreign NGOs. Those figures are published administrative information, not a permanent statutory entitlement; applicants should recheck the portal, tax treatment and payment method immediately before filing. [4]
Under the amended Act, the Director General sends a correct registration application, information and documents to the Ministry of Home Affairs and the Financial Institutions Division for opinions. If a favourable opinion or recommendation is received, the Director General issues the certificate in the prescribed form within the prescribed period. If the relevant ministry or division does not provide its opinion within the prescribed time, the Director General may issue a certificate based on the application. The statute does not make approval automatic, so applicants should not promise a fixed outcome or filing timetable to donors, staff or counterparties. [1]

Obtain project approval and control the funds flow
Registration and project approval must be treated as separate gates. Under amended section 6, an NGO or organisation generally may not receive foreign donations without the Bureau’s project approval. For a project, the application must use the prescribed form and identify the specific area in which voluntary activities will be conducted. The Act permits the Director General to seek the relevant ministry or division’s opinion under the Rules of Business, 1996. It also provides that a subsequent phase of a multi-phase project in the same area, and a foreign NGO’s administrative-expense project, need not undergo a fresh ministry-opinion step in the circumstances stated in the law. [1]
The current e-service guidance identifies FD-6 as the project-proposal form. A project narrative should align the donor commitment, activities, beneficiaries, geographical area, implementation partners, budget, staffing and monitoring evidence. Material inconsistencies are not merely drafting issues: the Act confines voluntary activities to the project approved by the Bureau. [1] [3]
The amended law caps administrative expenditure at 20% of approved project expenditure. It also creates a limited treatment for foreign donations up to BDT 5 million in a year: Bureau project approval is not required, provided the Bureau is notified in advance of all project activities and areas, and an audit report prepared by a Bureau-listed audit firm is sent after project completion within the prescribed time. This is not a general waiver from registration, recordkeeping or other legal obligations. It is a conditional exception to project approval for a defined annual amount. Organisations contemplating this route should verify the threshold, aggregation analysis, notice mechanics and audit requirements against the current rules and portal before receiving funds. [1] [3]
Emergency relief has a separate statutory provision. Where an application, information and documents are considered proper for immediate disaster or post-disaster emergency relief, the Director General may issue an order for project approval and foreign-donation release within 72 hours. The word “may” and the condition that the papers are proper are important. Emergency planning should therefore include an up-to-date documentary pack rather than assume an automatic 72-hour clearance. [1]
Funds controls continue after approval. The 2016 Act requires all foreign donations to be received in foreign or domestic currency through a specified “mother account” at a scheduled bank. A bank may not disburse foreign donations to a person or NGO without a Bureau permission letter for disbursement. Bangladesh Bank must provide the Bureau and Economic Relations Division semi-annual accounts of foreign exchange received by each relevant individual or NGO. [2]
Build compliance into operations
A strong compliance file should start before the first disbursement. The statutory baseline requires an NGO to have a constitution covering its structure, goals, objectives and management, including its executive and general councils. It must maintain accounts in the prescribed manner, prepare annual financial statements and retain project-completion vouchers for five years. After each financial year, it must submit an annual activity report to the Director General in the prescribed manner; the Director General may also call for a report or statement on any approved project. [2]
The Bureau may inspect, observe and monitor activities and progress, and the NGO must provide relevant statements, ledgers, documents and information during those processes. This means a useful internal control environment includes a board-approved delegation matrix, a project-to-budget ledger, signed supporting documents, donor and vendor due diligence, approvals for material changes, an asset register and a calendar for reports, audits and renewals. These are practical controls inferred from the statutory record, reporting and inspection duties; they should be tailored to the organisation’s scale and any donor requirements. [2]
Renewal preparation should begin well before the statutory six-month filing deadline. The current FD-8 instructions distinguish domestic and foreign NGO files but broadly call for the current form, governance records, governing documents, fee and VAT evidence, certificate copies, annual reports and audit reports. They also request information on foreign-donation activities for prior years. The statutory review period is five years, while the online renewal checklist includes, among other documents, 10 years of audit reports and annual reports. That difference is a reason to preserve the complete historical file and confirm the then-current checklist with the Bureau before renewal. [1] [5]
Foreign personnel require their own workstream. For appointment or extension of a foreign adviser, expert or officer on an approved project, the amended Act requires an application to the Director General for security clearance; the proposal must stay within the person-months approved for that project. The Director General undertakes a preliminary review and sends the matter to the Ministry of Home Affairs for its opinion. If no opinion is sent within the prescribed period, the Director General may approve, recording reasons. The portal refers to FD-9 for foreign-national appointment documentation and separately refers to a work-permit application for the approved period. Immigration and employment requirements must also be assessed independently. [1] [3]
The 2026 amendment also changed the approach to overseas project travel. Where a person working on a project travels abroad on approved project funds for project-related work, the NGO must record the travel in its annual report. This is a reporting obligation under the amended provision, not a substitute for any other required travel, employment, tax or immigration compliance. [1]
Non-compliance can have serious operational consequences. The Act authorises the Director General to issue a written warning or corrective directions, suspend or cancel registration or activities, and, in the case of foreign donations received without permission, impose a prescribed fine up to three times the monetary value received. It also addresses asset restrictions and administration following cancellation, suspension or termination. An aggrieved NGO or individual may appeal a Bureau order to the Secretary, Prime Minister’s Office within 45 days; the appellate authority may allow up to 15 additional days for reasonable cause, and should dispose of the appeal within 45 days. [1] [2]

Plan a defensible registration sequence
A successful application is usually a controlled documentation project, not a single form submission. The following sequence is designed to reduce rework while respecting that regulator practice may change.
- Scope the model. Identify the donor, expected amounts, proposed activities, area, implementation chain, foreign personnel and whether the funding is project support or potentially institutional support.
- Choose and align the legal vehicle. Match the constitution, objects, membership or board structure, non-distribution provisions and local registration route to the operating model. Do not file a foreign-funding application with objects that contradict the project narrative.
- Prepare evidence before the online filing. Gather certified organisational documents, board resolutions, donor evidence, Bangladesh office or representative documents where relevant, governance information, plan of operation, organogram and premises evidence. Confirm which documents require notarisation or embassy attestation.
- Check the live Bureau instructions and payment data. Use the current FD-1 and published checklist. Reconfirm the fee, VAT, treasury codes, forms and portal workflow on the filing date; these are administrative items that may be updated.
- Design the project package in parallel. Prepare the FD-6 proposal, budget and geography so they accord with the registration case. Build the 20% administrative-expenditure cap into the draft budget rather than attempting to solve it later.
- Set up the post-approval controls. Before any receipt, configure the designated bank account process, approval matrix, records retention, audit plan, reporting calendar and foreign-staff process. Treat the approval conditions and project boundaries as live operating controls.
For a tailored assessment of a planned Bangladesh structure, funding arrangement or compliance programme, readers may contact TRW through its contact page or review the firm’s practices. No confidential or project-sensitive information should be sent through an unapproved public channel.
Frequently Asked Questions
Does a local society or not-for-profit company automatically have the right to receive foreign donations?
No. Formation under the Societies Registration Act, a section 28 Companies Act structure or another local regime may establish the organisation’s legal basis. It does not displace the amended foreign-donation rule: an organisation or NGO needs NGO Affairs Bureau registration before undertaking and conducting voluntary activities with foreign donations. Project approval may also be required before donations are received. [1] [6] [7]
Is NGO Affairs Bureau registration different from project approval?
Yes. Registration concerns the organisation’s status under the Foreign Donations Act. Project approval concerns the proposed foreign-funded activity, including the specified area and project terms. The amended Act generally requires project approval before an NGO or organisation receives foreign donations, subject to the statutory limited exception for up to BDT 5 million in annual donations when the notification and audit conditions are met. [1]
How long does NGO Affairs Bureau registration last?
The amended Act states that registration and renewal certificates last for 10 years from the date shown on the certificate. A renewal application must be made six months before expiry with the prescribed fee. A timely application allows activities to continue while the Director General decides it, but this should not be treated as permission to defer renewal preparation. [1]
What documents should a foreign NGO expect to provide?
The current Bureau checklist includes an FD-1 signed by the chief executive in Bangladesh, home-country incorporation certificate, constitution, activity report, plan of operation, board decision to open a Bangladesh office, appointment letter for the country representative, landlord agreement, executive-committee list and letter of intent, as well as payment evidence. Overseas documents should be notarised or attested as the Bureau instructs. Check the live portal for the current version before filing. [4]
Can an NGO receive a small foreign grant without project approval?
The amended Act allows an NGO to receive up to BDT 5 million in foreign donations in a year without Bureau project approval only if it notifies the Bureau in advance of all activities and project areas and later provides the required audit report from a Bureau-listed audit firm within the prescribed period. Registration is still required for an organisation or NGO conducting voluntary activities with foreign donations, and the exception should be verified against current rules before use. [1] [3]
Is there a limit on administrative expenditure for a foreign-funded project?
Yes. Amended section 6 provides that no more than 20% of approved expenditure on a project may be spent for administrative purposes. The classification of a particular cost should be considered when the budget is designed, documented and submitted, rather than only after funds have been spent. [1]
Must foreign advisers and officers obtain approval?
For an approved project, an appointment or extension for a foreign adviser, expert or officer requires an application for security clearance to the Director General and must stay within the project’s approved person-months. The Bureau’s current portal identifies FD-9 for the appointment-clearance workflow and describes a separate work-permit application for the approved period. Other immigration and employment requirements may also apply. [1] [3]
What happens if the Bureau makes an adverse order?
The Act provides a route of appeal to the Secretary, Prime Minister’s Office. Following the 2026 amendment, the appeal period is 45 days from the order, with a possible extension of up to 15 days for reasonable cause. The appellate authority may uphold, cancel or amend the order and should dispose of the appeal within 45 days. Immediate advice should be obtained because the facts, order, deadlines and ongoing controls will matter. [1]
Source register
Primary legal and regulatory sources
Source materials were checked on 18 October 2026. Statutory interpretation should be confirmed against current official texts and the facts of the matter.
- Foreign Donations Voluntary Activities Regulation Amendment Act 2026
- Foreign Donations Voluntary Activities Regulation Act 2016 official English text
- NGO Affairs Bureau e-service portal
- NGO Affairs Bureau registration application instructions
- NGO Affairs Bureau renewal application instructions
- Societies Registration Act 1860
- Companies Act 1994
- Voluntary Social Welfare Agencies Registration and Control Ordinance 1961
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