Artificial Intelligence and AI Governance in Bangladesh

by Barrister Tahmidur Rahman | Sep 8, 2026

Technology, IP & DataResponsible AI, practical governance8 min read

Artificial Intelligence and AI Governance in Bangladesh

AI governance advice for Bangladeshi companies, banks, telecoms, healthcare providers, technology exporters and public bodies, covering board oversight, AI policies, risk and impact assessments, data protection under the Personal Data Protection Act 2026, sector regulation, vendor contracts, staff training and preparation for foreign AI laws.

Overview

How we advise on AI governance in Bangladesh

Artificial intelligence is already embedded in Bangladeshi business: chatbots in customer service, scoring models in lending, fraud detection in mobile financial services, diagnostic support in healthcare, automated screening in recruitment and generative tools on employees' desks. Many organisations adopted these tools quickly, without deciding who is responsible for them or how risks will be identified and managed. AI governance is the framework of policies, roles, processes and contracts that closes that gap. We help organisations build governance that is proportionate to their use of AI, as part of our technology, IP and data practice in Bangladesh.

Bangladesh does not yet have a dedicated AI statute, although government policy work on artificial intelligence has continued and further rules are likely. That does not mean AI is unregulated in Bangladesh. The Personal Data Protection Act 2026 applies to AI systems that process personal data, including profiling and automated decision-making. Consumer protection, employment, anti-discrimination principles in the Constitution, cyber security and intellectual property laws all apply to AI uses. Sector regulators, particularly Bangladesh Bank, BTRC and health authorities, expect regulated firms to manage technology and model risk, and boards remain accountable for decisions made with AI.

For many Bangladeshi businesses, foreign rules matter as much as domestic ones. Software and IT-enabled service exporters, garment manufacturers using AI in supply chains, and outsourcing providers serving European, US or Middle Eastern clients may be contractually or legally required to meet standards such as the EU AI Act, sector rules in client jurisdictions, or frameworks such as ISO/IEC 42001 and the NIST AI Risk Management Framework. Clients increasingly ask suppliers about their AI governance in due diligence questionnaires. We help businesses understand which foreign obligations reach them and build one governance system that can satisfy several audiences.

In our view, good governance starts with an inventory: what AI is in use, who supplied it, what data it uses and what decisions it influences. From there, organisations can classify uses by risk, set approval and testing requirements, assign accountable owners, train staff, and monitor performance, bias and incidents after deployment. Contracts with AI vendors must support this framework by giving the organisation the information, audit and control rights it needs. We draft policies, procedures and contract terms that fit the organisation's size and sector, rather than importing heavy foreign frameworks that staff will simply not follow.

We work with boards, general counsel, compliance teams, data protection officers and technology leaders. Our advice covers board briefings on AI risk, AI policies and acceptable use rules, risk and impact assessments, data protection compliance, workplace AI and employee monitoring, vendor contracting, regulator engagement and incident response. Where AI is linked to a dispute, such as a challenge to an automated decision, our dispute resolution team assists. We coordinate with counsel in the UK, US, UAE, China, India and Singapore for multinational groups, so that AI governance in Bangladesh aligns with the group's global approach.

01 · What we handle

Core workstreams

  • Board oversight and AI strategy
  • AI policies and acceptable use rules
  • AI risk and impact assessments
  • Data protection and automated decisions
02 · How it runs

Four clear stages

  1. 01Inventory and gap analysis
  2. 02Framework design
  3. 03Documents and training
  4. 04Monitoring and updates
03 · Start here

Talk to a partner

Consultations in Dhaka or by video. Scope, team and fees are agreed in writing first.

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How we help

AI governance and compliance work we handle

Workstream 01Technology, IP & Data

Board oversight and AI strategy

  • Inventory and gap analysis
  • Framework design
  • Documents and training
  • Monitoring and updates
Workstream 02Technology, IP & Data

AI policies and acceptable use rules

  • Inventory and gap analysis
  • Framework design
  • Documents and training
  • Monitoring and updates
Workstream 03Technology, IP & Data

AI risk and impact assessments

  • Inventory and gap analysis
  • Framework design
  • Documents and training
  • Monitoring and updates
Workstream 04Technology, IP & Data

Data protection and automated decisions

  • Inventory and gap analysis
  • Framework design
  • Documents and training
  • Monitoring and updates
Workstream 05Technology, IP & Data

Workplace AI and employee monitoring

  • Inventory and gap analysis
  • Framework design
  • Documents and training
  • Monitoring and updates
Workstream 06Technology, IP & Data

Foreign AI rules and client requirements

  • Inventory and gap analysis
  • Framework design
  • Documents and training
  • Monitoring and updates
01

Board oversight and AI strategy

We brief boards and senior management on the legal and regulatory risks of AI, directors' duties in relation to technology decisions, and the questions a board should ask about AI projects. We help define governance structures, such as an AI steering committee or designated owner, set reporting lines and risk appetite, and prepare board papers that support informed decisions rather than box-ticking. We also help directors document their oversight.

02

AI policies and acceptable use rules

We draft AI policies, acceptable use rules for generative AI, procurement and approval procedures, and guidance for staff on confidential information, personal data, intellectual property and accuracy. Policies are tailored to the organisation's sector, size and actual use of AI, and written so that employees can follow them. We also prepare short training materials and help communicate the rules across the business. Policies are reviewed as tools change.

03

AI risk and impact assessments

We design templates for and carry out legal risk and impact assessments for AI systems, covering data protection, fairness and discrimination, transparency, accuracy, security, intellectual property and sector rules. For high-risk uses such as credit scoring, recruitment or health, we recommend controls such as human review, testing, documentation and monitoring, and we record decisions so that the organisation can explain them later to regulators, courts or customers.

04

Data protection and automated decisions

We advise on applying the Personal Data Protection Act 2026 to AI systems, including lawful basis, transparency notices, data minimisation, retention, security, data subject rights and cross-border transfers. Where AI is used to make or support decisions about individuals, we advise on explanation, human review and complaint handling, so that people affected by automated decisions are treated fairly and the organisation can defend its approach. Clear complaint routes are essential.

05

Workplace AI and employee monitoring

We advise employers on using AI in recruitment, performance management, productivity monitoring and workplace security, taking account of labour law, privacy, data protection and employee relations. We review notices, consent where relevant, proportionality and safeguards against discrimination, and draft policies that explain to staff how AI tools are used and how they can raise concerns or challenge outcomes. Trade union and works council issues are also considered where relevant.

06

Foreign AI rules and client requirements

We help Bangladeshi exporters, IT companies and outsourcing providers understand how the EU AI Act and other foreign rules may apply to their products and services, and respond to AI governance questionnaires and contractual requirements from foreign clients. Working with counsel abroad, we map obligations, identify gaps and prepare documentation that demonstrates responsible AI practices to customers and partners. This often strengthens tenders and renewals.

RecognitionThe Legal 500Asia Pacific ranks Tahmidur Remura Wahid (TRW) Law Firm for dispute resolution in Bangladesh.
Cross-border reach6 jurisdictionsMatters coordinated with counsel in the UK, US, UAE, China, India and Singapore.
Bar and admissionsDhaka and LondonBarristers and advocates in Bangladesh, with a solicitor of England and Wales (non-practising).
HeadquartersDhakaHouse 410, Road 29, Mohakhali DOHS. Consultations in person or by video.
Who leads this work

Partner-led, on every matter.

Technology, IP & Data matters at TRW are led by partners, supported by associates, with one responsible lawyer from first advice to final outcome.

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01

Is AI governance a legal requirement for businesses in Bangladesh?

There is no single statute that requires an AI governance programme as such, but several legal duties effectively require one. Directors must exercise care and diligence over material business decisions, data controllers must comply with the Personal Data Protection Act 2026, regulated firms must manage technology and outsourcing risk to their regulators' standards, and businesses remain liable for consumer, employment and IP breaches caused by their AI tools. A documented AI governance framework is the most practical way to show that those duties are being met. It also prepares the organisation for any AI-specific rules that may follow.

02

Where should a Bangladeshi business start with AI governance?

Start with a simple inventory of the AI tools and systems in use, including generative AI used by staff, AI features within existing software, and models built in-house or by vendors. Record what each tool does, what data it uses, who supplied it and which decisions it influences. Then classify uses by risk, appoint accountable owners, adopt a short AI policy and acceptable use rules, and set up an approval process for new tools. We help organisations complete these first steps quickly and then build out more detailed AI governance where the risk profile justifies it.

03

How does the Personal Data Protection Act 2026 affect AI systems and automated decisions?

The Act applies whenever an AI system processes personal data, whether in training, testing, prompting or producing outputs. Organisations need a lawful basis, clear notices, data minimisation, appropriate security, retention limits and processes for data subject rights. Profiling and automated decision-making raise particular concerns about transparency and fairness, and cross-border transfers to foreign AI providers must comply with the Act's transfer rules. Implementing regulations and guidance are still being developed, so we recommend aligning with the core principles now and adjusting as guidance is issued. Data protection is usually the backbone of AI governance in practice.

04

Does the EU AI Act apply to Bangladeshi software and outsourcing companies?

It can. The EU AI Act applies to providers placing AI systems on the EU market and, in some cases, to providers and deployers outside the EU whose AI outputs are used in the EU. A Bangladeshi software company selling an AI product to European customers, or an outsourcing provider whose AI-supported services are used in the EU, may therefore have obligations or face contractual requirements from EU clients. The obligations depend on the risk category of the system and the company's role. We work with EU counsel to assess exposure and build compliance into the company's AI governance.

05

What do regulators expect from banks and financial institutions using AI?

Bangladesh Bank expects banks and financial institutions to manage technology, information security, outsourcing and model risk, and to treat all customers fairly. Where AI is used in credit decisions, fraud detection, anti-money laundering screening or customer service, institutions should be able to explain how the model works, test it for accuracy and bias, keep humans involved in significant decisions and report incidents. Contracts with AI vendors should give the institution and its regulator audit and information rights. We help banks and financial institutions design AI governance frameworks that fit within their existing risk and compliance structures.

06

Can employees use ChatGPT and similar generative AI tools at work?

They can, if the organisation sets clear rules. Uncontrolled use of public generative AI tools can leak confidential information or personal data, produce inaccurate content and create intellectual property questions. Many organisations allow approved tools under enterprise terms with data protection commitments, prohibit entering confidential or personal data into public tools, require human review of outputs used externally and train staff on risks. We draft acceptable use policies and training that strike a balance between productivity and protection, and we review vendor terms to check how prompts and data are handled. Rules should be reviewed regularly.

07

Who is legally liable when an AI system causes harm in Bangladesh?

Liability usually rests with the organisation that deploys the AI system and makes or relies on its outputs, although it may sometimes be able to recover some losses from the vendor under the contract. Claims may arise in contract, negligence, consumer protection, data protection or employment law, depending on the harm. Bangladeshi courts have not yet developed a body of AI-specific case law, so general legal principles will apply. Strong AI governance, including testing, human oversight, records and appropriate contract terms, reduces both the chance of harm and the exposure if a claim is made.

08

How often should an AI governance framework be reviewed and updated?

At least annually, and whenever there is a significant change such as a new high-risk AI use, a new law or regulation, a major vendor change or an incident. AI technology and regulation are both moving quickly, and a framework that was adequate a year ago may no longer reflect how the organisation actually uses AI. We recommend a regular review cycle overseen by the accountable owner or committee, with reports to the board. We can carry out periodic legal reviews, update policies and contracts, and brief management on legal developments in Bangladesh and in key export markets.

How a matter runs

From first call to resolution.

  1. 01

    Inventory and gap analysis

    We work with the client to list all AI tools and uses, review existing policies, contracts and data practices, and then identify the main legal and regulatory gaps against Bangladeshi law and any relevant foreign requirements.

  2. 02

    Framework design

    We propose a proportionate AI governance structure, including roles, risk classification, approval steps, policies and contract standards, and agree priorities and timing with management and, where appropriate, the board. Existing compliance structures are reused wherever possible.

  3. 03

    Documents and training

    We draft the AI policy and acceptable use rules, assessment templates, vendor contract clauses and staff guidance, and deliver tailored briefings and training so that the framework is understood and used in practice.

  4. 04

    Monitoring and updates

    We support periodic AI governance reviews, assessments of new AI uses, incident response and regulator engagement, and then update the framework as Bangladeshi law, foreign rules and the client's use of AI develop.

“Demonstrates an extraordinary command over both domestic litigation and international arbitration.”

The Legal 500 Asia Pacific, Bangladesh: Dispute resolution, client feedback

FAQ

Questions, answered.

Still unsure? Email info@trw.co with a short outline of the matter.

What is AI governance?
AI governance is the set of policies, roles, processes, controls and contracts an organisation uses to make sure its artificial intelligence systems are lawful, safe, fair, secure and aligned with its objectives. It covers how AI tools are chosen, approved, tested, monitored and retired, who is accountable for them, and how risks and incidents are handled. Good governance supports rather than slows innovation by giving staff clear rules and management confidence. Without it, AI risk tends to be managed inconsistently.
Is there a national AI policy in Bangladesh that affects AI governance?
The government has worked on national AI policy and strategy documents for several years, focused on adoption, skills, ethics and public sector use. Policy documents guide government priorities but generally do not create binding legal obligations for private businesses in the way a statute does. We monitor policy and legislative developments and advise clients on how they may affect AI governance obligations in practice. Sector regulators may also issue their own AI guidance, which can carry real weight for regulated firms.
Do small and medium-sized businesses need AI governance?
Yes, but in proportion to their use of AI. A small business using a few generative AI tools may need only a short policy, a list of approved tools and basic staff guidance on confidential and personal data. Businesses using AI to make decisions about customers or employees, or operating in regulated sectors, need more. We tailor AI governance to the organisation's size, sector and risk profile. As use grows, the framework can be expanded step by step, without rebuilding it from the start.
What is an AI impact assessment?
An AI impact assessment is a structured review of a proposed AI system's purpose, data, design, risks and safeguards, focused on effects on individuals, the organisation and third parties. It typically covers data protection, fairness, transparency, accuracy, security and legal compliance, and records the decision to proceed, change or stop. It can be combined with a data protection impact assessment under the Personal Data Protection Act 2026. We prepare templates that business teams can complete themselves, with legal review reserved for higher-risk systems.
How does AI governance relate to cyber security?
AI systems can be targets of cyber attacks, such as data poisoning or prompt injection, and can also be used by attackers. AI governance should therefore be integrated with information security policies, access controls, vendor security reviews and incident response plans. Regulated firms should also consider their sector regulator's cyber security requirements and the obligations under Bangladeshi cyber security law. We help clients connect these functions so that security and AI governance teams share information and respond together when an incident occurs.
Can AI tools be used in recruitment and hiring in Bangladesh?
AI tools can support recruitment, but employers must ensure that screening and assessment do not discriminate unfairly, that candidates' personal data is handled in line with the Personal Data Protection Act 2026, and that significant decisions involve human judgment. Candidates should be told when AI is used. We review recruitment tools and processes and recommend safeguards. Vendors should be asked how their tools are tested for bias, how decisions can be explained and what records are kept, and contracts should reflect the answers.
What records should we keep as part of AI governance?
Useful records include the register of approved tools, the AI inventory, risk classifications, impact assessments, approval decisions, testing and monitoring results, vendor due diligence and contracts, training records and incident logs. These records help demonstrate compliance to regulators, auditors, customers and courts, and they also support continuous improvement of the governance framework. Records should be kept for a defined period, stored securely and reviewed regularly, so that they remain accurate and useful when questions arise. Gaps in records are very hard to fix later.
How can TRW & Co help with AI governance?
We help boards and management teams build practical AI governance frameworks, draft policies and contracts, carry out risk and impact assessments, and respond to regulators and clients. We also work with counsel in the UK, US, UAE, China, India and Singapore for international groups and exporters. To discuss your organisation's AI governance needs, please contact our Dhaka office. We will listen, explain the options and suggest a practical starting point.

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