Aviation Regulation & Airport Projects in Bangladesh

by Barrister Tahmidur Rahman | Sep 13, 2026

Projects & Real EstateAirports, airlines and approvals8 min read

Aviation Regulation & Airport Projects in Bangladesh

Aviation regulation and airport project advice for airlines, ground handlers, investors, contractors and lenders working in or with Bangladesh in 2026: CAAB permissions, operating agreements, concessions, airport finance, construction contracts and the practical regulatory questions that decide whether a project can actually fly.

Overview

How we approach aviation regulation and airport work in Bangladesh

Bangladesh aviation is growing quickly in 2026, with more passengers, new terminal capacity, expanding cargo traffic and fresh interest from foreign carriers and service providers. That growth brings a dense layer of aviation regulation. The Civil Aviation Authority of Bangladesh (CAAB) is both the safety regulator and the operator of most of the country's airports, which makes the relationship between a business and the regulator unusually important. We advise airlines, ground handlers, cargo operators, maintenance providers, investors and contractors on the permissions, contracts and risk allocation behind an aviation business or airport project in Bangladesh.

Our starting point is always the commercial goal. A foreign airline seeking new routes faces different questions from a fund looking at an airport concession, a contractor bidding for terminal works or a logistics company planning a cargo village. For each, we identify which permissions are needed, who grants them, which documents the regulator will expect and which issues can be negotiated. Aviation regulation in Bangladesh is shaped by the Civil Aviation Act 2017, rules and directives made under it, international standards set through ICAO and the bilateral air services agreements Bangladesh has signed with other states.

Airport projects add a further dimension. Terminal, cargo, fuel farm and hangar developments usually involve government land, public procurement or a public-private partnership structure, environmental approvals and complex construction documentation. Since 23 August 2026, the investment promotion and PPP functions previously held by BIDA, BEZA and the PPP Authority sit with Invest Bangladesh under the Invest Bangladesh Act 2026. We help sponsors and lenders understand how that new institutional map interacts with CAAB, the Ministry of Civil Aviation and Tourism and the aviation regulation framework on an airport project.

Aviation regulation does not stop at the airport fence. Aircraft leasing and finance, customs treatment of spare parts, foreign exchange rules on lease rentals and remittances, withholding tax on payments to non-residents and work permits for foreign pilots and engineers all affect the economics of an aviation business. We coordinate these strands so that a client sees one joined-up view, and we work closely with colleagues across our projects and real estate practice and our regulatory practice where a matter needs both.

The result is a plan reflecting how aviation regulation, tax and finance rules actually interact on the ground.

Where questions go beyond Bangladesh law, for example the English-law terms of an aircraft lease, a foreign licensing regime or an international financing, we work with counsel in the UK, US, UAE, China, India and Singapore and keep the boundaries between jurisdictions clear. Our name partners bring experience in transactions, project finance, foreign investment and international arbitration, which matters when an aviation dispute or a concession disagreement needs to be resolved. We describe options plainly and candidly, flag what depends on regulatory discretion and help clients plan realistic timetables for approvals that cannot simply be bought with urgency.

01 · What we handle

Core workstreams

  • Airline and foreign operator permissions
  • Airport concessions and PPP
  • Ground handling and services
  • Aircraft leasing and finance
02 · How it runs

Four clear stages

  1. 01Define the objective
  2. 02Map the approvals
  3. 03Negotiate the documents
  4. 04Support delivery
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

Where we help aviation and airport clients

Workstream 01Projects & Real Estate

Airline and foreign operator permissions

  • Define the objective
  • Map the approvals
  • Negotiate the documents
  • Support delivery
Workstream 02Projects & Real Estate

Airport concessions and PPP

  • Define the objective
  • Map the approvals
  • Negotiate the documents
  • Support delivery
Workstream 03Projects & Real Estate

Ground handling and services

  • Define the objective
  • Map the approvals
  • Negotiate the documents
  • Support delivery
Workstream 04Projects & Real Estate

Aircraft leasing and finance

  • Define the objective
  • Map the approvals
  • Negotiate the documents
  • Support delivery
Workstream 05Projects & Real Estate

Airport construction and terminal works

  • Define the objective
  • Map the approvals
  • Negotiate the documents
  • Support delivery
Workstream 06Projects & Real Estate

Compliance, safety and disputes

  • Define the objective
  • Map the approvals
  • Negotiate the documents
  • Support delivery
01

Airline and foreign operator permissions

We advise domestic and foreign carriers on the permissions needed to operate in and out of Bangladesh, including foreign operator permits, route approvals, slot and schedule filings and the documents CAAB is likely to request. We map how bilateral air services agreements, designation by the home state and local aviation regulation requirements fit together, and we help prepare clear, consistent submissions that reduce avoidable queries and delay. We also keep a diary of permit expiry and renewal dates so that operations are not interrupted by a lapsed approval.

02

Airport concessions and PPP

For terminal, cargo, hangar and commercial concessions, we review tender documents, concession agreements and lease terms, and advise on bidding consortium arrangements, step-in rights, termination payments, tariff controls and revenue risk. We explain how Invest Bangladesh, CAAB and the line ministry interact on a public-private partnership and where government-to-government arrangements may displace an open tender, so sponsors can price risk realistically. We also review land lease terms.

03

Ground handling and services

Ground handling, catering, fuelling, security screening and cargo services at Bangladesh airports involve licensing, access and commercial arrangements with the airport operator and incumbent providers. We advise on market entry, licence conditions, service level agreements, standard ground handling agreement terms and liability allocation, and we help clients understand how aviation regulation and security requirements shape what a service provider may and may not do. Exclusivity terms are reviewed carefully.

04

Aircraft leasing and finance

We act on the Bangladesh side of aircraft operating and finance leases, engine leases and spare parts financing. This covers registration and deregistration questions, export of lease rentals and maintenance reserves through the banking system, withholding tax on payments to foreign lessors, security filings, aviation regulation points affecting airworthiness records and the practical steps lessors take to protect repossession rights if an operator gets into financial difficulty.

05

Airport construction and terminal works

Airport construction is technically demanding and often runs alongside live operations. We review EPC and design and build contracts, FIDIC-based conditions, airside access protocols, insurance and bonding requirements and interface agreements between contractors, consultants and the airport operator. We also help contractors and employers manage variations, delay events, performance guarantees and claims, and coordinate with our dispute team where positions start to harden. Site safety and environmental conditions are covered too.

06

Compliance, safety and disputes

When an aviation business faces an inspection finding, a suspension notice, a passenger claim or a commercial dispute with an airport or counterparty, we assess the legal position quickly and plan a response. We advise on regulatory correspondence, corrective action plans, administrative review, writ proceedings before the High Court Division where appropriate, arbitration under concession or lease terms, and settlement strategies that protect operations. Where possible we seek interim arrangements that keep flights, handling or construction running while the underlying dispute is resolved.

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.

Projects & Real Estate matters at TRW are led by partners, supported by associates, with one responsible lawyer from first advice to final outcome.

Meet the firm →
01

Who is responsible for aviation regulation in Bangladesh?

The Civil Aviation Authority of Bangladesh is the main body responsible for aviation regulation, covering safety oversight, licensing of operators and personnel, air navigation services and the operation of most airports. Policy sits with the Ministry of Civil Aviation and Tourism, which also handles air services negotiations with other states. Other agencies matter on specific points: customs for parts and cargo, Bangladesh Bank and authorised dealer banks for foreign exchange, the tax authorities for withholding and VAT, and Invest Bangladesh for foreign investment. We help clients identify the relevant bodies early and confirm in writing which one decides each point.

02

How does a foreign airline start scheduled flights to Bangladesh?

In outline, the airline's home state usually designates it under the bilateral air services agreement with Bangladesh, and the airline then applies to CAAB for the relevant foreign operator permission, supported by its air operator certificate, insurance, security programme and operational documents. Schedules and slots must then be approved. Commercial steps run alongside, including ground handling, fuel supply, sales agency and banking arrangements for remitting revenue. Timing depends on the bilateral position, capacity entitlements and how complete the application is. We review the full document set and help the airline anticipate the questions aviation regulation will raise.

03

Can a foreign investor own a Bangladeshi airline or aviation business?

Foreign ownership in aviation businesses is possible in some segments but is subject to policy limits, licensing conditions and the ownership and control tests that apply to national carriers under air services agreements. A scheduled passenger airline raises different aviation regulation issues from a maintenance organisation, a flight school or a ground handling company. The position also depends on current investment policy, which Invest Bangladesh now administers. Because the rules can change and are applied case by case, we review the latest policy, the intended structure and any shareholder protections before a client commits capital to the business.

04

How are airport projects procured in Bangladesh, and who approves them?

Airport projects may be procured as conventional public works funded by the government or development partners, as public-private partnerships, or through government-to-government arrangements with a foreign state and its nominated companies. Each route has a different legal basis, approval chain and level of competition. Public-private partnership projects now run through Invest Bangladesh, which absorbed the former PPP Authority in August 2026, while CAAB remains responsible for aviation regulation and airport operations. We help bidders and sponsors understand the procurement route, the approvals behind it and the contractual protections that are realistic in that context. Bidders should check this first.

05

What licences does a ground handling or air cargo company need in Bangladesh?

A ground handling or cargo operator generally needs a company properly established in Bangladesh, the relevant authorisation from CAAB as airport operator and regulator, security clearances for personnel and vehicles, and commercial agreements with airlines and the airport. Cargo businesses also deal with customs licensing, bonded warehouse rules where applicable and dangerous goods requirements under aviation regulation. Trade licences, tax registration and fire and environmental approvals for facilities may also apply. The list depends on the services and airport concerned, so we prepare a licence map with expiry dates before operations begin.

06

What aviation regulation issues arise when leasing aircraft to a Bangladeshi airline operator?

Lessors usually focus on registration and deregistration of the aircraft, the enforceability of repossession and export rights, the operator's ability to remit rentals and maintenance reserves in foreign currency, withholding tax on lease payments and the treatment of insurance and reinsurance. Aviation regulation also affects airworthiness, maintenance records and the operator's approvals, which influence value at return. We advise on the Bangladesh-law aspects, including powers of attorney and deregistration documents, and coordinate with the lessor's English or New York counsel on the main lease. Check return conditions at the outset, as they decide how smoothly the aircraft is redelivered.

07

Can disputes on airport construction projects in Bangladesh be arbitrated?

Yes, where the contract contains an arbitration agreement. Many airport construction contracts include dispute boards or engineer determinations followed by arbitration, which may be seated in Dhaka or abroad. Arbitrations seated in Bangladesh are governed by the Arbitration Act 2001, and foreign awards can be enforced in Bangladesh under the New York Convention framework. Public works contracts may have their own dispute provisions, and the Commercial Courts Act 2026 may be relevant to court proceedings. Notice requirements and time bars in the contract are often decisive, so we review them as soon as a dispute appears.

08

How long do aviation regulation approvals usually take?

There is no single answer. Some approvals turn on routine documentary review, while others involve inspections, inter-agency consultation, security clearance or negotiations between governments. Incomplete or inconsistent applications are the most common cause of delay in aviation regulation matters. We do not promise fixed timetables for regulatory decisions, but we help clients build a realistic plan by sequencing filings, preparing documents to the regulator's expected standard and identifying which approvals sit on the critical path for the commercial launch, the start of construction or financial close. Building in contingency for queries is sensible.

How a matter runs

From first call to resolution.

  1. 01

    Define the objective

    We start with a short scoping discussion about the business, the asset or route, the counterparties and the deadline, then confirm which questions involve Bangladesh aviation regulation and which need advice from foreign counsel. A clear scope keeps costs proportionate.

  2. 02

    Map the approvals

    Together with your team, we prepare a practical, written map of permissions, regulators, documents and dependencies, showing which approvals affect each other and which ones sit on the critical path for operational launch, construction start or financial close.

  3. 03

    Negotiate the documents

    We draft and negotiate concession, lease, handling, construction and finance documents, aligning commercial terms with what aviation regulation, investment policy and public procurement rules actually permit in Bangladesh. Regulatory approval conditions are carried directly into the drafting.

  4. 04

    Support delivery

    After signing and throughout operations, we help with filings, regulatory correspondence, compliance reviews and change requests, and we act quickly if an inspection, a payment problem or a commercial dispute threatens the operation or the project timetable. Our team can also keep a diary of renewals and reporting dates so that obligations are met on time.

“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.

Which law governs aviation regulation in Bangladesh?
The Civil Aviation Act 2017 is the main statute, supported by rules, air navigation orders and directives issued by CAAB. Bangladesh is a member of ICAO, so international standards strongly influence local aviation regulation and inspections. Bilateral air services agreements govern traffic rights between Bangladesh and other states. Related areas such as customs, tax, foreign exchange, labour and investment are governed by their own laws, which an aviation business must also observe when planning operations. We track changes to these rules closely.
Is CAAB both regulator and airport operator?
Yes. CAAB regulates safety and air navigation and also operates most airports in Bangladesh. This dual role means a business may negotiate commercial terms with the same body that grants its permissions. We help clients keep regulatory filings and commercial negotiations organised and consistent, and we watch for any policy moves towards separating regulatory and operational functions, which would change how aviation regulation applies to future airport projects and concessions. We keep both channels documented. Consistent records help in both.
Does Invest Bangladesh have a role in airport projects?
It can. Invest Bangladesh, created by the Invest Bangladesh Act 2026, took over the functions of BIDA, BEZA and the PPP Authority from 23 August 2026. It is relevant where a project involves foreign investment registration, a public-private partnership or investment incentives. CAAB and the Ministry of Civil Aviation and Tourism remain central to the aviation-specific aspects of any airport project, including safety, security and airport operating conditions. We help coordinate both channels. Where both are involved, keep copies of each approval, because lenders and counterparties will usually ask to see them.
Do you advise on drone operations?
Yes. Unmanned aircraft operations in Bangladesh require permissions from CAAB and may need security clearance from other authorities, particularly near airports, sensitive installations or in dense urban areas. Requirements vary with the purpose, the aircraft and the location. We help businesses understand current aviation regulation requirements, prepare applications and build compliance procedures for commercial drone survey, inspection, agriculture and media work, including record keeping and insurance. Rules in this area are changing, so we check current aviation regulation requirements for each mission.
Can you help with an aviation regulation enforcement notice?
Yes. We review the notice, the underlying finding and the operational impact, then advise on the response, any corrective action plan and the options for administrative review or court challenge. Early, accurate engagement with the regulator often achieves more than a confrontational stance, but where a decision is unlawful, procedurally unfair or disproportionate we advise on writ proceedings before the High Court Division and on urgent interim relief. Deadlines for a challenge can be short, so clients should act quickly.
How are payments to foreign lessors and suppliers taxed?
Payments to non-residents are generally subject to withholding tax, with rates depending on the nature of the payment and any applicable double tax treaty. Under the Finance Act 2026, withholding on interest paid to non-residents is 10%, reduced from 20%. Lease rentals, service fees, maintenance payments and royalties may be treated differently, so we review the payment flows early and coordinate with the client's tax advisers before contracts are signed. Treaty relief usually requires supporting documents, which take time to obtain.
Do you work with foreign aviation counsel?
Yes, where a matter needs it. Many aviation transactions are governed by English or New York law, and many regulatory questions involve the home state of an airline or lessor. We work with counsel in the UK, US, UAE, China, India and Singapore, handling the Bangladesh-law and local aviation regulation aspects ourselves and keeping each adviser's scope clear so that nothing important falls between jurisdictions. A single coordinated timetable helps keep a cross-border transaction on track for signing and delivery.
How do we start a matter on aviation regulation with TRW & Co?
Contact our Dhaka office with a short description of the business, the project or the issue and any deadlines. We will confirm conflicts, agree a scope and fee basis, and identify the documents we need to review first. You can reach us on +880 1708 000660, at info@trw.co or through our contact page, and we will respond promptly. Initial calls are used to understand the matter and agree next steps. We can usually meet in person or by video.

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