No dedicated carbon capture and storage statute is currently in force in Bangladesh. Projects are therefore assessed under existing laws, including environmental clearance rules, petroleum and gas legislation, land laws, safety and explosives regulation and maritime zone legislation for offshore activity. This creates uncertainty on issues such as long-term liability and ownership of stored carbon dioxide, which specialist CCS laws in other countries address directly. We help sponsors identify the gaps and design contracts and government arrangements that manage them, and we monitor policy developments that could lead to specific rules. Policy can move quickly in this area.

A carbon capture project will normally require environmental clearance from the Department of Environment for the capture plant, pipelines and injection facilities, with the level of assessment depending on how the activity is categorised under the Environment Conservation Rules 2023. Large or higher-risk projects are likely to need site clearance, a full environmental impact assessment and an environmental management plan. Conditions often cover monitoring, emergency response and reporting. Existing facilities that add capture equipment may need a revised or amended clearance. We map the approval route early, because the assessment can drive the overall timetable.

Bangladesh law does not specifically allocate ownership of captured or stored carbon dioxide, so the answer depends largely on the contracts between the emitter, the transport operator and the storage operator, and on any arrangement with the state. Parties usually define when title and risk pass at each delivery point, who is liable for leakage and who may claim any carbon credits. Ownership of the storage formation itself raises separate questions, because subsurface resources are generally vested in the state. We draft these provisions carefully, because ambiguity here undermines financing and credit claims for any carbon capture project.

Possibly, but it requires careful legal and technical analysis. Depleted gas fields in Bangladesh are generally held by state-owned companies or operated under production sharing contracts with international oil companies, and they carry existing obligations on decommissioning and abandonment. Reusing a reservoir for storage would require agreement from the rights holder and the relevant government bodies, a clear allocation of liability between past production and future injection, and suitable permits. We advise on how these arrangements could be documented and which approvals would be needed, while engineers assess whether the reservoir is suitable. Data from past production is also important.

Liability for leakage, environmental damage and monitoring can continue long after injection stops. In many countries, specialist laws allow liability to transfer to the state after a closure period, often in return for financial security. Bangladesh has no equivalent statutory mechanism at present, so liability will be governed by general environmental law, tort principles and the contracts between the parties. Sponsors and lenders therefore need clear contractual caps, insurance where available, financial security arrangements and, ideally, a government agreement addressing closure. We help negotiate these protections and explain the residual risks honestly.

Carbon capture activity may generate credits under some voluntary standards or under cooperative approaches pursuant to Article 6 of the Paris Agreement, but eligibility depends on the methodology, the baseline, the permanence of storage and host-country authorisation where credits are transferred internationally. Bangladesh's position on authorising credits and corresponding adjustments affects their value. Credit revenue also brings monitoring, verification and reporting obligations that must be reflected in project documents. We advise on the legal steps for credit eligibility and transfer and coordinate with technical and carbon market specialists on methodology. Credit rights should be allocated in writing.

Where a carbon capture project involves foreign investment, an economic zone location, a public-private partnership or investment incentives, Invest Bangladesh is likely to be relevant. Created under the Invest Bangladesh Act 2026, it has operated since 23 August 2026 and took over the functions of BIDA, BEZA and the PPP Authority. The Department of Environment, the energy ministry, Petrobangla and other sector bodies remain responsible for their own approvals. We help foreign investors understand how registration, incentives and sectoral consents fit together, and which bodies need to be engaged first. Early, coordinated engagement avoids duplicated filings.

A typical chain needs a capture services or offtake agreement with the emitter, a transport agreement covering pipeline or shipping, a storage agreement with the injection operator, EPC and operation and maintenance contracts for each facility, technology licences and equipment supply contracts, and financing and security documents. Interface agreements are critical, because a failure at one link affects all others. Key provisions include carbon dioxide specifications, capacity and curtailment, liability caps, insurance, change in law and dispute resolution, typically through arbitration for cross-border contracts. We draft these documents so that they work together.