That depends on whether Bangladesh Bank is currently inviting applications and on the terms it has set. The framework introduced in 2023 allowed applications within a defined process, and Bangladesh Bank has discretion over timing, numbers and conditions. Sponsors sometimes assume that an application can be filed at any time, which is not necessarily the case. We confirm the current position, and in the meantime help sponsors prepare their structure and records so that a credible digital bank proposal can be submitted promptly when an opportunity is available or when the framework is revised. Preparation time is rarely wasted.

Sponsors may include individuals and companies, including technology, telecom, financial and conglomerate groups, provided they meet Bangladesh Bank's eligibility requirements. These usually focus on integrity, financial capacity, legitimate source of funds, tax compliance and clean credit history, and there are restrictions linked to loan defaults. Rules on minimum and maximum shareholdings and on family or group concentration may also apply. Foreign sponsors face additional questions about investment and foreign exchange approvals. We review each proposed sponsor early, because one ineligible sponsor can undermine the whole digital bank application. Early checks save considerable time and cost.

Bangladesh Bank sets a minimum paid-up capital requirement for digital banks, which is lower than that for conventional scheduled banks but still substantial, and it can be revised. Capital must come from legitimate, documented sources and be paid in the form and at the time the regulator requires. Sponsors should also plan for capital beyond the minimum, because technology, staff, compliance and early losses usually require more funding than the regulatory floor. We advise on the current requirement and on documenting each sponsor's contribution so that it withstands Bangladesh Bank scrutiny. Capital planning should be conservative.

Not directly. A mobile financial service provider or payment service operator is licensed under a different framework from a bank, and a digital bank requires a banking licence under the Bank Company Act 1991. A group that owns an existing provider can usually sponsor or participate in a new bank, but the two businesses must be kept legally and operationally distinct, with clear arrangements for shared technology, data, staff and customers. Conflicts of interest and related-party transactions need careful governance. We advise groups on how the new entity and the existing business should interact while staying separate in practice.

Foreign participation is possible in principle, subject to Bangladesh Bank's rules on bank shareholding and the specific conditions of the digital bank framework. Foreign sponsors need to bring capital through recognised banking channels, document the source of funds, and satisfy fit-and-proper checks that may involve overseas regulators. Investment registration and any related filings now sit within the Invest Bangladesh framework, which replaced BIDA from 23 August 2026. We advise foreign investors on these steps and coordinate with their home-country counsel on approvals and reporting requirements in their own jurisdiction. Planning these steps ahead avoids delay.

These banks are intended to serve customers through digital channels rather than branches, and the framework has placed limits on certain activities, such as physical branch banking, over-the-counter services and some categories of large-ticket lending or trade services. The precise restrictions depend on the current guidelines and the terms of each licence. A business plan that relies on restricted activities will face questions. We review the proposed product range against the current rules, and help sponsors design a digital bank model that meets financial inclusion goals and stays within its permitted scope. Scope matters to the regulator.

Yes, but outsourcing does not move regulatory responsibility away from the bank. Bangladesh Bank expects the bank to retain control over critical systems and data, to carry out due diligence on vendors, to have audit and access rights, and to maintain business continuity if a provider fails. Data location and cross-border transfer questions arise under banking rules and the Personal Data Protection Act 2026. Outsourcing to a sponsor's own technology company raises related-party issues. We review cloud and vendor contracts for each digital bank so that they meet these expectations, with exit and data return rights.

A letter of intent or in-principle approval is usually conditional. The sponsors must typically incorporate the company, inject capital, appoint the board and senior management, put systems and policies in place and satisfy any other conditions within a stated period, before a final licence is issued. Bangladesh Bank may inspect systems and premises before launch. Missing a condition or deadline can lead to the approval lapsing. We help sponsors convert a letter of intent into an operating licence by preparing a condition tracker and coordinating the legal, technology and compliance workstreams.