Fintech, Payments and PSP Licensing in Bangladesh

by Barrister Tahmidur Rahman | Sep 8, 2026

Technology, IP & DataPayments licensing with fewer surprises9 min read

Fintech, Payments and PSP Licensing in Bangladesh

Advice on PSP licensing, payment system operator approvals and fintech regulation in Bangladesh for e-wallets, payment gateways, aggregators, mobile financial services, digital lenders and foreign payment companies: structuring, Bangladesh Bank applications, bank partnerships, foreign investment and ongoing compliance after launch, inspections and disputes.

Overview

How PSP licensing and fintech regulation work in Bangladesh

Bangladesh has one of the most active digital payments markets in South Asia, built on mobile financial services, bank apps, card networks, payment gateways and a growing number of e-wallets. Every business that moves customer money needs to understand where it sits in Bangladesh Bank's regulatory perimeter. Our fintech practice advises start-ups, banks, telecom groups, e-commerce businesses and foreign payment companies on PSP licensing, payment system operator approvals, partnerships and compliance. We combine regulatory, corporate and technology expertise, and this work sits within our technology, IP and data practice in Bangladesh, alongside our banking and finance team.

The Payment and Settlement Systems Act 2024 gives Bangladesh Bank a modern statutory basis for licensing and supervising payment systems and payment service providers. Broadly, payment system operators run infrastructure such as switches, clearing systems and gateways that connect institutions, while payment service providers offer services such as e-wallets and payment initiation directly to users. Bangladesh Bank sets conditions on capital, ownership, governance, technology, safeguarding of customer funds, consumer protection and reporting, and issues licences with specific conditions attached. PSP licensing therefore requires a business that can show it is safe to hold and move public money.

Mobile financial services remain a separate and significant category, with their own regulations, typically led by banks or bank subsidiaries, and agent networks that bring services to rural areas. Digital banks are licensed under a separate Bangladesh Bank framework, and non-bank lenders, microfinance institutions and insurers have their own regulators. Many fintech models touch several of these regimes at once. A buy-now-pay-later product, for example, may involve payments, credit, consumer protection and data rules. We map each model against the full perimeter so that clients choose the right licence, partner with the right institution or redesign the product where needed.

Foreign payment companies face additional questions. Bangladesh Bank rules on ownership, foreign exchange, remittances and cross-border settlement, together with foreign investment registration through Invest Bangladesh, shape how an international business can enter. Some choose a local subsidiary seeking its own licence, others partner with a licensed bank or PSP, and some focus on inward remittances through approved channels. The Personal Data Protection Act 2026 and cyber security legislation add obligations on customer data and system security. We advise on the most practical entry route, prepare PSP licensing applications and negotiate partnership agreements regulators accept. Allow for regulatory review.

Barrister Tahmidur Rahman leads our transactions, finance and investment work, and Barrister Remura Meheruba Mahbub advises on banking, corporate and foreign investment matters, including fintech fundraising and joint ventures. We work with counsel in the UK, US, UAE, China, India and Singapore where groups operate across several markets. Beyond licensing, we support product launches, agent and merchant agreements, card and gateway contracts, regulatory inspections and disputes. To discuss PSP licensing, a partnership or a new product, contact our Dhaka office and we will arrange an initial review of your model. Early PSP licensing advice often shortens the overall timetable.

01 · What we handle

Core workstreams

  • Perimeter and licence strategy
  • PSP licensing applications
  • Bank and partner agreements
  • Merchant, agent and user terms
02 · How it runs

Four clear stages

  1. 01Model and perimeter review
  2. 02Application preparation
  3. 03Regulator engagement
  4. 04Launch and compliance
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

What we handle

Workstream 01Technology, IP & Data

Perimeter and licence strategy

  • Model and perimeter review
  • Application preparation
  • Regulator engagement
  • Launch and compliance
Workstream 02Technology, IP & Data

PSP licensing applications

  • Model and perimeter review
  • Application preparation
  • Regulator engagement
  • Launch and compliance
Workstream 03Technology, IP & Data

Bank and partner agreements

  • Model and perimeter review
  • Application preparation
  • Regulator engagement
  • Launch and compliance
Workstream 04Technology, IP & Data

Merchant, agent and user terms

  • Model and perimeter review
  • Application preparation
  • Regulator engagement
  • Launch and compliance
Workstream 05Technology, IP & Data

AML, data and cyber compliance

  • Model and perimeter review
  • Application preparation
  • Regulator engagement
  • Launch and compliance
Workstream 06Technology, IP & Data

Investment, M&A and disputes

  • Model and perimeter review
  • Application preparation
  • Regulator engagement
  • Launch and compliance
01

Perimeter and licence strategy

We analyse the product, money flows and customer journey to decide whether the business needs a PSP or PSO licence, falls under mobile financial services or digital bank rules, or can operate through a licensed partner. Our perimeter memos explain the reasoning, the risks of each route and the timeline, so that founders, boards and investors can make an informed decision before committing capital and launching. Each memo is updated as rules change.

02

PSP licensing applications

We prepare and manage PSP licensing and payment system operator applications to Bangladesh Bank, including corporate documents, business plans, governance and fit-and-proper information, technology and security descriptions, risk management frameworks and policies on safeguarding customer funds. We respond to regulator queries, attend meetings where appropriate and help clients satisfy licence conditions before launch and during the early months of operation. Strong PSP licensing files anticipate the regulator's likely questions.

03

Bank and partner agreements

Most payment models rely on banks for settlement, safeguarding accounts and card or account access. We draft and negotiate sponsorship, settlement, escrow, agency and white-label agreements between fintechs, banks, MFS providers and international payment networks. Key terms include responsibility for compliance, customer due diligence, fraud losses, chargebacks, data sharing, service levels, exclusivity, fees and exit arrangements when the relationship ends. Partner terms often decide PSP licensing outcomes in practice.

04

Merchant, agent and user terms

We prepare customer terms, merchant agreements, agent contracts and fee disclosures that reflect Bangladesh Bank requirements and consumer protection expectations. We advise on complaint handling, dispute resolution for failed or unauthorised transactions, transaction limits, dormant accounts and refunds, so that documents are clear for users and robust when tested by regulators, customers, merchants or agents in a dispute. Bangla versions are prepared where customers need them. Templates are updated when Bangladesh Bank issues new circulars or guidance.

05

AML, data and cyber compliance

Payment businesses must meet anti-money laundering and counter-terrorist financing obligations, including customer due diligence, transaction monitoring and suspicious transaction reporting to the BFIU. We help design compliance programmes, e-KYC journeys and sanctions screening, and advise on the Personal Data Protection Act 2026, cyber security legislation, incident reporting and the security expectations Bangladesh Bank applies to licensed payment businesses. Programmes are tested before launch and before inspections. Weaknesses found in testing are corrected and documented before applications or inspections.

06

Investment, M&A and disputes

We advise fintechs and investors on fundraising, foreign investment registration, share transfers requiring regulatory approval, joint ventures with banks or telecom groups, and acquisitions of licensed businesses. We also represent payment businesses in regulatory inspections, enforcement proceedings, disputes with partners and merchants, and customer claims, coordinating with our disputes team and foreign counsel where needed. PSP licensing conditions are built into every transaction timetable. Exit routes, such as share sales or buy-outs, are considered at the outset so that approvals are not a late surprise.

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

Which law governs PSP licensing and payment regulation in Bangladesh?

The Payment and Settlement Systems Act 2024 is the main statute. It empowers Bangladesh Bank to license, regulate and supervise payment systems, payment system operators and payment service providers, and to issue regulations, circulars and licence conditions. Other rules also apply depending on the model, including regulations on mobile financial services, foreign exchange rules, anti-money laundering law, the Personal Data Protection Act 2026 and cyber security legislation. Because Bangladesh Bank issues detailed requirements through circulars that change over time, we confirm the current position at the start of every PSP licensing project and track updates through the process.

02

What is the difference between a PSO and a PSP licence in Bangladesh?

In general terms, a payment system operator runs infrastructure that connects banks and other institutions, such as switching networks, clearing arrangements or payment gateways used by multiple participants. A payment service provider offers payment services directly to customers or merchants, such as e-wallets, payment initiation or merchant acquiring. The distinction matters because the licence category, capital, governance and operational requirements differ. Some businesses perform both roles. We review the business model and its intended services to identify the correct category and avoid applying for a licence that does not fit the activities planned. Mixed models need careful analysis.

03

How long does PSP licensing take in Bangladesh from application to launch?

There is no fixed timetable that applicants can rely on. The process usually involves preparing the application, responding to Bangladesh Bank queries, possibly receiving an in-principle approval with conditions, then completing technical, capital and governance requirements before final permission to operate. Timing depends on the quality of the application, the complexity of the model, ownership structure, the regulator's workload and policy priorities. Well-prepared applications with clear answers on safeguarding, technology and compliance tend to progress more smoothly. We help clients plan for each stage and set realistic expectations with investors and partners. Delays often stem from incomplete answers.

04

Can a foreign company obtain a PSP licence or own a fintech business in Bangladesh?

Foreign investment in Bangladeshi fintech is possible, but ownership, control and licensing questions need careful planning. Bangladesh Bank considers the identity and standing of shareholders, the source of funds and the governance of applicants, and specific rules may affect foreign shareholdings in particular licence categories. Foreign exchange rules govern capital injection, fees and repatriation of profits, and investment must be registered with Invest Bangladesh. Some foreign groups partner with local banks or licensed providers instead. We advise on structures that work for both the regulator and the group, and on PSP licensing strategy for foreign-owned applicants.

05

Do we need a licence to operate a payment gateway or merchant aggregator?

Usually some form of authorisation is required if the business collects or settles funds on behalf of merchants, connects to banking or card infrastructure, or holds customer money. Depending on the model, a gateway may need its own licence under the 2024 Act or may operate through a licensed bank or payment provider under a partnership arrangement. Technical service providers that never touch funds may sit outside the perimeter, but the line is narrow. We review flows of funds and data, because small design choices can change the licensing outcome. Control of funds before settlement often decides the outcome.

06

How must customer funds be protected by a licensed PSP in Bangladesh?

Bangladesh Bank expects customer funds held by payment service providers to be kept separate from the provider's own money, typically in designated accounts with scheduled banks, and to be available to meet customer claims at all times. Rules also address reconciliation, use of funds, interest, record-keeping and what happens if the provider fails. Safeguarding is one of the most closely examined areas in PSP licensing and supervision. We help design safeguarding arrangements, draft trust or escrow account agreements with banks and prepare policies that satisfy both regulators and partner banks. Weak safeguarding often delays approval.

07

Can a fintech offer lending or buy-now-pay-later products in Bangladesh legally?

Lending is regulated separately from payments. Banks and licensed financial institutions can lend, and digital banks operate under their own framework, but a payment provider generally cannot extend credit unless permitted. Many fintechs therefore partner with banks or finance companies, providing the technology and customer interface while the licensed lender provides credit. Such arrangements need clear allocation of regulatory responsibility, customer disclosures, data sharing and collections practices. We advise on structures that keep fintechs on the right side of lending and payment rules while delivering a seamless product to customers. PSP licensing alone does not permit lending.

08

What ongoing obligations apply after PSP licensing is granted?

A licence brings continuing obligations. Licensed providers must comply with licence conditions, maintain capital and governance standards, file reports, safeguard funds, meet anti-money laundering and cyber security requirements, handle complaints and obtain approval before significant changes such as new products, changes of control or outsourcing of key functions. Bangladesh Bank may inspect and can impose penalties or restrictions for breaches. We provide ongoing regulatory support, compliance reviews, training and help with inspections, so that the value created through PSP licensing is not lost through later compliance failures. Yearly reviews catch drift from licence conditions. Records should be kept current.

How a matter runs

From first call to resolution.

  1. 01

    Model and perimeter review

    We examine the product, money flows, customer journey, partners and ownership, then advise on whether PSP licensing, another licence or a partnership model is the right route, with an outline timeline and requirements.

  2. 02

    Application preparation

    We prepare the application package, including corporate documents, business plan, governance and fit-and-proper information, policies, safeguarding arrangements and technology descriptions, and coordinate input from founders, auditors and technical teams. Gaps are fixed before filing.

  3. 03

    Regulator engagement

    We submit the application, manage Bangladesh Bank queries and meetings, help satisfy in-principle conditions and negotiate partner agreements with banks, networks and vendors required before the business can launch. Each query is tracked to closure.

  4. 04

    Launch and compliance

    We support go-live with customer terms, merchant and agent agreements, compliance manuals and training, then provide ongoing advice on reporting, inspections, product changes, investment and disputes after launch. PSP licensing conditions are monitored throughout.

“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.

Is PSP licensing required to launch an e-wallet service in Bangladesh?
Generally yes. An e-wallet that holds customer value and allows payments or transfers is a core payment service, and Bangladesh Bank grants licences for such services under the Payment and Settlement Systems Act 2024. The licence carries specific conditions on operations, safeguarding and compliance. Some e-wallet models are instead run by banks or MFS providers under their own authorisations. We help clients decide which route fits their business. Our PSP licensing advice compares those routes on cost, timing and control.
Can a non-bank company operate mobile financial services in Bangladesh?
Mobile financial services have traditionally been bank-led, operated by banks or their subsidiaries under Bangladesh Bank's MFS regulations, with specific rules on ownership, agents, transaction limits and safeguarding. Policy in this area has evolved over time, so current requirements should be checked for any new entrant. Non-bank businesses often participate as technology providers, distributors or partners. We advise on the options available under the current rules. Partnership terms need careful drafting to protect both sides. Agent network rules also apply.
Do cross-border remittance services need Bangladesh Bank approval to operate?
Yes. Inward remittances must flow through approved channels, usually banks and authorised partners, and remittance companies abroad typically work through drawing arrangements with Bangladeshi banks or licensed providers. Outward remittances are tightly controlled under foreign exchange rules. Digital remittance models must fit within these channels. We advise international remittance companies and local partners on structures, agreements and the approvals required. Compliance with anti-money laundering rules and reporting duties is essential throughout every remittance arrangement. Partner banks will ask for this.
How much capital is needed for PSP licensing in Bangladesh?
Capital requirements are set by Bangladesh Bank and differ by licence category, and they can change through regulations and circulars. Beyond minimum paid-up capital, the regulator considers whether the business has enough resources for technology, security, staffing and growth, and whether shareholders can support it if needed. We confirm the current requirements at the start of each engagement and help prepare credible financial projections. Capital must also be maintained after launch, not only at application. Shortfalls can trigger regulatory action.
Are cryptocurrencies allowed for payments or wallets in Bangladesh?
Bangladesh Bank has repeatedly warned the public against dealing in virtual currencies, noting that they are not authorised as legal tender and that transactions may breach foreign exchange and anti-money laundering laws. Payment businesses should not offer crypto services without clear legal advice. Blockchain technology for other purposes, such as record-keeping, raises different questions. We advise on the current position and on lawful alternatives. Reputational risk with partner banks is also significant. Any product touching virtual assets should be reviewed with us before partner banks are approached.
Can a licensed fintech use cloud services hosted abroad?
Possibly, but Bangladesh Bank has expectations on outsourcing, data location, security and regulatory access, and the Personal Data Protection Act 2026 sets conditions on transferring personal data abroad. Some data or systems may need to remain in Bangladesh. Licensed businesses may need to notify or obtain approval for material outsourcing. We review hosting plans and contracts so that technology choices do not create licensing problems. Cloud questions often arise during PSP licensing reviews. Contracts with cloud providers should also cover access to data and orderly transfer if the arrangement ends.
Do changes in shareholding of a licensed PSP need regulatory approval?
For licensed payment businesses, significant changes in shareholding, control or management typically need prior approval from Bangladesh Bank, and licence conditions often specify thresholds. Investors should build approval conditions into transaction documents and allow time for the process. Completing a deal without required approval can put the licence at risk. We advise on approval requirements in fundraising rounds, secondary sales and acquisitions. Licence conditions should be checked before any term sheet is signed. Approval timetables can move, so completion conditions should allow for an extension.
How do you charge for PSP licensing and fintech regulatory work?
Fees depend on the scope, the complexity of the model and the stage of the business, and we agree them in writing before work begins. Many clients start with a perimeter and strategy review, which helps define the work needed for an application. Contact our Dhaka office on +880 1708 000660 or info@trw.co to discuss your project and receive a proposal suited to your plans. Clear scoping keeps costs predictable. We respond promptly to new enquiries.

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