TRW Insight / Bangladesh
A tenderer in Bangladesh has seven days to complain, three administrative tiers to climb and one appeal to a BPPA Review Panel. The Public Procurement Rules 2025 reset the deadlines and fees, and the High Court Division polices every step.
Procurement complaint review panel Bangladesh: the 2026 framework
A bidder who wants to use the procurement complaint review panel Bangladesh law provides has a short statutory road and very little room for error. Sections 29 and 30 of the Public Procurement Act 2006 give the right to complain and to appeal, and Part 12 of the Public Procurement Rules 2025 now fixes the tiers, the deadlines, the fees and the powers of the Review Panel. The Public Procurement (Amendment) Act 2026 confirmed the reformed framework with effect from 28 September 2025.
This guide is about the challenge itself: who may complain and on what grounds, how the three administrative tiers work, how to lodge an appeal with the Bangladesh Public Procurement Authority (BPPA), what the Review Panel can and cannot order, how e-GP changes the timing, when the panel has jurisdiction over projects financed by development partners, and how the High Court Division reviews panel decisions in writ. The wider procurement reforms are covered in our companion guides, which we link rather than repeat.

Summary: A tenderer must complain in writing within 7 calendar days of learning of the problem, first to the officer who issued the tender document, then to the head of the procuring entity, then to the Secretary of the ministry or division. Only after those tiers are exhausted can it appeal to a BPPA Review Panel, with a registration fee and a refundable security deposit scaled to contract value. The panel must decide within 12 working days, its decision is final within the procurement, and the High Court Division can review it under article 102 of the Constitution.
Key point: Time is the decisive factor. Under Schedule 2 of the Public Procurement Rules 2025, each escalation window is only 3 working days, and in Shohoz-Synesis-Vincen JV v CPTU the High Court Division set aside a Review Panel decision because the first complaint did not show it was made within 7 calendar days of knowledge. A complaint that is late at tier one cannot be rescued on appeal.
At a glance
Seven days
The first written complaint must be lodged within 7 calendar days of becoming aware of the circumstances that give rise to it.
Three tiers
Procuring officer, head of the procuring entity, then the ministry Secretary, each with 5 working days to decide.
Fee and deposit
A Review Panel appeal carries a registration fee of Tk 10,000 to 25,000 and a refundable deposit of Tk 50,000 to 5 lakh.
Twelve working days
The Review Panel must give a written decision within 12 working days of receiving the appeal.
Writ review
The High Court Division has quashed panel decisions for late complaints, improper composition and exceeding the panel's powers.
Table of Contents
The legal basis after the 2025 and 2026 amendments
The complaint mechanism has two layers. The Act creates the right and the forum. Section 29(1) allows any person who has suffered, or is likely to suffer, loss because a procuring entity failed to perform a duty imposed by the Act to complain against that entity to the authorities named in section 30.[1] Section 30 requires the complaint to go first to the procuring entity's administrative authority, allows an appeal to a Review Panel if the complainant is dissatisfied or the authority fails to decide in time, and leaves the procedure to rules.[1]
The Rules supply the detail. The Public Procurement Rules 2025 were published in the Bangladesh Gazette on 28 September 2025 and replaced the 2008 Rules. Part 12, headed "Complaints and Appeals", contains rules 72 to 77, and the time limits, fees and panel numbers sit in Schedule 2.[4] BPPA's December 2025 standard tender document for goods now tells tenderers that the right to complain arises under sections 29 and 30 of the Act and rule 72, and that complaints are disposed of under rules 72 to 77.[5]
What the 2026 Act changed for complaints
The Public Procurement (Amendment) Act 2026 is Act No. 41 of 2026. It received assent and was gazetted on 10 April 2026, is deemed to have taken effect on 28 September 2025, and repealed the Public Procurement (Amendment) Ordinance 2025 while saving everything done under it.[2]
For complaints, three changes matter. Section 30(3) now expressly covers expertise in physical services as well as goods, works and intellectual and professional services. Section 65(1) now requires all public procurement that can be processed on the e-GP portal to be conducted electronically, with BPPA's prior approval for any exception. And the Act defines BPPA as the authority established under section 4 of the Bangladesh Public Procurement Authority Act 2023, the successor to the old Central Procurement Technical Unit.[2] Section 29 itself was not amended. Our guide to the 2026 public procurement amendments covers the other reforms, and our note on current procurement sources explains which official texts to rely on.
Who can complain and what can be challenged
Standing turns on loss. The Act does not limit complaints to tenderers who were rejected, but the complainant must show actual or likely loss flowing from the procuring entity's failure to comply with its duties.[1] In practice that means a potential applicant who could not obtain a document, a tenderer excluded at opening or evaluation, or a tenderer ranked below a bidder it says should have been disqualified.
The statutory exclusions in section 29(2)
Section 29(2) removes some decisions from the complaint route altogether: the choice of procurement method, the rejection of an application for short-listing, a decision cancelling prequalification applications, tenders, quotations or proposals, and a decision to award a contract following approval by the Cabinet Committee on Government Purchase.[1] These exclusions are read narrowly. In Priyanka Printing and Publications v Government of Bangladesh, decided on 9 November 2021, tenderers argued that section 29(2) prevented them from complaining about a corrigendum that changed production-capacity criteria. The High Court Division rejected the argument as "fallacious" and held that the grievance should have gone through the complaint procedure.[11]
The grounds listed in rule 72
Rule 72 sets out the circumstances in which a formal complaint may be lodged, grouped by stage.[4]
- Prequalification: the document was not ready on the date of advertisement or not made available on request; clarifications were not given in time; the evaluation committee did not apply the stated criteria; there are reasonable grounds to believe prequalification was unfairly refused; or corruption or collusion is suspected.
- Tendering (open, limited, direct, two-stage, one-stage two-envelope, quotation and reverse auction): defective advertisement; documents not available; late clarification; specifications that only one or a few manufacturers can meet; a failed or badly notified pre-tender meeting; irregular, premature or non-public opening; failure to open every tender received in time; evaluation outside the criteria in the tender document; negotiation initiated with the successful tenderer; breach of confidentiality in two-stage tendering; or suspected corruption or collusion.
- Requests for proposals: failure to keep technical proposals confidential; opening financial proposals with technical ones; evaluation outside the stated criteria; pressure to change fee rates where price is an evaluation factor; or suspected corruption or collusion.
The list frames the complaint. A procurement complaint review panel Bangladesh tenderers file should identify the specific rule 72 ground and the provision of the tender document that was breached, rather than a general allegation of unfairness.
The tiered procurement complaint review panel Bangladesh mechanism, step by step
Rule 73 requires every complaint to be made in writing within the time in Schedule 2, and builds three administrative tiers below the Review Panel.[4] The sequence below is what a complainant must follow.
Fix the date of knowledge
Record when and how you learned of the problem, keep the notice or document, and calendar 7 calendar days from that date.
Complain to the issuing officer
File a written complaint with the official who issued the tender document, citing the rule 72 ground and tender clause.
Escalate to the head of the entity
If dissatisfied or unanswered, re-file within 3 working days counted from the fifth working day after the first filing.
Escalate to the Secretary
Take the same complaint to the ministry or division Secretary within the next 3-working-day window.
Prepare the appeal pack
Seal the complaint and evidence for the panel chairperson, and attach the fee and deposit as bank drafts to a letter to BPPA.
Lodge with BPPA
File the appeal within the Schedule 2 window; BPPA must assign a panel within 3 working days and suspend the award.
Present the case
Make written and oral submissions, ensure affected bidders are heard, and check the panel has three members.
Act on the decision
Implement or challenge the decision within days; a writ under article 102 is the only further route.
Tier one: the officer who issued the documents
The complaint goes first to the official of the procuring entity who issued the tender or proposal document, such as the project director, line director, project manager or procurement officer. That official decides whether to reject the complaint or take corrective action, and must tell the complainant in writing within 5 working days of receipt, giving reasons for rejection or describing the corrective measures, such as an amendment to an unacceptable tender condition.[4]
Tier two: the head of the procuring entity
A complainant who is dissatisfied may lodge the same complaint with the head of the procuring entity. Schedule 2 gives a window of 3 working days counted from the fifth working day after the first complaint was filed. If the head of the procuring entity chaired or sat on the evaluation committee, they must forward the complaint to the Secretary within 3 working days and tell the complainant; otherwise they must decide within 5 working days.[4]
Tier three: the Secretary of the ministry or division
The third tier is the Secretary of the ministry or division concerned, again within 3 working days counted from the fifth working day after filing at tier two. The Secretary has 5 working days to decide and must send copies of the reasoned decision to the procuring entity and BPPA.[4] If any tier fails to decide in time, rule 73(9) allows the complainant to go directly to the next higher authority within the scheduled period, and every authority must keep a complaint register.[4]
Why the windows run from filing, not from the decision
Schedule 2 counts each escalation window from the fifth working day after the previous complaint was filed, not from receipt of a decision.[4] A complainant who waits for a late reply, or who treats an early decision as restarting the clock, risks missing the next tier. BPPA's web explainer on the Review Panel still cites the 2008 Rules and describes the old timetable, including 7 working days for an appeal, so it should not be used to calculate deadlines under the 2025 Rules.[3]
The table later in this guide compares the stages. The courts treat these deadlines as substantive, as the Shohoz decision discussed below shows.[10]

Lodging an appeal with the procurement complaint review panel Bangladesh provides
Rule 73(11) and (12) allow an appeal to the Review Panel only by a person dissatisfied with the Secretary's decision, and only after every administrative tier has been exhausted.[4] Under rule 73(13), the appeal may be filed after the Secretary's decision or, where no decision arrives in time, within the Schedule 2 window of 3 working days counted from the fifth working day after filing with the Secretary.[4]
The sealed-envelope procedure
The form is unusual and must be followed exactly. The complaint and supporting documents go in a sealed envelope marked "confidential", addressed to the chairperson of the Review Panel, to be opened only by the chairperson. That envelope is sent to BPPA under a forwarding letter addressed to BPPA's Chief Executive Officer, stating the intention to appeal and the nature of the complaint. The forwarding letter must attach the registration fee and the refundable security deposit as bank drafts in favour of the Chief Executive Officer.[4]
Registration fees and security deposits
Schedule 2 scales both amounts to contract value.[4]
- Contract value below Tk 1 crore: registration fee Tk 10,000; security deposit Tk 50,000.
- Tk 1 crore to Tk 5 crore: fee Tk 15,000; deposit Tk 1 lakh.
- Above Tk 5 crore to Tk 10 crore: fee Tk 20,000; deposit Tk 2 lakh.
- Above Tk 10 crore: fee Tk 25,000; deposit Tk 5 lakh.
- Complaints about matters before tender opening: fee Tk 10,000; deposit Tk 50,000.
An appeal without the fee and deposit is not placed before a panel; BPPA informs the appellant and copies the procuring entity.[4] The deposit is at risk: the panel may dismiss a frivolous appeal and forfeit the deposit, and it may order the deposit refunded where the procuring entity failed in its obligations.[4]
Direct appeals after the award
Rule 73(14) contains an important exception. Once a notification of award has been issued or the contract signed, no complaint may be lodged at any administrative tier. Where there are reasonable grounds to believe the award or contract was defective or contrary to the Rules, however, a formal appeal may go directly to the Review Panel against the procuring entity's action.[4] This is the only route that skips the tiers, and it should be used promptly.
How the Review Panel is constituted
Section 30(3) allows the Government to form one or more Review Panels of recognised experts in law, in the technical aspects of procuring goods, works, physical services or intellectual and professional services, in management and in procurement, and bars any serving officer of the Republic from membership.[1] [2] Rule 74 turns that power into the standing procurement complaint review panel Bangladesh tenderers now appeal to.[4]
- BPPA keeps a list of experts in three categories: procurement law (which may include retired senior officials), technical procurement expertise, and procurement and contract-management practice and dispute resolution (who may be nominated by the Federation of Bangladesh Chambers of Commerce and Industry). Schedule 2 caps each category at 10 experts.
- Each panel has one member from each category, at least 3 members in all, one of whom is chairperson. BPPA nominates members and chairpersons with the prior approval of the minister in charge of its ministry, and Schedule 2 provides for 3 to 5 panels.
- A panel may ask BPPA to co-opt up to 2 further members from the list, case by case.
- BPPA must issue a detailed procedure for panels, provides logistics, and may not involve itself in any complaint or appeal.
Under rule 75 the Government may dissolve any panel in the public interest with reasons, and remove a member for a conflict of interest, breach of section 64 of the Act, or incapacity.[4] Members receive Tk 8,000 per meeting for each review, for a maximum of 5 meetings.[4]
Composition defects void the decision
The three-member rule is jurisdictional. In Mim Development Engineering Ltd v Government of Bangladesh, decided on 6 December 2023, a panel of a chairperson and one member had decided the appeal. The High Court Division held the decision coram non judice, set aside both the panel order and the later notification of award, and directed a properly constituted panel to decide within 7 working days.[12] In Roots Developments Ltd v Chairperson, Review Panel No. 2, decided on 13 August 2025, the court again treated a two-member panel as coram non judice.[14] Both cases arose under the 2008 Rules, but rule 74 keeps the minimum of 3 members.[4]
Issuing officer
The official who issued the tender or proposal document decides within 5 working days.
Head of the procuring entity
Re-hears the complaint, or forwards it to the Secretary if they sat on the evaluation committee.
Ministry or division Secretary
Decides within 5 working days and copies the decision to the procuring entity and BPPA.
Bangladesh Public Procurement Authority
Receives appeals, assigns panels by rotation and directs suspension of the award.
Review Panel
Three experts in law, technical procurement and contract management; decides within 12 working days.
High Court Division
Reviews panel and procuring entity decisions under article 102 of the Constitution.
Suspension of the award and the public interest override
A properly filed appeal freezes the award, but not the evaluation. On receiving an appeal with the fee and deposit, BPPA must, within 3 working days, select a panel by rotation, send it the appeal and direct the procuring entity not to proceed to contract until the panel decides, informing the Secretary and the appellant by letter.[4] Rule 76(2) adds a general rule: while a complaint or appeal is pending before the procuring entity or the panel, no notification of award may be issued, although evaluation and approval may continue.[4] Once seised, the panel advises the procuring entity to keep the suspension in place until its decision.[4]
The public interest certificate
The suspension does not apply if the head of the procuring entity, with the approval of the Secretary or the minister, certifies that continuing the procurement is essential in the public interest. The grounds must be recorded specifically in the procurement record, and the certificate is final at every stage of the complaint "except judicial review".[4] That wording matters: a certificate issued without real grounds is open to challenge in the High Court Division, and the record is the evidence.
The courts weigh the same interest. In Consortium of Bashundhara Multi-Trading v Government of Bangladesh, decided on 5 September 2024, the High Court Division found parts of the Review Panel's direction unsustainable but, given the urgent need for coal at the Matarbari power plant, declined to order a fresh tender and left the final decision to the procuring entity with government approval.[13] Urgency can shape the remedy even where a complainant succeeds on the law.
What the procurement complaint review panel Bangladesh law creates can decide
The panel must give a written decision within 12 working days of receiving the appeal and send copies to the appellant, the Secretary, BPPA and the procuring entity.[4] Apart from dismissing a frivolous appeal and forfeiting the deposit, rule 77(3) lists its options, which may be used alone or together.[4]
- Reject the appeal with reasons and direct the procuring entity to continue.
- State the rules and principles that govern the complaint and direct the parties to act on them.
- Direct remedial measures where the procuring entity's action contravenes the Rules.
- Annul, in whole or part, any act or decision inconsistent with the Rules, other than an act or decision bringing a procurement contract into force.
- Where the procuring entity failed in its obligations, direct compensation for the cost of preparing the tender, legal costs and other complaint costs, together with refund of the security deposit.
- Direct that the procurement be completed.
Decisions are by majority and are final, and all parties must act on them. They must be opened to public inspection promptly, unless disclosure would be contrary to law, impede law enforcement, be against the public interest, prejudice the parties' legitimate commercial interests or inhibit fair competition.[4]
Limits on the panel's powers
The panel is not an evaluation committee. In Softesule Private Limited v Government of Bangladesh, decided on 4 January 2018, the High Court Division held that the powers in the old rule 60 were exhaustive, conferred no power of "substitution of judgments", and were exceeded when the panel declared one bidder non-responsive and another responsive. The court also held that a bidder whose rights would be affected must be heard.[9] In Roots Developments, the court held that a direction to re-tender was beyond the panel's mandate under the 2008 Rules.[14]
The 2025 text frames the outcomes in rule 77(3) as decisions, including annulment and compensation.[4] Whether the courts will read the new wording more broadly than the 2008 rule has not yet been tested. The safer view is that the panel can annul and direct a lawful re-run, but should not itself rank the tenders.

e-GP complaints and electronic evidence
Since the 2026 Act, e-GP is the default for all procurement the portal can process.[2] The Revised e-GP Guidelines 2025 describe the portal as covering advertisement, submission, opening, evaluation, award and contract management.[6] Three features change complaint practice.
- Timing: the notification of award is issued through the tenderer's dashboard, and the issuance date in the system is treated as the date of receipt.[6] Because an issued award ends the administrative tiers under rule 73(14), monitoring the portal daily is essential.[4]
- Evidence: evaluators who change values in the evaluation matrix must seek permission, and the system records the alteration.[6] A complaint that alleges manipulated evaluation should ask for those records.
- Publication: BPPA's December 2025 standard document requires contract award details to be published within 24 hours of the award and kept up for at least 28 days, and contract-signing information with beneficial ownership details within 3 days of signing.[5] Those notices often start the 7-day clock for a rival bidder.
The complaint itself is not filed through the portal. Rule 73 requires a written complaint at each tier, and the Review Panel appeal must be lodged in a sealed envelope with bank drafts.[4] The Rules define "in writing" to include a duly authenticated electronic message, but the appeal procedure is expressly physical.[4] Keep screenshots, system timestamps and e-mails, and file a hard copy with proof of delivery at every tier.
Debriefing and tender validity
The standard documents allow a tenderer to request a debriefing, limited to the relative status and weaknesses of its own tender.[5] A debriefing can supply the facts for a complaint, but it does not extend the 7-day period. Where a complaint delays award, the procuring entity may ask tenderers, through e-GP and at most twice, to extend tender validity, and tender security must then run 28 days beyond the new expiry. A tenderer that refuses does not forfeit its security, but drops out of the evaluation.[5] Complainants should agree to extensions, or they may win the argument and lose the tender.
Review Panel jurisdiction in foreign-funded procurements
Projects financed by the World Bank, the Asian Development Bank, JICA and other partners raise the most difficult forum question. The starting point is that the Act applies. Section 3(2) extends it to procurement under a loan, grant or other agreement between the Government and a development partner, foreign state or organisation, and "public funds" include grants and loans channelled through the Government.[1] Rule 3 of the 2025 Rules applies the Rules wherever the Act applies.[4]
The proviso to section 3(2) then reverses the position where the financing agreement says something different: its terms prevail.[1] Whether a procurement complaint review panel Bangladesh tenderers would normally use is available therefore depends on what the legal agreement, the procurement plan and the bidding documents provide on complaints.
World Bank-financed contracts
The World Bank's Procurement Regulations for IPF Borrowers (7th edition, September 2025) draw a clear line. Complaints on contracts that must use the Bank's Standard Procurement Documents are handled under Annex III, and the procurement plan identifies those contracts. Other complaints are handled by the borrower under "the applicable complaint review rules and procedures as agreed by the Bank".[7] National procedures used for national open competitive procurement must include "an effective complaints mechanism".[7]
For Annex III contracts, the deadlines differ from PPR 2025. A challenge to bidding documents must be made at least 10 business days before the submission deadline, or within 5 business days of an amendment; a challenge to exclusion within 10 business days of notice; and a challenge to award within the standstill period, which runs for 10 business days after the notification of intention to award. The borrower must acknowledge within 3 business days and respond within 7 or 15 business days, and for prior-review contracts it cannot proceed without the Bank's confirmation that the complaint has been satisfactorily resolved.[7]
How the two systems interact
Three working conclusions follow. First, on a Standard Procurement Document contract, the Annex III process is the agreed complaint system, and the section 3(2) proviso gives it priority over any inconsistent part of rules 72 to 77; filing with BPPA alone risks missing the Bank's standstill.
Second, on contracts procured under national procedures accepted by the Bank, the PPR 2025 tiers and the Review Panel are normally the agreed mechanism.
Third, the panel has in practice heard donor-funded disputes. In ST Electronics v Patimas International, an IDA-financed Bangladesh Bank project, the panel cancelled an award in 2006 under the pre-Act Public Procurement Regulations; the High Court Division set its order aside, and the Appellate Division dismissed the leave petition on 6 June 2007.[8] Softesule concerned an international tender for vitamin A capsules under a health sector programme financed by IDA Credit No. 4954-BD; the panel heard the appeal and the court quashed its decision on other grounds, without addressing whether the financing agreement displaced the panel.[9]
Where the position is unclear, run both tracks in parallel: lodge the complaint with the borrower within the development partner's deadline, copy the partner where the rules allow, and protect the PPR 2025 deadlines at the same time. Partners other than the World Bank have their own rules, which must be read from the financing agreement for the project.
Writ jurisdiction after a procurement complaint review panel Bangladesh decision
The panel's decision is final within the procurement, but not immune from the courts. The High Court Division reviews panel decisions, and procuring entity decisions, on applications under article 102 of the Constitution, and rule 76(4) of the 2025 Rules itself recognises judicial review.[4] [10] Our guides to judicial review in Bangladesh and to filing a writ petition in Bangladesh explain the general grounds and procedure; this section covers how they have been applied to procurement.
Exhaust the statutory route first
A tenderer that goes straight to the High Court Division usually fails. In Priyanka Printing, the court discharged the rule as not maintainable because the petitioners had not used the complaint procedure, and noted that they had participated in the tender after the corrigendum they attacked.[11] Participation without objection and delay both weigh against a later challenge.
Limitation, jurisdiction and natural justice
The grounds that succeed are mostly about process. In Shohoz-Synesis-Vincen JV v CPTU, 16 SCOB [2022] HCD 25, decided on 27 January 2022, a third-ranked bidder obtained a re-tender recommendation in the Bangladesh Railway ticketing tender. The High Court Division held that the first complaint did not disclose the date of knowledge, was therefore barred, and that the panel erred in making no finding on limitation; it declared the panel's order without lawful authority.[10]
The court relied on VA Tech WABAG Ltd v Bangladesh, 17 BLC (HCD) 568, which treated a date of knowledge asserted for the first time later in the process as an afterthought.[10] Composition defects (Mim Development, Roots Developments), substitution of the panel's own evaluation (Softesule), and failure to hear an affected bidder (Softesule) complete the main grounds.[9] [12] [14]
Merits are reviewed only for obvious error
The court will look at the merits where the panel's reasoning is unsustainable on the record. In Roots Developments, the court examined each objection, found them "without any foundation", and noted that the complaint process had been started before tender opening on matters that could only be known afterwards.[14] In Bashundhara, the court held that stating a Taka equivalent beside a US dollar bid security was not a material deviation, but upheld the exclusion on other qualification criteria.[13]
The table below summarises the leading decisions. On a phone, scroll it sideways.
| Case | Decided | Issue | Outcome | Lesson |
|---|---|---|---|---|
| Softesule v Government of Bangladesh, 12 SCOB [2019] HCD 205 | 4 January 2018 | Panel declared winner non-responsive without hearing it | Panel decision set aside | Panel cannot substitute its evaluation; affected bidders must be heard |
| Priyanka Printing v Government of Bangladesh | 9 November 2021 | Writ against corrigendum without complaint | Rule discharged as not maintainable | Use the statutory complaint route first |
| Shohoz-Synesis-Vincen JV v CPTU, 16 SCOB [2022] HCD 25 | 27 January 2022 | First complaint did not show date of knowledge | Panel order declared without lawful authority | The 7-day limit is enforced |
| Mim Development Engineering v Government of Bangladesh | 6 December 2023 | Two-member panel | Panel order and award set aside; rehearing ordered | Panel needs three members |
| Consortium of Bashundhara Multi-Trading v Government of Bangladesh | 5 September 2024 | Bid security wording and panel directions | No fresh tender ordered given urgency | Public interest shapes the remedy |
| Roots Developments v Chairperson, Review Panel No. 2 | 13 August 2025 | Two-member panel directed re-tender | Panel decision declared without lawful authority | Composition and mandate are jurisdictional |
Interim relief and the Appellate Division
Procurement writs move quickly because the Appellate Division often intervenes at the interim stage. In Shohoz, the Chamber Judge ordered status quo and the Appellate Division directed disposal within a set period; in Mim Development, it directed the rule to be heard within two months; in Bashundhara, the Chamber Judge stayed the High Court Division's stay and directed a decision on merit.[10] [12] [13] Expect any stay to be tested within days.
Related tracks: debarment and tender guarantees
Debarment runs on a different track. Under rule 149 of the 2025 Rules, the head of the procuring entity may declare a person ineligible for all public procurement for up to two years for corrupt, fraudulent, collusive, coercive or obstructive practice; a temporary suspension lapses if debarment is not decided within 42 days; and an appeal lies to the Debarment Review Board constituted under Schedule 21, not to the Review Panel.[4]
Guarantees can also become live during a complaint. A tender security may be forfeited, and a performance security called, while the procurement dispute is still running. Our analysis of bank guarantee encashment in Bangladesh covers the injunction routes and the conditions in the 2025 standard documents.
Strategy for complainants and procuring entities
The procurement complaint review panel Bangladesh system rewards preparation more than advocacy. Most failed challenges fail on time, form or forum.
- Record the date of knowledge: state in the first complaint the exact date and source of knowledge, attach the document that gave it, and file within 7 calendar days. Shohoz shows that a date supplied later will be treated with suspicion.[10]
- Diary every tier at once: calculate all the Schedule 2 windows on the day the first complaint is filed, and escalate on time whether or not a reply has arrived.[4]
- Tie each point to rule 72: cite the ground and the tender clause; general allegations of favouritism rarely survive.[4]
- Prepare the bank drafts early: the fee and deposit depend on contract value, and an appeal without them is not placed before a panel.[4]
- Check the financing agreement: in a donor-financed project, identify the complaint system and the standstill period before the first deadline expires.[7]

For procuring entities and successful bidders
The mirror image applies. Procuring entities should answer each complaint in writing within 5 working days with reasons, keep the complaint register, record the grounds for any public interest certificate, and confirm that any panel has three members.[4] A successful bidder that hears of an appeal should ask to be heard, test the complainant's date of knowledge, and, where the panel goes beyond rule 77, consider a writ promptly. In Softesule and Roots Developments, the winning bidders were not heard before the panel and later obtained relief in the High Court Division.[9] [14]
What to watch in 2026 and 2027
Three questions will shape how the procurement complaint review panel Bangladesh tenderers rely on develops. First, whether the High Court Division reads the decision-making language of rule 77(3) as wider than the recommendatory powers described in Roots Developments and Softesule.[4] [14] Second, how BPPA's detailed panel procedure under rule 74(5) deals with notice to affected bidders. Third, how the new filing-based escalation windows in Schedule 2 are applied to complaints made in the e-GP era, where the portal fixes the date of every notice.[4] [6]
TRW acts for tenderers, consortia and procuring entities in complaints, Review Panel appeals and procurement writ petitions, including on projects financed by development partners. Our constitutional and writ litigation practice handles High Court Division challenges, and our construction claims and project disputes team advises on the contract that follows. You can also contact TRW directly, ideally before the 7-day window closes.
Frequently asked questions
How long do I have to make a procurement complaint in Bangladesh?
Seven calendar days from becoming aware of the circumstances that give rise to the complaint, under rule 73(1) and Schedule 2 of the Public Procurement Rules 2025.[4]
Can I go straight to the Review Panel?
Normally no. Rule 73(12) allows an appeal only after the administrative tiers are exhausted. The exception is rule 73(14): after an award has been notified or a contract signed, a defective or irregular award may be appealed directly to the panel.[4]
What are the administrative tiers?
The officer who issued the tender document, the head of the procuring entity, and the Secretary of the ministry or division. Each must decide within 5 working days, and each escalation must be made within 3 working days counted from the fifth working day after the previous filing.[4]
How much does a Review Panel appeal cost?
A registration fee of Tk 10,000 to Tk 25,000 and a refundable security deposit of Tk 50,000 to Tk 5 lakh, depending on contract value, both paid by bank draft in favour of BPPA's Chief Executive Officer.[4]
How quickly does the Review Panel decide?
BPPA must assign the appeal to a panel within 3 working days, and the panel must give a written decision within 12 working days of receiving it.[4]
Does an appeal stop the contract award?
Yes, unless the head of the procuring entity, with the Secretary's or minister's approval, certifies that proceeding is essential in the public interest. Evaluation and approval may continue while the complaint is pending.[4]
Can the Review Panel award the contract to me?
Does the Review Panel hear complaints on World Bank-financed contracts?
It depends on the financing agreement. Section 3(2) of the Act gives the agreement priority, so the procurement complaint review panel Bangladesh route may be displaced. The World Bank handles complaints on Standard Procurement Document contracts under Annex III of its Procurement Regulations, with a 10-business-day standstill.[1] [7]
Can a Review Panel decision be challenged in court?
Can I file a writ without complaining first?
Usually not. In Priyanka Printing the High Court Division held a writ not maintainable because the petitioners had not used the statutory complaint procedure.[11]
Source register
Primary legal and regulatory sources
Materials checked on 20 October 2026. Confirm the current official text before relying on any provision.
- Public Procurement Act 2006 and Public Procurement Rules 2008 with all amendments up to January 2019 (sections 2, 3, 29 and 30) — BPPA
- Public Procurement (Amendment) Act 2026 (Act No. 41 of 2026) — Bangladesh Gazette Extraordinary, 10 April 2026
- BPPA — Formation of Review Panel (complaint and appeal explainer, dated 16 March 2025)
- Public Procurement Rules 2025 (Part 12, rules 72 to 77, rule 149 and Schedule 2) — Bangladesh Gazette, 28 September 2025, via BPPA
- BPPA Standard Tender Document e-PG3A (goods, framework agreement), December 2025
- Bangladesh e-Government Procurement (e-GP) Guidelines (Revised) 2025 — Bangladesh Gazette, 12 March 2025
- World Bank — Procurement Regulations for IPF Borrowers, 7th edition, September 2025 (paragraphs 3.26 to 3.31, 5.3 to 5.4, 5.78 to 5.80 and Annex III)
- ST Electronics (Infor Soft Ware System) Pvt Ltd v Patimas International Sdn Berhad, Appellate Division, 6 June 2007 — case report
- Softesule Private Limited v Government of Bangladesh, 12 SCOB [2019] HCD 205 — Supreme Court of Bangladesh
- Shohoz-Synesis-Vincen JV v CPTU, 16 SCOB [2022] HCD 25 (Writ Petition No. 2455 of 2021) — Supreme Court of Bangladesh
- Priyanka Printing and Publications v Government of Bangladesh, Writ Petition No. 6022 of 2021 (HCD, 9 November 2021)
- Mim Development Engineering Ltd v Government of Bangladesh, Writ Petition No. 8501 of 2023 (HCD, 6 December 2023)
- Consortium of Bashundhara Multi-Trading Co Ltd v Government of Bangladesh, Writ Petition No. 8664 of 2024 (HCD, 5 September 2024)
- Roots Developments Ltd v Chairperson, Review Panel No. 2, BPPA, Writ Petition No. 6624 of 2024 (HCD, 13 August 2025)
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