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A Clearer Forex Framework for Digital Exports


Bangladesh Bank has consolidated and restated the foreign-exchange rules applicable to freelancers and individual service exporters, bringing them into closer alignment with the documentary realities of digital trade. The guidelines issued on 22 July 2026 cover ICT services, business-process outsourcing and other professional services supplied through the internet or electronic media. They confirm that procedures designed for physical merchandise, including submission of the EXP Form, do not apply to these transactions. Authorised dealer banks may instead rely on electronic evidence such as contracts, emails, invoices (where available), platform statements, and other digital communications. This is an important administrative correction, though it does not remove foreign-exchange regulation. Freelancers must still repatriate their export earnings within the prescribed period, and banks remain responsible for verifying the legitimacy of the underlying transactions and complying with customer-identification, anti-money-laundering, counterterrorist-financing, tax, reporting and record-keeping requirements. The value of the framework lies in recognising that digital work leaves a different documentary trail from merchandise exports, and that compliance procedures should reflect how online professional services are commissioned, delivered and paid for.

The guidelines also clarify payment channels, transaction thresholds and foreign-currency retention facilities. An inward remittance of up to $20,000, or its equivalent, may be credited without Form-C; transactions above that threshold require online Form-C (ICT), unless another applicable instruction permits otherwise. Payments received through internationally recognised online payment gateway service providers remain subject to a ceiling of $10,000 per transaction. Bangladesh Bank’s earlier export regulations had already permitted small-value non-physical service exports through such providers, so the latest circular is best understood as a consolidation and clarification of the existing regime, together with more specific instructions for freelancers and individual exporters. Exporters of software, data entry, data processing and other ICT-related services may retain up to 50% of their net export earnings in an Exporters’ Retention Quota account, while exporters of other eligible services may retain up to 30%. The remaining amount must be converted into taka and credited to a local account. Funds held in an ERQ account may be used for specified legitimate expenses, including software registration, domain and hosting fees, server maintenance, foreign travel and the import of equipment. These provisions acknowledge that digital exporters may earn abroad while also needing foreign currency to pay for essential technology, services and business operations.

The framework also allows eligible export proceeds to be received through bank-issued dual-currency freelancer cards, licensed mobile financial service providers and payment service providers operating through arrangements with foreign payment operators. Funds may be transferred to bank accounts or digital wallets, while the permissible foreign-currency portion may be placed in an ERQ account. For workers outside the main commercial centres, these channels could reduce dependence on physical bank branches and make legitimate earnings easier to access. The economic case for making such channels work is reinforced by the concentration of Bangladesh’s merchandise exports. The country earned about $48 billion from merchandise exports in the 2025-26 fiscal year, of which ready-made garments contributed approximately $38.7 billion. Apparel therefore accounted for roughly four-fifths of total merchandise export earnings. The garment industry remains indispensable, but this concentration gives Bangladesh a clear reason to develop additional sources of foreign-currency income, including software, online professional services and other knowledge-based exports. A more functional payment system for digital service providers could support export diversification without diminishing the importance of the country’s existing industrial base.

Formalising service-export receipts will not cause every incoming dollar to appear automatically in Bangladesh Bank’s official reserves. The immediate effects are more precise: the income is recorded through the formal financial system, contributes to measured service exports and adds foreign-exchange liquidity to the banking sector. Such inflows can support reserve accumulation when the central bank is able to purchase foreign currency from the market. But the country’s broader reserve position will continue to depend on imports, exports, remittances, debt payments, financial flows, exchange-rate policy and central-bank intervention. Digital services may require fewer imported physical inputs than many manufacturing activities, but they do not operate without foreign-currency costs. Service providers often need to pay for software subscriptions, cloud infrastructure, hosting, online tools, equipment and international travel. The ERQ facility therefore gives eligible exporters a regulated way to meet specified bona fide foreign-currency expenses, several of which may be paid without prior Bangladesh Bank approval. A successful system should make lawful transactions easier to complete while preserving the transparency required for financial supervision.

Implementation will determine whether the policy works in practice. The circular permits electronic evidence, but that flexibility will have little value if commercial banks continue to demand documents associated with physical shipments or apply inconsistent standards from one branch to another. Banks should establish clear procedures for assessing platform records, contracts, remittance messages and customer profiles, and their staff should understand the difference between merchandise exports and digitally supplied services. At the same time, the prohibition on keeping export earnings abroad remains in force. Apart from approved merchant or notional accounts used to transfer funds to Bangladesh, service exporters may not retain their proceeds in foreign accounts, assets or virtual assets. This places a corresponding responsibility on banks and regulators to ensure that legally required repatriation can occur without unnecessary delay, irrelevant paperwork or arbitrary interpretation. Bangladesh does not need to choose between financial compliance and digital trade; it needs a system capable of doing both. A knowledge-based export economy cannot be governed exclusively through rules written for containers, customs documents and shipping ports. Recognising contracts, platform records, electronic correspondence and payment messages as legitimate evidence does not weaken foreign-exchange governance. Properly applied, it makes compliance more realistic and brings a larger share of lawful cross-border economic activity within the regulated financial system.
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The writer is an Assistant Professor in the Department of Philosophy at IUBAT and is currently on study leave, residing in Oslo, Norway





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