An Easier Import Regime Needs Smarter Compliance

On August 24, 2026, the government gazetted the Import Policy Order 2026-2029. It permits industrial and commercial importers to use sales or purchase contracts, alongside letters of credit, without the previous annual US$500,000 non-LC cap, subject to applicable rules. It also contains provisions for free trade zones and central bonded warehouses. The change can simplify imports for businesses. But its success will depend on a less visible reform: whether the state can make trade easier without making transactions harder to see. For a small manufacturer, quicker access to inputs can mean fewer production interruptions, less inventory pressure and more reliable delivery to customers. For larger firms, it can widen sourcing options and cut paperwork. These are good reasons to welcome a more flexible regime.

Yet the policy will fail its most practical test if a formal hurdle disappears only to be replaced by repeated checks at different agencies. Trade facilitation is not the absence of compliance. It is compliance that is fast for the legitimate importer and exacting where the record does not add up. That distinction matters. A letter of credit is not a guarantee that every transaction is sound, and a sales contract is not a loophole by definition. Both can support legitimate trade. As the new Order broadens the scope for contract-based imports, the chain from contract to payment to customs clearance needs to become more reliable, not less.

The Commerce Ministry should convene Bangladesh Bank, the National Board of Revenue’s Customs wing and the Office of the Chief Controller of Imports and Exports to agree a 90-day implementation protocol. The goal should be a unique transaction reference, assigned at contract execution and retained through bank payment and customs declaration.

Bangladesh does not have to invent this information architecture. Bangladesh Bank’s current import circular, issued on August 13, 2026, requires authorised dealers to obtain underlying contracts, indents and pro forma invoices; report primary information to the Online Import Monitoring System (OIMS); and assesses contracted prices against market conditions. It also requires specified product details and eight-digit HS codes in the relevant underlying documents. For eligible contract imports, the underlying contracts must be submitted through designated dealers for online reporting. That makes coordination more consequential. Contracts, importer registration, HS codes, invoices, payment dates, bills of entry and, where relevant, bonded-warehouse records all relate to the same commercial transaction. Matched once and reused by agencies with a lawful need to see them, these records can cut resubmission without loosening scrutiny. Otherwise, legitimate firms face repeated checks and anomalies become harder to resolve.

This is not an argument to preserve an LC-centred system or to impose a new blanket approval layer. Together, the Order and current circular provide for contract-based imports, subject to the Order’s conditions and applicable foreign-exchange rules. The policy gain lies in a common electronic trail that replaces repeated manual proof, not in a relaxation of checks. A good system asks a compliant importer once for the relevant information, and then lets authorised agencies use it for their lawful purposes. Some will say that an integration programme will delay liberalisation. That would be a valid concern if it created another portal and another discretionary signature. It should do the opposite. A shared reference and defined service clock should remove duplicate submissions, make risk review more targeted and give honest traders a clearer answer when something goes wrong.

The Commerce Ministry should convene Bangladesh Bank, the National Board of Revenue’s Customs wing and the Office of the Chief Controller of Imports and Exports to agree a 90-day implementation protocol. The goal should be a unique transaction reference, assigned at contract execution and retained through bank payment and customs declaration. That reference should link existing records rather than duplicate data, without publishing commercially sensitive information. The protocol should not create another portal; it should let existing systems recognise the same reference. Bangladesh Bank already instructs authorised dealers to match bills of entry against the relevant IMP forms and invoices, then report the verification to OIMS. The next step is a controlled data link with customs. Customs should receive only the data necessary for its lawful functions.

Material discrepancies should be assigned to the agency accountable for resolving them, not returned to the trader as a fresh paper chase. The protocol should establish a risk-based processing route. Routine transactions with a complete, consistent record deserve fast processing. Mismatches in price, product classification, country of origin, payment maturity or evidence of entry should trigger review. The selection logic need not be public, but service standards should specify who responds, how quickly, and how a firm can correct a good-faith data error. Public reporting must measure the reform at the point where business feels it. Each quarter, the agencies should publish aggregate figures on clearance times, contract imports matched to bills of entry, exceptions resolved and enforcement outcomes.

They need not expose any company’s commercial data. They do need to show whether the state is reducing needless delay while finding real risk. That balance matters most to smaller importers. A large group can afford lawyers, specialist compliance teams and stock buffers.

A modest manufacturer or trader often cannot. If the new route works only for firms that can navigate three separate systems, it will intensify concentration rather than broaden opportunity. Predictability is not a concession to business; it is the condition under which rules apply equally.

The new Import Policy Order is not merely a document about relaxing a limit. It is a test of whether Bangladesh can move from compliance as paperwork to compliance as usable evidence. If the government makes lawful trade easier and anomalies easier to detect, it will strengthen both competitiveness and confidence. If it only shifts paperwork from the LC desk to another queue, the promise will remain on paper.