Mobile Financial Services, PSP and PSO Licensing in Bangladesh: Current Compliance Guide

Executive Summary and Statutory Authority

Question	Current official position reviewed	Practical consequence
Who supervises payment licensing?	Bangladesh Bank’s Payment Systems Department (PSD) issues and oversees PSP and PSO licences under the payment framework.	Do not rely on RJSC incorporation, a trade licence or a software label as permission to provide regulated payment services.
What is a PSP?	Bangladesh Bank describes a PSP as facilitating payment or payment processing directly for customers and settling through a scheduled bank or financial institution; examples include e-wallet or mobile-wallet services.	Map the real customer and funds flow before choosing a licence category.
What is a PSO?	Bangladesh Bank describes a PSO as operating a settlement system between participants where the principal participant is a scheduled bank or financial institution; payment gateways and aggregators are examples.	A “technology only” description does not settle the classification question.
What is MFS?	The MFS Regulations 2022 govern Bangladesh’s bank/FI/government-entity-led mobile financial services model and operate with the payment and trust-management framework.	Confirm the sponsor, ownership/control structure, permitted services and current Bangladesh Bank approval route.

1. The Three Regulatory Categories

1.1 Payment Service Provider (PSP)

Bangladesh Bank’s payment-systems page describes a PSP as a company that facilitates payments or payment processing directly for customers and settles through a scheduled bank or financial institution. Its examples include e-wallet and mobile-wallet services. The category should therefore be tested against the proposed product, user relationship, payment instrument, settlement arrangement and customer-money flow—not merely the name used in a business plan.

1.2 Payment System Operator (PSO)

The same official page describes a PSO as operating a settlement system between or among participants where the principal participant must be a scheduled bank or financial institution. Bangladesh Bank gives payment gateway and payment aggregator services as examples. A promoter should prepare a functional classification memo before launch and ask PSD to confirm the applicable route where the model combines gateway, acquiring, wallet, switch or marketplace functions.

1.3 Mobile Financial Services (MFS)

The MFS Regulations 2022 replaced the 2018 regulations and state that they operate together with BPSSR 2014, the trust-fund management guidance and other applicable law. The Regulations describe a bank/FI/government-entity-led model in which the MFS provider is a subsidiary of a scheduled commercial bank, financial institution or government entity with at least 51% of the shares held by that sponsor and control of the board. That ownership description must be read with the current Regulations, approvals and any later Bangladesh Bank direction; it should not be converted into a general promise that every fintech may hold the remaining interest on identical terms.

1.4 What is not established by this article

The reviewed public Bangladesh Bank materials do not establish a universal BDT 10–40 crore PSO capital band, BDT 10–20 crore PSP band, BDT 45 crore MFS floor, one standard application form, a fixed 45/60/90-day decision period, a universal 6–12 month letter-of-intent period, or a single national fee schedule. Those figures were removed from this amended edition. An applicant must use the current approval procedure and written PSD instructions for the relevant service.

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This roadmap is conceptual. It does not create an in-principle approval, licence, statutory deadline or automatic right to begin operations.

2. A Defensible Application Preparation Sequence

2.1 Map the product and funds flow

Describe each user, participant, payment instrument, settlement account, merchant relationship, agent arrangement, dispute path and point at which the business controls or holds funds. Separate payment processing from lending, deposit-taking, remittance, prepaid instruments and merchant-acquiring functions. If the product crosses more than one perimeter, ask PSD and the other relevant authority for written direction.

2.2 Establish the corporate and governance file

Incorporation and constitutional documents are supporting evidence, not a substitute for Bangladesh Bank approval. Prepare the ownership and control chart, board and senior-management profiles, business plan, risk assessment, financial projections, internal-control framework, consumer complaint process, outsourcing register and business-continuity plan. Do not state that a particular RJSC form, fee or minimum capital is universal unless the current approval procedure expressly requires it.

2.3 Prepare settlement, safeguarding and reconciliation controls

Identify the scheduled-bank or financial-institution settlement arrangement and document how customer, merchant and corporate funds are separated, reconciled and released. The Bangladesh Bank regulations and the 2022 trust-management guidance should be read together with any current PSD instruction. The exact account title, permitted investment, reporting cadence and reconciliation standard must be verified for the product; this guide does not promise that every PSP, PSO or MFS model has identical trust-account mechanics.

2.4 Prepare AML/CFT, KYC and security evidence

Build a risk-based customer-identification, transaction-monitoring, sanctions-screening, suspicious-transaction escalation, record-retention and reporting programme under the applicable Bangladesh law and BFIU directions. Include access control, incident response, resilience, vendor oversight, change management and audit-log controls. Bangladesh Bank’s public guidance list now separately identifies e-KYC, ICT-security, cloud-computing and 2026 cybersecurity materials; the applicant should use the version applicable to its regulated entity and service.

2.5 Submit only after current PSD confirmation

Bangladesh Bank says PSD reviews market demand, business rationale, regulatory requirements, risk-management systems, settlement systems and eligibility criteria when considering PSP/PSO applications. The public pages do not promise a uniform processing time. Obtain the current approval-procedure document, filing channel, checklist, fees and any pre-application meeting requirement directly from PSD, and keep the written response in the regulatory file.

3. MFS Operations, Interoperability and Consumer Protection

Bangladesh Bank’s payment-systems page lists domestic MFS services such as cash-in, cash-out, P2P, P2B, B2P, P2G and G2P. It also says cross-border money transfer is not allowed through MFS, while inward remittance disbursement through banking channels is permitted. Product specifications and public claims should follow the current MFS Regulations and Bangladesh Bank directions rather than an old service list.

Bangladesh Bank describes NPSB as an interoperability platform for participating banks and separately lists certified institutes for BanglaQR and MFS interoperable transactions. The existence of those rails does not by itself prove that every PSP, PSO or MFS provider has an identical mandatory integration, transaction limit, MDR, settlement window or technical certification. Confirm the applicable rule and certification for the proposed service.

4. Enforcement and Practical Risk Controls

Operating a regulated payment service without the required approval can expose the business and responsible persons to regulatory, contractual and criminal risk under the applicable payment and AML/CFT framework. This article does not assert a single penalty amount or a universal appeal deadline because those consequences depend on the instrument, provision, notice and current law. Preserve every Bangladesh Bank notice, response, approval condition, audit finding and remediation record.

• Do not launch on incorporation alone: obtain the required PSD approval before offering the regulated service.
• Do not use a software label to avoid classification: analyze control of payment flows and customer relationships.
• Do not mix safeguarded or settlement funds with operating cash: document account controls and reconciliations.
• Do not treat a public webpage as a complete licence checklist: obtain the current approval procedure and written PSD direction.
• Do not publish old rates, limits, fees or timelines: date-stamp them and cite the current circular or remove them.

Statutory and Regulatory Document Checklist

File	Evidence to assemble	Verification note
Classification	Service map, participant map, funds-flow diagram and proposed customer journeys	Ask PSD to confirm PSP, PSO, MFS or another route where functions overlap.
Corporate and ownership	Constitutional documents, ownership/control chart, governance and fit-and-proper materials	Do not infer approval or ownership permission from incorporation.
Settlement and safeguarding	Bank arrangements, account controls, reconciliation, merchant settlement and dispute flows	Apply the current trust/settlement guidance and product-specific directions.
Risk and security	AML/CFT programme, KYC/e-KYC controls, cyber controls, resilience, outsourcing and audit plan	Use the current Bangladesh Bank and BFIU materials relevant to the entity.
Consumer protection	Terms, disclosures, complaints, transaction records, fraud response and redress process	Retain approval conditions and evidence of ongoing compliance.

Official Sources Reviewed

• Bangladesh Bank: MFS Regulations 2022
• Bangladesh Bank: Payment Systems, MFS and PSP/PSO overview
• Bangladesh Bank: Regulations and guidelines list
• Bangladesh Bank: Circulars and circular letters
• Bangladesh Bank Annual Report 2024–2025, payment-system chapter
• Bangladesh Bank Payment Systems Report, December 2024

Frequently Asked Questions