In April 2026, as Dhaka’s political calendar accelerates toward general elections and the IMF watches every legislative move from Washington, Bangladesh’s newly elected BNP-led parliament has quietly detonated a grenade in the middle of a still-fragile banking reform. The Bank Resolution Act 2026, enacted on Friday, April 11, paves a wide — some would say suspiciously wide — road for former bank owners to reclaim institutions they drove into distress. The question hardening in the minds of depositors, reform economists, and international creditors alike is brutally simple: is this pragmatic crisis management, or the most elegant act of regulatory impunity Bangladesh has ever legislated?

What the Bank Resolution Act 2026 Actually Says — and What It Doesn’t

Let’s start with the architecture of the law, because the devil lives in its fine print.

Under the Bank Resolution Act 2026, former directors or owners of banks that are merging or listed for mergers can pay just 7.5 percent upfront of the amount injected by the government or Bangladesh Bank to reclaim their institutions. The remaining 92.5 percent is repayable within two years at 10 percent simple interest. The Daily Star Before any approval is granted, Bangladesh Bank must conduct due diligence and seek government clearance. Even after approval, the central bank will closely monitor the merged entity for two years, with a special committee reviewing compliance — and failure to meet conditions could lead to cancellation of approval and further regulatory action. The Daily Star

On paper, the safeguards sound serious. In practice, economists who have spent years watching Bangladesh’s banking politics are not reassured. Zahid Hussain, former lead economist at the World Bank’s Dhaka office and a member of the interim government’s banking reform task force, warned that the amendment destroys the credibility of the reform process, saying that “a clear roadmap has been provided for former owners to re-occupy banks that were distressed due to their own mismanagement and the siphoning of funds.” The Business Standard

The numbers Hussain cites are staggering in their implication. He estimated that for the five merged banks, the total required payment would be roughly Tk 35,000 crore — and expressed concern that the terms are so lenient that former owners could easily pay the initial 7.5 percent and borrow the remainder from the banking sector itself. The Business Standard That is not a bailout mechanism. That is a round-trip ticket funded by the very system that was looted.

The Sommilito Islami Bank Merger: A Reform That May Never Have Happened

To understand what is now at stake with the Bank Resolution Act 2026, you must first understand what the 2025 Ordinance was attempting to accomplish — and why it mattered beyond Bangladesh’s borders.

As part of its reform drive, in May 2025, the interim administration had approved the Bank Resolution Ordinance 2025 to merge five troubled Shariah-based private banks into a state-run entity titled Sommilito Islami Bank. The five institutions — First Security Islami Bank, Social Islami Bank, Union Bank, Global Islami Bank, and Exim Bank — had collectively become symbols of politically directed lending and governance failure. The Daily Star

The boards of four of the banks were dominated by the controversial S Alam Group, led by its Chairman Mohammed Saiful Alam, while Exim Bank was long controlled by Nassa Group Chairman Md Nazrul Islam Mazumder. The Daily Star The S Alam Group banks return 2026 scenario — which the new Act explicitly enables — is not abstract; these are the same ownership structures whose related-party lending created the crisis in the first place.

The Shariah banks merger reversal risk is now real enough that even Bangladesh Bank’s own officials are alarmed. Bangladesh Bank officials told The Daily Star that concerns remain over how these banks will be managed if former owners return, whether depositors will be able to recover their money, and that if a bank is returned to its previous owners, it cannot easily be taken back again. “This raises doubts about whether they would be able to run the banks properly and ensure full legal and regulatory compliance,” one official said, adding that the return of previous owners could hinder the ongoing merger process. The Daily Star

That is a central bank quietly sounding an alarm about a law passed by its own government. Read that again.

The Macroeconomic Context: A Sector Already on Life Support

No assessment of the Bank Resolution Act 2026 can be divorced from the catastrophic baseline it is operating against. The World Bank’s Bangladesh Development Update released in 2025 documented a sector in acute distress. Banking sector-wide non-performing loans reached 24.1 percent by March 2025, significantly above the South Asian average of 7.9 percent. The capital-to-risk-weighted asset ratio fell to 6.3 percent, well below the regulatory minimum of 10 percent. World Bank

These are not technical footnotes. A CRAR of 6.3 percent — against a required 10 percent minimum, and a Basel III-compliant effective floor closer to 12.5 percent when capital conservation buffers are included — means Bangladesh’s banking system is operating with a structural capital hole that is visible from space.

The IMF’s 2025 Article IV Consultation, concluded on January 26, 2026, was characteristically blunt. Directors highlighted the urgent need for a credible banking sector reform strategy consistent with international standards to restore banking sector stability. Such a strategy should include estimates of undercapitalization, define fiscal support, and outline legally robust restructuring and resolution plans. They also cautioned against unsecured liquidity injections into weak banks. International Monetary Fund The ink on that consultation was barely dry when parliament passed the Bank Resolution Act 2026 — a law whose principal mechanism is, functionally, a structured return of capital to distressed institutions controlled by their original owners.

The IMF’s language about “prolonged reliance on forbearance measures” was not accidental. Fund staff specifically stated that “any approach to dealing with weak banks should ensure healthy balance sheets, sustained profitability, and adequate liquidity without prolonged reliance on forbearance measures.” International Monetary Fund What the new Act provides — a 7.5 percent entry ticket and 10 percent simple interest on a two-year repayment — is, by any global standard, forbearance in a legislative costume.

The International Standard: What the BRRD, FDIC, and India’s IBC Actually Require

To appreciate why the Bank Resolution Act 2026 troubles international observers, compare it against the frameworks Bangladesh has nominally aligned itself with.

The European Union’s Bank Recovery and Resolution Directive (BRRD) operates on a “no creditor worse off” principle, with resolution authorities empowered to impose losses on shareholders and unsecured creditors before any public money is committed. Critically, the BRRD explicitly prohibits the return of equity to former shareholders whose mismanagement contributed to resolution proceedings. The message is structural: resolution is not a waiting room for rehabilitation. It is a point of no return.

The US Federal Deposit Insurance Corporation (FDIC) model is similarly unambiguous. When an institution enters FDIC resolution, former owners lose their equity entirely. The FDIC then sells assets, transfers deposits, or establishes bridge banks — without reopening a window for the people who broke the bank in the first place. The concept of a former owners Bangladesh Bank Resolution Act mechanism — paying back a fraction upfront and recovering control — would be legally inconceivable under FDIC rules.

India’s Insolvency and Bankruptcy Code (IBC), enacted in 2016, went further: its Section 29A specifically bars promoters who have defaulted from participating in resolution plans for their own companies. After years of politically connected promoters recycling distressed assets back to themselves, India drew an explicit legislative line. Bangladesh, in April 2026, appears to be drawing that line in the opposite direction.

The Chambers and Partners Banking Regulation 2026 Guide for Bangladesh acknowledges that the regulatory agenda of Bangladesh Bank for 2025 and 2026 is “exceptionally dynamic, driven by a national push for enhanced governance, financial sector stability, and compliance with IMF programme conditions.” Chambers and Partners The Bank Resolution Act 2026 as enacted tests whether that dynamism is substantive or cosmetic.

The Government’s Defence: Fiscal Pragmatism or Political Convenience?

Finance Minister Amir Khosru Mahmud Chowdhury presented the Act in parliament as a “market solution” — a phrase that in emerging market contexts tends to arrive dressed as economic logic and leave as political cover. The minister described the government as having already invested approximately Tk 80,000 crore into weak banks and potentially needing another Tk 1 lakh crore — a financial burden he called unsustainable. “This new arrangement places the obligation of recapitalisation and liability settlement on the applicants, reducing the pressure on the government and the Deposit Insurance Fund,” he stated. The Business Standard

This argument has a kernel of validity that cannot be entirely dismissed. A sovereign that has already pumped the equivalent of several GDP percentage points into failing banks and faces the prospect of doubling down — during a period when, as the IMF notes, Bangladesh’s debt service-to-revenue ratio exceeds 100 percent — has a legitimate interest in finding private recapitalization. The question is not whether to seek private capital. It is from whom, and on what terms.

The Act’s critics, including Zahid Hussain, argue the answer currently provided is: the same people who caused the crisis, on terms lenient enough to enable regulatory arbitrage. Hussain warned that the provision undermines past reform efforts, noting: “If, under this law, the previous owners return and reclaim their organisations, the integrity of the new structure created after the merger could be lost. In that case, all merger-related work would effectively become meaningless.” The Daily Star

He is right. And the S&P Global Islamic Banking Outlook 2026 context makes this more acute: Islamic finance institutions globally are under increased scrutiny for governance standards, with rating agencies increasingly marking down Shariah-compliant lenders in frontier markets where board independence and related-party transaction controls are weak. The Som milito Islami Bank ex-owners returning to manage the merged entity would face an uphill battle establishing the governance credibility that international Islamic finance counterparties — Gulf investors, sukuk markets, multilateral development banks — now routinely require.

The Post-Hasina Governance Test: Is Bangladesh Building Institutions or Recycling Networks?

The deepest concern about the Bank Resolution Act 2026 is not technical. It is political economy.

Bangladesh’s post-August 2024 moment — the political transition that followed the uprising ending Sheikh Hasina’s government — was described by reformers and development partners as a generational opportunity to rebuild institutional integrity. Finance Adviser Dr. Salehuddin Ahmed himself described the inherited banking system as one hollowed out by “rampant embezzlement, unchecked corruption, and politically driven loan rescheduling.” BBF Digital

The three-year reform roadmap — backed by the IMF, World Bank, and Asian Development Bank — committed Bangladesh to asset quality reviews, risk-based supervision, the Distressed Asset Management Act, and legally robust restructuring frameworks. The overarching goal was to “ensure banks are financially sound and to end the long-standing practice of granting regulatory forbearance to weaker institutions.” The Daily Star

The Bank Resolution Act 2026 as enacted is not a clean break from that narrative. It is, at minimum, an asterisk — and at worst, a structural loophole that future actors will exploit regardless of what due diligence and monitoring clauses say on paper. Bangladesh Bank officials themselves acknowledge the asymmetry: once a bank is returned to former owners, recovering it is legally and operationally far harder than the two-year monitoring clause implies.

The former owners Bangladesh Bank Resolution Act pathway, combined with the ex-owners reclaim banks Bangladesh mechanism at 7.5 percent upfront, sets a precedent that future distressed bank owners will study carefully. The message it sends to the market — domestic and international — is that Bangladesh Bank resolution is a negotiated exit, not a structural consequence. That signal will outlive any monitoring committee.

What a Credible Reform Would Look Like

This article does not argue for leaving the five merged Shariah banks in permanent regulatory limbo. Merger uncertainty damages depositors. Extended state management creates moral hazard in the other direction. Bangladesh does need a resolution pathway.

But a credible pathway, consistent with the BRRD model and India’s IBC experience, would require: mandatory and independent forensic audits of all related-party transactions before any return of ownership is considered; an open competitive bidding process for new strategic investors — not a preferential window for former owners; full equity writedowns for shareholders whose mismanagement contributed to resolution triggers; enhanced personal liability provisions backed by asset freezes, not merely regulatory monitoring; and independent board composition certified by Bangladesh Bank before any operational handback.

The IMF, in its January 2026 Article IV, called for “swift action to operationalize new legal frameworks that facilitate orderly bank restructuring while safeguarding small depositors” alongside “robust asset quality reviews for all large and systemic banks, bank restructuring aimed at forward-looking viability, strengthened risk-based supervision, and enhanced governance and transparency.” International Monetary Fund The Bank Resolution Act 2026 addresses the first clause and largely bypasses the rest.

The Verdict: Alarming Precedent, Redeemable Only by Enforcement

Bangladesh’s Bank Resolution Act 2026 is not beyond redemption. The due diligence requirement, BB monitoring provisions, and cancellation clauses are meaningful — if enforced with the independence the law’s critics doubt Bangladesh Bank can summon under a newly elected government whose political networks overlap uncomfortably with the very ownership groups seeking re-entry.

The Tk 35,000 crore question is not whether former owners can write the initial cheque. It is whether Bangladesh’s regulatory institutions have the spine to cancel approvals when compliance conditions are not met, to withstand political pressure during the two-year supervision window, and to protect the 17 million depositors whose savings are concentrated in institutions whose balance sheets remain deeply impaired.

For international investors, IMF programme managers, and World Bank country teams watching from Washington and Jakarta, the Bank Resolution Act 2026 is a stress test of post-crisis institutional credibility. Bangladesh passed the legislative test of enacting a resolution framework in 2025. It now faces the harder test: proving that the framework means what it says, even when the politically connected come knocking.

History suggests that in emerging markets, that second test is the one that matters — and the one most frequently failed.