Bangladesh Bank’s recent move to onboard the Business-to-Business-to-Consumer (B2B2C) framework within the country’s export regime marks an important step toward aligning the foreign exchange regulatory environment with contemporary global digital commerce. On 24 November 2025, the central bank issued a circular expanding the scope of e-commerce exports beyond the Business-to-Consumer (B2C) model to a more integrated supply-chain arrangement that engages globally recognised platforms, marketplaces and warehousing service providers. This policy shift offers significant potential for export diversification, SME participation in global marketplaces, and the broader digital transformation of Bangladesh’s external sector. Yet it also brings to the surface certain operational and regulatory challenges, particularly concerning the repatriation timeline of export proceeds and the treatment of unsold goods, that require thoughtful calibration.
The B2B2C model represents a hybrid cross-border structure where exporters ship goods to an intermediary business which subsequently sells the goods to the end consumer abroad. Unlike traditional exports where the foreign buyer and the exporter are contractually linked, the intermediary in B2B2C is not the final buyer but a facilitator providing warehousing, fulfillment, and global reach. The exporter ships goods under open account arrangements, declares fair value based on proforma invoices, and relies on the intermediary to complete the sales process.
The new circular operationalises this framework by allowing shipping documents to be prepared in the name of consignees such as online platforms, legitimate subsidiaries, or third-party warehouses. Export proceeds may be realised through traditional banking channels or through legitimate payment service providers abroad. Importantly, the settlement of proceeds follows a flexible First-in, First-out (FIFO) matching method, acknowledging that bulk receipts from a platform may correspond to multiple shipments under different EXP Forms. This is a pragmatic recognition of the realities of cross-border e-commerce logistics.
These enhancements open avenues for thousands of Bangladeshi firms to participate directly in global marketplaces such as Amazon, eBay, Walmart, and Alibaba. Until now, the B2C model limited exporters in scale, as they could only sell products individually per transaction, often lacking the branding, warehousing space, or market presence required to build sustainable volume. B2B2C transforms this landscape by enabling exporters to send consignments in bulk to foreign warehouses, from which platforms manage distribution to consumers. This effectively integrates Bangladeshi enterprises into global supply chains, increasing visibility, buyer reach, and potential foreign currency inflows.
The foremost challenge relates to the repatriation timeline for export proceeds. Under the prevailing foreign exchange regulations, exporters must repatriate proceeds within 120 days of shipment. While this timeline is largely feasible for traditional exports or B2C courier-based sales, the dynamics of B2B2C operations are more complex. Export proceeds in this model are realised only after the second-leg transaction when the intermediary business completes sales to ultimate consumers. This can take substantially longer than the current 120-day limit.
Globally, cross-border e-commerce fulfillment often requires extended inventory holding periods, dynamic pricing adjustments, returns management, and seasonal sales cycles. Platforms typically take time to liquidate inventory depending on consumer demand, marketing campaigns, and market saturation. In addition, proceeds are disbursed to registered merchants following cycle-based remittance schedules, sometimes stretching beyond four months. For Bangladeshi exporters operating under strict domestic repatriation timelines, such delays could technically categorise standard marketplace operations as non-compliant even when no malpractice is involved.
Therefore, expanding the regulatory framework to explicitly allow a 180-day repatriation period for B2B2C transactions would significantly align Bangladesh’s policy with international e-commerce realities. The additional 60 days would provide exporters with the operational flexibility required to navigate fulfillment centre timelines, platform payment cycles, and gradual sales turnover. It would also reduce unnecessary pressure on AD banks to enforce rigid monitoring in cases where delays are inherent to the business model rather than attributable to negligence
Another regulatory issue relates to the treatment of unsold goods abroad. In cross-border e-commerce, particularly under B2B2C arrangements, it is common for a fraction of inventory to remain unsold after a sales cycle. Returning the goods to the exporter is often commercially unviable, given the high cost of reverse logistics, customs duties, freight charges, and warehouse storage. The Bangladesh circular, however, does not yet provide explicit guidance on how exporters should account for and document such unsold or discarded goods. Without clarity, exporters and banks may face difficulties in reconciling EXP Forms, closing regulatory files, or justifying inventory discrepancies despite legitimate operational circumstances.
The regulatory framework needs to incorporate flexible, realistic provisions for unsold goods. This may include allowing exporters to declare allowable wastage or write-offs supported by platform-generated reports, warehouse statements, or independent confirmation from logistics providers. Such provisions should specify the documentation required, the valuation method for unsold goods, and the process for closure of EXP Forms in cases where goods must be discarded. Establishing a structured mechanism for this issue would prevent bottlenecks and disputes, and would protect exporters from potential accusations of non-repatriation.
Moreover, the adoption of B2B2C models supports the internationalisation of Bangladeshi enterprises which can encourage foreign investors, venture capitalists, and global logistics players to engage more actively with Bangladeshi enterprises. It also complements government efforts to improve digital payment systems, upgrade logistics capability, and promote startup ecosystems.
As per media coverage, Bangladesh Bank’s move to introduce B2B2C exports within the foreign exchange regulatory framework is timely and visionary. It expands the horizons of what Bangladeshi firms can achieve in global marketplaces and enhances the country’s strategic transition toward a diversified, digitally capable export base. But to fully unlock this potential, the regulations must reflect the operational realities of global e-commerce. By extending the repatriation period from 120 to 180 days and providing clarity on the treatment of unsold or discarded goods, the central bank can reinforce its commitment to facilitating cross-border trade in the digital era. These reforms would position Bangladesh to benefit from the fast-expanding global e-commerce landscape, empower domestic entrepreneurs, and drive sustainable growth in foreign exchange earnings.
