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Some Additional Thoughts On BSIC: Potential Risks, Second-Order Consequences, and What Bangladesh’s Startup Ecosystem Still Needs

On May 12th, thirty-nine Bangladeshi commercial banks launched Bangladesh Startup Investment Company PLC (BSIC), unveiling its inaugural fund, Onkur Bangladesh Fund 1, with committed capital of Tk 425 crore — roughly $35 million. 

In short, BSIC is Bangladesh's first institutionally governed venture capital platform. The firm is formed under Bangladesh Bank's guidance to pool the mandatory 1 percent of annual bank profits into a single, professionally managed vehicle targeting late-seed-to-Series A startups. The requirement by Bangladesh Bank for banks to invest in startups was first introduced in 2021 but didn’t result in any meaningful deployment in practice. The new structure is expected to change that. 

We covered the launch in detail here.

This piece aims to do two things. It is a follow-up on our coverage of the announcement, and then we try to ask a few clarifying questions around what BSIC gets right, potential sources of risk for the firm, and what it all means for Bangladesh’s startup ecosystem. 

The backdrop

The past two and a half years have been remarkably quiet for Bangladesh's startup scene. Funding has become sporadic, new company formation has slowed, and ecosystem activity has dimmed. 

Part of this is global: the end of the Zero Interest Rate Policy era drained the abundant liquidity that powered venture investing worldwide. When safe assets started offering real returns again, institutional capital retreated to proven territories. 

Bangladesh felt the slowdown more sharply than many other markets, with an almost complete collapse of the startup funding in the country.

The global cycle is only part of the story, though. 

Bangladesh has structural constraints that sit underneath any capital cycle, which we discussed at length here. In short, most international VCs have no geographic mandate for Bangladesh, which falls awkwardly between India and Southeast Asia in how investors carve up the world; there is no meaningful domestic capital base; the policy environment pays lip service to startups while doing little to lower the actual cost of building them; and there are real gaps in founder execution quality relative to peers in the region. 

These problems require sustained, deliberate work to resolve.

BSIC addresses one of them: the absence of domestic institutional capital at the late-seed to Series A stage. 

That is an important problem. But being clear that it is one of several challenges is important to assess what BSIC can reasonably achieve. 

At the same time, it is important to understand the context in which BSIC exists—the extent of the local capital challenge and whether a Bangladesh Bank-mandated VC firm is the only right approach to solving the local capital gap. 

What BSIC gets right

BSIC is a meaningful improvement on its previous iteration. It creates a separate legal entity rather than asking banks to invest from their own balance sheets. This explains why the previous approach produced almost nothing. Since 2021, Bangladesh Bank required banks to allocate 1 percent of annual net profits to startup investment. Less than Tk 5 crore of a pool exceeding Tk 100 crore was ever deployed. 

Commercial banks are built for credit risk. Asking them to take equity positions in early-stage companies from within their own balance sheets ran against every incentive and process they had. The mandate existed on paper. The institutional machinery did not.

BSIC puts the same mandated capital into a separately governed entity with its own investment mandate, its own people, and its own accountability. The banks become shareholders. Their exposure is capped. If the portfolio performs, returns come back as dividends and capital appreciation. That structural fix produces an independent investment firm, a clear improvement that the previous five years never attempted.

The capital structure is also well designed with an annual inflow of approximately Tk 200 crore from ongoing bank contributions, making BSIC self-replenishing. 

In venture capital, follow-on capacity — the ability to support portfolio companies through difficult fundraising periods and double down on what is working — is a meaningful part of how returns are built. A fund that keeps receiving capital has that flexibility.

A four-layered governance framework: a local investment team for deal sourcing; an investment committee of professional VC practitioners; an advisory board; and the shareholder bank board above it, is also a meaningful structural improvement. 

Part of the intention may be to keep investment decisions insulated from the banking culture above. At the same time, the structure, if followed through on, should allow the firm to operate more effectively. 

However, it remains to be seen how the firm operationalizes aspects of the structure that appear more fluid rather than rooted in the organizational foundation itself. 

Potential risks for BSIC to look out for

As the firm begins operation, we will be watching a few things. 

First, the independence of the investment committee from the board. On paper, investment decisions sit with VC practitioners. In practice, the board draws its executive directors from bank managing directors, and those banks are the shareholders. 

When early investments underperform, and some will, the pressure on the investment committee from above will be likely. Whether the four-layer structure holds under that pressure will define the character of this institution over time.

The second will be the coordination and alignment. Thirty-nine shareholders with varying levels of enthusiasm can easily turn into a real governance challenge. Getting meaningful alignment on decisions that require conviction and speed, across so many institutions, will require active and continuous management. 

Multi-stakeholder bodies with large, heterogeneous shareholder bases tend toward either capture by the largest shareholders or slow institutional paralysis. Albeit this can be our imagination, and it is not something predetermined. But both are worth watching for.

A third concern comes from the dual mandate. Bangladesh Bank Governor Md Mostaqur Rahman asked BSIC to prioritize the rural economy. That is a legitimate social objective, and one worth taking seriously. It can also sit in tension with the commercial return expectations of 39 shareholder banks and the return profiles of any international co-investors BSIC may bring in alongside. 

Institutions that try to optimise for both commercial returns and social distribution mandates simultaneously tend to deliver mediocre outcomes on both. Resolving which is primary before the first investment will save BSIC considerable difficulty later.

Additional government challenges can come from two other sources. One, government mandates can also bring meaningful governance challenges in a market like Bangladesh, something we don’t feel needs further explanation for discerning readers. 

Second, the structure brings in many practitioners and external players into the investment decision-making process. Many of these actors may have their own investments and portfolio companies that are raising capital, and they may tend to prefer them for BSIC to invest in as well. 

One might argue that what’s wrong with that if the company is solid and the deal is done in a proper manner. The problem is a conflict of interest. It creates a self-dealing situation where people making critical investment decisions are, in a sense, investing in their own companies. If you allow these tendencies once, it can destroy the quality of the overall decision-making process of an organization in no time. 

Then there is the tension Tammer Qaddumi of VentureSouq named at the launch: the banks backing BSIC may eventually hold stakes in companies taking market share from their own businesses. Fintech companies displacing bank fee income, logistics platforms competing with trade finance, and agri-marketplaces disintermediating rural lending are precisely the businesses that would disadvantage the 39 institutions funding it. 

That said, the governance architecture is designed to handle some of these tensions. The structure has potential. But execution will determine whether it holds, whether the investment committee can maintain operational independence from the board. After all, structures are easy to craft on paper and hard to operationalize in the messy world of practice. More so if that structure is not a fundamental organizational necessity and is not aligned with the incentives of the key players in an organization.  

Exit pathways are a longer-horizon concern. BSIC plans to exit from 2029 onward through DSE listings or direct stake sales. Bangladesh's capital market has not successfully absorbed a startup-stage technology company at a reasonable valuation. The analyst coverage, valuation frameworks, and institutional appetite for high-growth pre-profitability businesses simply don't exist on the DSE today. If the exit strategy depends on a market that isn't ready to receive the portfolio, no amount of good upstream investing fully compensates.

These are some of the operational questions that we think require thinking and will only be crystallized as the firm begins full operation. 

The second-order questions

That was about BSIC and what we hope the firm will eventually deliver. But the concern we keep coming back to isn't about any risk inside BSIC. It is about what BSIC's existence means for the private venture capital ecosystem that Bangladesh actually needs to build. That is more of a policy question. 

Simply put, what Bangladesh's local startup capital problem ultimately needs is a functioning private venture capital industry: multiple independent firms, professional managers with carried interest structures, a demonstration effect from successful exits, and private institutional capital forming habits of investing in high-growth startup companies. 

That ecosystem, once built, sustains itself without mandates or government direction.

Unfortunately, over the past ten years, despite various government-led initiatives, that private ecosystem has not materialized. 

Seventeen SEC-licensed Alternative Investment Fund Managers exist, but most haven't raised meaningful capital. Local wealthy capital flows overwhelmingly to real estate and traditional business. Local conglomerates tend to do everything in-house or invest within their own circle. There is hardly a local M&A culture. The policy environment has done little to change that calculus.

Part of BSIC's stated aim is to build that missing local capital base, but seen from a particular policy perspective, the risk is that it can clearly exacerbate the problem it is founded to solve, particularly on two fronts. 

The first runs through policymakers. Once BSIC is operational and deploying capital, the political incentive to address the underlying regulatory environment that makes private VC formation difficult — tax incentives for angel investing, cleaner equity registration, forex repatriation for foreign co-investors, a capital market capable of absorbing startup exits — weakens considerably. The problem appears solved. 

When policymakers do the solution instead of creating an environment where many solutions can come from private sector players, the trade-off for the policymakers is easy: why bother? This is always the risk of policy-making. You are always making a trade-off. If this happens, it means the structural work enabling a private ecosystem remains undone.

The second runs through private capital. Bangladesh has substantial privately held family wealth that has had no structured channel into startups. Rahat Ahmed of Anchorless made the point at the launch that because BSIC's backing banks are institutions wealthy families already trust, BSIC gives local private capital a credible channel to co-invest alongside them. That is a genuine opportunity in the short term. 

The longer-term risk, however, is that family offices and wealthy individuals route their startup exposure through BSIC rather than backing independent private fund managers. BSIC, being government-adjacent and bank-backed, carries the implicit safety of institutional endorsement. A first-time private fund manager running their first vehicle carries none of that. If the rational short-term choice for private capital is BSIC over an independent VC fund, every taka that takes that route delays the formation of the private ecosystem Bangladesh needs over the long run.

This isn't an argument against BSIC. It is a flag that BSIC's launch needs to be paired with deliberate policy work, making private VC formation easier and more attractive so that the two grow together.

The deeper problem

We see a pattern in how Bangladesh's government has approached the startup ecosystem challenges so far, and BSIC sits squarely within that pattern. 

When policymakers see a gap — in funding, in support infrastructure, in early-stage capital — the instinct is to fill the gap directly. The government creates the fund. The government runs the accelerator. The government mandates the bank. The government builds the incubator. 

The response to a private sector absence has been a strange public sector substitution. That, for good reason, doesn’t work if you want to build a sustainable and competitive ecosystem. 

What has received far less attention, across every wave of government initiative, is the complementary work: making Bangladesh a place where the private sector has genuine reason to participate. 

The tools for this are well understood. 

Tax incentives that make angel investing and VC fund formation attractive. A carried interest framework that allows professional fund managers to build sustainable careers. Equity registration processes that don't add weeks of friction to every deal. Forex repatriation rules that don't create structural hesitation for foreign co-investors. Company law that accommodates startup-specific instruments: SAFEs, convertible notes, founder vesting, ESOP frameworks. A capital market with a realistic pathway for growth-stage companies to list and exit. 

None of these requires the government to deploy capital or partner with a development sector entity to launch an accelerator program or mandate banks to launch a VC fund. 

They, however, require serious and sincere long-term policy work, which is less visible than a fund launch and harder to fit into a press event.

As we wrote in July 2025, the recurring pattern with government financing initiatives is that they address the visible symptom — the absence of capital — while the underlying conditions that would enable private capital to flow remain unchanged. 

BSIC may improve meaningfully on the governance and structural side. It does not change the fundamental character of the approach: government directing capital into a space that a private ecosystem would ideally occupy on its own terms. 

That pattern is important to notice and understand because it shapes what needs to happen alongside BSIC for any of this to add up to something durable.

Endnote 

With BSIC coming into operation, one interesting convergence can happen. Startup Bangladesh Limited is launching a Fund of Funds with an initial corpus of $33 million, anchoring privately managed venture funds at the pre-seed and seed stages. This is closer to what Korea's KVIC model looks like — government as anchor LP enabling private managers rather than government picking companies directly. That framework has mobilized ₩12.3 trillion KRW across 74 funds and 654 Korean startups since 2013 while building a generation of professional local fund managers. 

In the context of Bangladesh, SBL's fund-of-funds can work at the earliest stage, BSIC as a direct investor at late-seed to Series A. The two institutions together can work as a more deliberate approach to the domestic capital problem.

However, this will only work if there are meaningful coordination efforts. Usually, different government initiatives in Bangladesh prefer not to talk to each other. BSIC and SBL have to overcome this tendency to make a meaningful synergistic play. 

So far, there is no publicly available information regarding where both organizations stand in terms of collaboration. If this doesn’t happen, more than limiting their respective impact, it also runs the risk of duplicated effort at a moment when the ecosystem cannot afford it.

That said, again, the regulatory gaps remain. BSIC can put equity into a company. It cannot fix the friction foreign co-investors face repatriating returns, or simplify the equity registration processes that slow deals, or build the capital market conditions its own exit strategy depends on. 

And neither BSIC nor SBL directly addresses the harder structural challenges such as the operator quality and lack of global exposure that put Bangladeshi founders at a disadvantage in competitive fundraising environments, the mandate problem keeping most international VCs from including Bangladesh in their deal flow, and the cultural work needed to bring new founders and new private capital into the ecosystem. Capital helps. It is not the only input.

BSIC is a serious institutional attempt to fix a problem that previous mandates failed to dent. The separation of venture risk from bank balance sheets and putting a proper operational structure in place significantly improves its chance of success. The recurring capital mechanism is excellent. 

Taken with SBL's Fund of Funds, the ecosystem now has a two-layered domestic capital structure it has not had before. For a remarkably quiet scene, this matters.

The risks and potential policy trade-offs we discussed here are serious, but none is immediately fatal if policymakers put parallel efforts into solving them. 

BSIC launch has created a new sense of optimism and momentum, and policymakers should respond to it by taking on the other more critical structural challenges in the ecosystem. 

This moment presents us with a new opportunity to pair a new institution with the regulatory reform work — on equity registration, foreign capital repatriation, angel investment incentives, and capital market development — that makes the private ecosystem around it possible. And to be deliberate about the second-order effects: ensuring that BSIC's arrival does not become a reason for private capital and government attention to step back from the longer, harder work of building a self-sustaining venture ecosystem and enabling an entrepreneurship policy environment.

Bangladesh's founders and the companies they are building deserve both the institution and the ecosystem conditions around it. 

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Mohammad Ruhul Kader is a Dhaka-based entrepreneur and writer. He founded Future Startup, a digital publication covering the startup and technology scene in Dhaka with an ambition to transform Bangladesh through entrepreneurship and innovation. He writes about internet business, strategy, technology, and society. He is the author of Rethinking Failure. His writings have been published in almost all major national dailies in Bangladesh including DT, FE, etc. Prior to FS, he worked for a local conglomerate where he helped start a social enterprise. Ruhul is a 2022 winner of Emergent Ventures, a fellowship and grant program from the Mercatus Center at George Mason University. He can be reached at ruhul@futurestartup.com

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