🔬 Niramoy
Market Research Dossier · Bangladesh · July 2026

The Evidence Base

Every figure in the proposal, traced to a named source and a year. And — just as important — an honest register of what could not be verified, so that no decision rests on a number that isn't real.


Scope
5 research streams
Market · Ambulance · Tourism · Competition · Regulation
Prepared By
Mahfuz Akand
উত্তরা, ঢাকা
🔒 Confidential Dossier v1.0 · July 2026
📐 Method

Numbers you can defend in the room

Most market decks in this category recycle statistics that dissolve the moment anyone checks them. This dossier does the opposite: each figure carries a source and a year, contested figures are shown as contested, and unverifiable claims are named and excluded rather than quietly rounded into the argument.

Figures sourced60+
Contradictions surfaced4
Claims rejected as unverifiable6
Open legal questions10
01 — The Core Argument

The thesis, in one chain

Four verified facts that link into a single, defensible argument. If any one of them were false, the business case would weaken. None of them are.

1
Bangladeshis pay for healthcare out of their own pockets — more than almost anyone on earth.

79.31% of health spending is out-of-pocket (2023), and it is rising while India, Pakistan, Nepal and Sri Lanka all trend down. Verified directly from the World Bank API (indicator SH.XPD.OOPC.CH.ZS; raw value 79.30711365).

2
A quarter of that money goes to diagnostics.

27.52% of out-of-pocket spend is diagnostic services — the second-largest category after medicines (54.40%). Consultation is only 10.31%. This single number is the TAM narrative: the money is in tests, not appointments.

3
That diagnostics market is structurally rigged against the patient.

Diagnostic centres pay referring doctors 20–50% commissions. The same test varies up to 32× in price between facilities. And ~95% of private facilities operate on un-renewed licences.

4
The rails to fix it are already in every hand.

72.4% household smartphone ownership, 89 million active mobile-money accounts, Tk 1.71 trillion moving through MFS every month. Checkout is a solved problem. Trust is not.

The quote that does the most work

The president of the Bangladesh Medical Association, Mustafa Jalal Mohiuddin, has publicly called referral commissions "a crime."

When the doctors' own professional body concedes the practice is indefensible, the reform argument stops being an outsider's complaint and becomes an insider's admission. Use it.

02 — Health Expenditure

What Bangladesh spends — and the growth story that isn't

Indicator20222023Source
Current health expenditure (% of GDP)2.22%2.17%World Bank / WHO GHED
Health expenditure per capitaUS$56.62US$53.46World Bank / WHO GHED
Out-of-pocket (% of health spend)78.25%79.31%World Bank / WHO GHED
Derived total health expenditure: ~US$9–9.5bn (2023) — calculated from GDP × 2.17%, cross-checked per-capita. Labelled as derived, not sourced.

⚠️ An honest correction to the obvious pitch

Per-capita health spending in USD fell from $56.62 (2022) to $53.46 (2023), and its share of GDP fell too. Much of that is taka depreciation rather than a real-terms collapse — but it means you cannot honestly claim "rapidly growing health expenditure" from WHO data. Anyone who does is either not checking or hoping you won't.

The growth story is real, but it lives in two specific places: the private/out-of-pocket segment, and the public budget — which doubled to Tk 69,409 crore (1.02% of GDP) in FY2026-27, crossing 1% for the first time.

The impoverishment number

3.7%of the population — about 6.13 million people — were pushed below the national poverty line by out-of-pocket health payments in 2022
BIDS / BNHA
187/191Bangladesh's world ranking for health spending as a share of GDP — among the very lowest
WHO, via secondary source (2022)
Tk 69,409crFY2026-27 public health budget — doubled year-on-year, first time above 1% of GDP
The Financial Express, 2026
54.40%of out-of-pocket spend goes to medicines — the largest category. Diagnostics (27.52%) is second.
BNHA / BIDS, 2021 data

Two official OOP figures exist and a sharp reader will catch the discrepancy. WHO/World Bank says 79.31% (2023); Bangladesh's own National Health Accounts says 73% (2021 data). Both are real — different methodologies. Cite WHO/World Bank for international credibility, and cite it precisely.

03 — The Supply Side

Fragmented, unverified, and therefore aggregatable

The supply side is a mom-and-pop industry with almost no licensing discipline. That is precisely the profile a trusted aggregation layer can consolidate.

WhatNumberSource
Registered physicians134,568 — of whom ~36,000 practise without renewed registration (roughly 1 in 4)BMDC, Nov 2024
Doctor density5.26 per 10,000 — second-lowest in South Asia. Doctors+nurses+midwives: 9.9 vs the WHO SDG threshold of 44.5WHO
Diagnostic centres10,291 (BBS survey of operating institutions) — or 35,597 (DGHS registrations)BBS 2021 / DGHS 2025
Private hospitals & clinics4,452 + 1,397 (BBS) — or 19,627 (DGHS)BBS 2021 / DGHS 2025
Share of hospital beds in private hands~67% (105,183 private vs 52,807 public)BBS, 2021
Ownership structure44% sole proprietor · 40% partnership — a fragmented, capital-poor supply side with no bargaining power and, critically, idle capacity to sell.

The two facility datasets conflict badly and must never be averaged. BBS is a survey of operating institutions (fieldwork c. 2019–21). DGHS is a registration database (2025) that likely includes defunct and duplicate entries. Present both, name the difference, and let the regulatory chaos itself make the argument for a verified discovery layer.

The licensing collapse — the strongest single statistic in the dossier

🏥

Hospitals & clinics

Only 914 of 19,627 (4.66%) renewed their licences in the fiscal year to 27 April.

🧪

Diagnostic centres

Only 1,790 of 35,597 (~5%) renewed.

~95% of private healthcare facilities in Bangladesh are operating on un-renewed licences (DGHS, 2025), and DGHS lacks the manpower to inspect them. Enforcement drives are live and ongoing through 2026 — 37 facilities sealed in a single day; ~1,000 unregistered centres shut.

Implication for the product: a valid DGHS licence must be a hard gate for listing. Listing an unlicensed centre and taking money for bookings there is the fastest route to being named in a DGHS raid.

04 — Price Variance

The same test, up to 32× the price

This is the clearest product-shaped hole in the market. There is no mandated price list, no published tariff, and no comparison mechanism. As one headline put it, private diagnostic facilities "charge at will."

TestGovernmentTrust-runPrivateMax spread
Lower abdomen ultrasoundTk 110Tk 1,200–3,50011×–32×
Serum creatinineTk 60Tk 220Tk 5008.3×
Lipid profileTk 300Tk 850Tk 1,6505.5×
RBSTk 60Tk 170Tk 3205.3×
ECGTk 80Tk 230Tk 400
Brain MRITk 3,000Tk 11,5003.8×
Brain CT scanTk 2,000Tk 7,5003.75×
CBCTk 150Tk 300Tk 4002.7×
Private facilities charge up to ~20× government rates on average, and as much as 32× on individual tests. Colonoscopy runs Tk 2,500 (government) to Tk 25,000+ (private) — a 10× spread.

Source: New Age, 12 August 2022. The prices are now ~4 years stale — but the ratios are the story, and nothing has happened since to compress them. Do not present these as current retail prices; present them as evidence of structural dispersion.

💡 The demand signal nobody is reading

A whole cottage industry of "test price in Bangladesh" SEO websites exists — low-quality aggregators competing for search traffic on diagnostic pricing queries.

That industry exists because patients are actively searching for price transparency and being served junk. The demand is already expressed, already measurable in search volume, and currently unmet by anyone credible. That is the wedge — and it is the reason the Google Search campaign in the growth plan is built on price-comparison intent rather than brand awareness.

05 — Ambulance / EMS

There is no emergency medical system. There is a phone number.

89.3%of the time, ambulances sit idle. Utilisation is 10.7%; patient satisfaction 1.8/4
Hossain et al., IJCCEM, 2022
35–40 minaverage time from calling 999 to receiving service — against a 15-minute clinical survival benchmark
BSS, 2025
4,821registered ambulances in Dhaka (7,076 nationally)
BRTA, May 2021 — no verified later count exists
Tk 35–40per km — the government's own reference rate. Nobody in the market uses it. Syndicates charge 2–3×
Prothom Alo, 2025
📞

999 owns no ambulances

The national emergency number exists — but it is a call-routing desk, not an EMS.

  • It phones third-party private operators; the ambulance is not free
  • ~24–25,000 calls/day on roughly 80 incoming lines
  • Academic finding: Bangladesh "lacks a dedicated prehospital emergency medical system" (TraumaLink, GHSP, 2022)
  • Ambulances are parked at hospitals and fetched on demand — no CAD, no medical priority dispatch, no SOPs
🚫

No meter exists anywhere

Price is negotiated at the point of maximum distress.

  • No metering, no universal rent chart, no monitoring authority
  • No national ambulance policy — a draft was submitted in 2016 and never acted on
  • Most Dhaka "ambulances" are converted microbuses with a stretcher and an often-empty oxygen cylinder — no cardiac monitor, no trained paramedic
  • Advertised Dhaka rates: in-city Tk 1,500–3,500; ICU Tk 8,000–18,000; Dhaka→Chattogram Tk 12,000–25,000

🔴 The syndicates are a physical competitor — and they have killed people

This is not a rhetorical risk. Ambulance syndicates control hospital gates, block outside ambulances, and take roughly half the fare as a cut from any vehicle from another district.

  • A newborn died in Shariatpur after a local drivers' syndicate blocked an out-of-town ambulance for 40+ minutes (August 2025)
  • A 70-year-old man died after his ambulance was stopped twice and held roughly 1.5 hours (January 2026)
  • Seven syndicate members were arrested at Rangpur Medical College Hospital for forcing patients into specific ambulances at inflated fares (June 2026)
  • Courts in Chattogram have ordered crackdowns; DGHS has launched drives against broker syndicates

Strategic consequence: an app that dispatches an outside ambulance to a hospital gate will collide with these people. The answer is not to fight for the gate — it is to contract with hospitals for gate access, so the platform arrives as an invited partner rather than an intruder. This must be solved commercially before it is solved in software.

Prior attempts — the graveyard

WhoWhat happened
URAL EMS (2018)Launched as "Bangladesh's first app-based ambulance service." Its Play Store listing now 404s and its domain no longer resolves. Dead.
SafeWheelStarted with on-demand rural ambulances — pivoted away to a medicine-delivery marketplace.
AmbuFast (Jan 2025)Alive but shallow: ~2 App Store ratings, no update since April 2025. Funded by a retail-investor scheme, not institutional VC.
TraumaLink (NGO)Not a competitor — a proof of concept. A volunteer SMS-dispatch network achieved ≤5-minute response in 88% of incidents across 3,119 patients. Distributed dispatch demonstrably works in Bangladeshi conditions.
Read this correctly. A weak field does not mean an easy market — it means nobody has proven the unit economics yet. Ambulance is a trust asset, not a revenue engine: it is a once-a-year emergency with poor retention. It earns the brand; diagnostics and tourism pay the bills.

Demand driver — road deaths, and why you must cite two numbers. Road Safety Foundation counted 7,359 killed in 2025; the official BRTA figure is ~5,490; the WHO estimates 31,578. The 4–6× gap between official and WHO figures is itself a well-documented fact. Cite both and name the discrepancy — using only one will get you challenged.

06 — Outbound Medical Tourism

The only line with a ticket size that carries a commission

$4–5bnspent abroad on treatment each year — more than the entire national health budget
Governor, Bangladesh Bank (Ahsan H Mansur), 2025; DCCI
450k–800kpatient journeys abroad per year (range, because many travel on tourist visas)
The Daily Star, 2024–25
482,336Bangladeshi medical arrivals in India in 2024 (falling to 325,127 in 2025)
India Ministry of Tourism
52–70%of all of India's foreign medical tourists are Bangladeshi
ORF, 2025

🔴 Read this before writing any strategy: India reopened on 28 June 2026

After a near-two-year freeze following August 2024, India resumed all visa categories for Bangladeshi nationals on 28 June 2026 — roughly three weeks before this dossier was written. All five IVACs moved to an automated time-slot system from 1 July 2026.

Any plan built on "India is closed and patients are stranded" is already obsolete. The rerouting to Thailand and China is real and it created the opening — but the corridor is reopening right now. The module must be multi-destination from day one, with India modelled as recovering rather than gone.

Sources: BSS (Bangladesh state news agency), Business Today, bdnews24, The Daily Star — June/July 2026.

Destinations — and the real constraint on each

DestinationRealityCost level
🇮🇳 India~50–60% of patients. Land border, no visa fee (Tk 1,500 processing). Reopened 28 June 2026. During the freeze, Kolkata hospitals lost up to 75% of volume — proof of how dependent they are on this flow.Cheapest
🇹🇭 Thailand~65,000 patients/yr. 60% of all Bangladeshi visa applications to Thailand are medical. MedPark Bangkok reports ~300% YoY growth. But ~80% of patients consider Thailand after an Indian visa failure and abandon it once they learn the cost.10–15× India
🇨🇳 China (Kunming)New and state-backed. ~600 patients treated by Aug 2025. One-day "green channel" visas. Bengali/English interpreters, halal food, dedicated wings.~¼ of Thailand
🇲🇾 MalaysiaRecord RM 10.4m revenue from Bangladeshi patients (2025). MHTC held Malaysia Healthcare Week in Dhaka (April 2026) and its CEO publicly said they want to partner with "local healthcare facilitators."Mid
Best-sourced cost fact in the dossier (journalism, not facilitator marketing): liver transplant workup — India $1,000–2,000 vs Thailand $10,000–15,000. Cardiac stent — India ~$2,000 vs Thailand $5,000–20,000. Al Jazeera, Jan 2025. This 5–10× gap explains why patients cannot simply switch destinations.
🗣️

The sharpest wedge in the entire research

Kunming's binding constraint is not medicine or cost. It is language — and the price of solving it is explicit and public.

  • Interpreter: ¥500 (~Tk 9,000) for the first session, then ¥200–300/hour
  • Only one direct Dhaka–Kunming flight

Bundle a vetted Bengali-speaking interpreter into a Kunming package and you have solved a concrete, priced, monetisable problem — not a slogan. This is the most actionable single finding in the dossier.

🎯

Someone is already building this module

Rhythm Group (Bangladesh) × Manipal Hospitals (India) signed a medical-tourism deal in April 2026 — explicitly including a digital video-consultation platform so Bangladeshi patients can consult Indian specialists before travelling.

That is our tourism module, roughly three months ahead of us. It goes in the deck by name. A client will find it in thirty seconds; better they hear it from us, with a differentiation answer ready (multi-destination, published fees, interpreter bundle).

Commissions — what we know, and what we're assuming

Facilitators typically earn 10–15%, up to 30% at the extreme; quotes are commonly padded 25–35% to absorb it. Critically, the fee is baked invisibly into the bundled price the patient is quoted — the patient never writes a separate cheque and generally does not know the commission exists. That opacity is exactly what a transparent platform disrupts.

⚠️ No verified Bangladesh-specific commission rate exists in any public source. This is the single most important number in the revenue model and it is not published anywhere. We model 10–15% and label it an assumption — never a fact. It must be confirmed by talking directly to facilitators and hospital international-patient departments.

07 — Competitive Reality

The all-in-one health app is the default idea here, not a contrarian one

This is the finding most likely to change your plan — and the one a competitor's deck will never tell you. The bundle is not the moat.

PlayerBundleStatus & weakness
Sasthya SebaListing · Telemed · Lab · Ambulance · Medical tourismShips our exact feature list — on a €5,000 grant. Essentially unfunded, call-centre-driven, weak brand. Living proof that the bundle isn't the differentiator.
Shukhee (Grameen)Listing · Telemed · Lab · AmbulanceLaunched Nov 2024 with Grameenphone + Robi distribution. 2.8M installs but only ~49,000 consultations — a 1.7% activation rate. Telco-bundle enrolments are not customers.
AroggaPharmacy → Lab → Teleconsult$5.7M raised — roughly 45% of all Bangladeshi health-tech funding ever. Has the transaction, the repeat customer and the logistics. The most dangerous competitor.
Praava HealthOwn clinics + labs + telemed$10.6M (2021) — best funded. Owns clinics, so owns the burn. Has been hunting a $15M Series B for ~5 years without closing it.
DoctorolaDoctor listing + appointmentsThe cautionary tale. Founded 2015, raised $250K. In 2026: 8 employees, zero press since 2016. It didn't blow up — it ossified.
Tonic (Grameenphone)Telco health membership☠️ Dead. ~6M "members." Free service killed July 2021; IVR killed August 2021.
Rhythm × ManipalMedical tourism + pre-travel video🔴 New — April 2026. Building our highest-margin module.

The five failure modes to design against

📵

1. The telco-freebie trap

Bundle into a free telco tier, report millions of "members," discover none will pay when the free tier ends. Tonic died of this. Shukhee is repeating it live.

📃

2. The listing-only trap

Doctors won't pay for leads; patients won't pay booking fees; you become a call centre. Doctor listing is a feature, not a business.

🎁

3. The grant trap

Optimise for donor metrics ("lives impacted") and you build something that cannot survive without donors.

🏗️

4. The capital-intensity trap

Own the clinics and you own the burn. Praava raised the most money in the sector and still can't close a Series B.

📉

5. The macro trap

Bangladesh startup funding: $435M (2021) → $72M (2023) → ~$41M (2024), a six-year low. 2025's "$124M" headline is a mirage — $110M of it was a single late-stage M&A.

⇒ The rule this forces

Bangladeshi health-tech has raised $12.6M in total, ever, across 15 funded companies. This business must reach profitability on revenue. Nothing may depend on raising a Dhaka Series A.

What every profitable global analogue has in common

CompanyWhere the money actually comes from
Practo (India)~35% SaaS sold to doctors (EMR/billing), teleconsult, corporate wellness. FY25 was its first full year of profitability.
Tata 1mg (India)Pharmacy + own-lab diagnostics margin. ₹2,392 crore FY25.
Apollo 24/7 (India)Works because it feeds an owned hospital chain.
Ping An Good Doctor (China)Became profitable by selling to insurers and employers instead of consumers. 2025 net profit RMB 379.5m (+366%).
Halodoc (Indonesia)Pharmacy + insurer/corporate deals. ~US$210M revenue FY2025.
Not one of them makes money from consumers booking doctors. Referral and booking are the acquisition layer — never the revenue layer. Any model that forgets this dies as Doctorola did.
08 — Regulation

The law rewrites the product — and hands us a moat

This section is the most valuable in the dossier. Most competitors either do not know these rules or are quietly breaking them.

🔴 The standard marketplace revenue model is very likely illegal

  • BMDC Code §4.3.2 — a doctor "shall not share his professional fees with any person other than the bona fide partners of his practice." A platform is not a partner. Taking a percentage of the consultation fee — the default telemedicine model worldwide — is therefore very likely prohibited.
  • BMDC Code §4.3.1 — a doctor may not accept from any organisation "any financial or other inducement" — explicitly including free or subsidised consulting premises or secretarial supportfor referral of patients for consultation, investigation or treatment. Paying doctors for referrals, in cash or in kind, is out.
  • Telemedicine Guidelines §7.6BMDC may blacklist a platform, after which no doctor may lawfully use it.

It is currently professional misconduct, not a crime, and it binds the doctor rather than the platform. But a platform that induces it can be blacklisted, and a Health Protection Act is being drafted that may criminalise the arrangement. Build so that a statutory ban would not kill the business.

What we CAN do

  • Patient-side booking fee, separately itemised, with the doctor's fee passed through intact — this avoids §4.3.2 fee-sharing entirely. The cleanest structure available.
  • Flat SaaS / listing subscription to facilities — not tied to volume or referrals.
  • Transparent, disclosed facility-side technology fee on patient-initiated bookings. §4.2.2 contemplates "administrators, agents, brokers, middlemen" provided the financial arrangements are disclosed to all parties. Grey — needs written legal opinion.
  • Medical tourism commission from foreign hospitals, disclosed to the patient.

What the advertising code forbids

BMDC Code §3 captures publicity by "anybody acting on his behalf" — our marketing of a doctor is caught by it.

  • No star ratings, rankings, or "Top/Best Doctor" — comparative and superiority claims are barred (§3.2b)
  • No patient testimonials or reviews — §3.4.3 requires that letters of gratitude not be published, and that doctors actively discourage them
  • No paid or sponsored doctor placement
  • No push notifications / SMS / email promoting specific doctors (§3.5.4)

⇒ Build a neutral directory card: permitted fields only, uniform styling, sorted by objective non-comparative criteria (availability, specialty, location, fee) — never by rating or paid rank.

The rest of the compliance surface

AreaThe ruleWhat it forces
TelemedicinePaid video consults are explicitly legal (BMDC Telemedicine Guidelines 2020, §5.8.3.1). But the platform must verify BMDC registration, display every doctor's registration number, provide a grievance channel, and record consent.Verification is a legal duty, not a feature.
AI§7.4 — AI/ML platforms may NOT counsel patients or prescribe. AI may assist and support only; the doctor must deliver the prescription.No AI symptom-checker that diagnoses. Assistive only.
E-prescriptionLegal, but bound by a drug matrix: List O (any mode) · List A (VIDEO ONLY) · List B (follow-up) · narcotics/psychotropics never. Drug names in CAPITALS.The matrix must be hard-coded into the prescribing UI so the software prevents the offence.
Data residencyDGHS Telehealth Guideline §5(10): overseas cloud hosting is prohibited unless the provider has a datacentre inside Bangladesh. Personal Data Protection Act passed 10 April 2026.Cannot default to a Singapore/US cloud region. In-country hosting; NDHIE/SeHR integration.
PaymentsHolding patient money and settling it out to hospitals = Payment System Operator territory. Tk 5,00,000 licence, trust account, directors personally liable for shortfalls.Never touch third-party funds. Use a licensed gateway's split-settlement / merchant-of-record model; invoice our fee separately.
Verification toolingBMDC has a form-based lookup, no public API, no bulk registry. DGHS facility lists are stale PDF dumps.Verification is a manual ops workflow with stored evidence and expiry tracking — not a scraper in the critical path.
⚠️ Platform licensingThe DGHS National Telehealth Guideline states that independently operating telemedicine apps need licensing, with a price list approved by the authority. We could not confirm it is gazetted or that the licensing window is operational. Assume a licence is required; confirm with DGHS and counsel before launch.

💡 The strategic inversion — why all of this is good news

The profitable model is illegal. The legal model is boring. That is precisely why nobody has built it properly.

Every constraint above is a barrier to entry for anyone who wants to do this the lazy way — and most incumbents are, right now, quietly non-compliant (ratings, reviews, fee-splitting, offshore hosting). A platform built legally from day one can say something no competitor can safely copy: every doctor's BMDC number is shown, every facility's DGHS licence is checked, and every fee we earn is disclosed on the screen where you pay it.

Compliance is not the tax on this business. It is the product.

09 — Known Gaps

What we could not verify

Stated plainly, because a plan that hides its unknowns fails at the worst possible moment. Nothing below appears as fact anywhere in the proposal.

Bangladesh health-tech market size

The widely-circulated "$70M market / $170M by 2027 / $600–750M TAM" figures trace only to an unverifiable Scribd-hosted PDF. Statista's numbers are paywalled and unread. Excluded from every document.

Dhaka-specific facility counts

No source disaggregates BMDC or DGHS data to Dhaka. We did not invent one. If Dhaka TAM matters, it requires manual extraction from the DGHS registry or a direct data request.

Duplicate/unnecessary test rates

The pain is described extensively in Bangladeshi media, but no study quantifies it. Any deck claiming "X% of tests are unnecessary" is making it up. This is a genuine research gap — and running our own survey would be a proprietary, defensible asset.

The real facilitator commission rate

The single most important number in the tourism revenue model — and it does not exist publicly. No source states what an Apollo or Bumrungrad actually pays a Dhaka facilitator. Modelled at 10–15% and labelled an assumption.

Do agents actually scam outbound patients?

Highly plausible and consistent with the documented domestic dalal (broker) culture — but no investigative report documents it for outbound medical tourism. Presented as a hypothesis to validate with patient interviews, never as a cited fact.

Will hospitals actually pay us?

No public source confirms hospital-chain willingness to accept a third-party referral platform or what take rate they'd accept. Chains with their own apps (Square, Evercare, Ibn Sina) have little incentive. The entire referral thesis rests on this, and it is unvalidated. Twenty primary calls, before any code.

⚖️ The ten questions for a Bangladeshi health-regulatory lawyer

To be answered in writing, before a line of product code is written. Phase 0 of the build exists for exactly this.

  • 1. Does BMDC Code §4.3.2 prohibit a platform taking a percentage of a doctor's consultation fee? (Highest stakes — it determines the revenue model.)
  • 2. Does §4.3.1 reach a platform taking a commission from a diagnostic centre on a patient-initiated booking?
  • 3. What does the draft Health Protection Act say about referral commissions — does it criminalise them?
  • 4. Is the DGHS National Telehealth Guideline in force, and is the app-licensing regime operational? Must we hold a licence before launch?
  • 5. Is a commercial doctor-listing app a lawful "doctors' directory" given §3.4.7 restricts directories to those published by professional medical organisations?
  • 6. Does patient health data held by a private platform fall within "Critical Information Infrastructure," triggering in-country synchronised-copy requirements?
  • 7. Any restriction on a Bangladeshi entity marketing foreign hospitals and earning commission from them — and what FX purpose code applies to that inward remittance?
  • 8. What licence, if any, governs an ambulance dispatch aggregator?
  • 9. Does the 1982 Ordinance itself contain commission, fee, or advertising provisions?
  • 10. Does the Digital Commerce Guidelines 2021 escrow requirement apply — and would complying push us into PSO licensing?
10 — Sources

Primary sources

Every material claim in the proposal, campaign and pitch deck traces to one of these.

DomainSources used
Health expenditure & OOPWorld Bank / WHO Global Health Expenditure Database (indicators SH.XPD.CHEX.GD.ZS, SH.XPD.CHEX.PC.CD, SH.XPD.OOPC.CH.ZS), 2023 · Bangladesh National Health Accounts (BNHA) / BIDS, presented July 2024 · The Financial Express & The Business Standard (budget), 2025–26
Supply sideBMDC registration statistics, Nov 2024 (via Prothom Alo) · BBS Survey of Private Healthcare Institutions, 2021 (via Dhaka Tribune) · DGHS registration & licence-renewal data, 2025 (via The Daily Star) · WHO health labour market analysis
Price varianceNew Age, "Pvt diagnostic facilities charge at will," 12 August 2022 · The Business Standard, "Refer a patient, get a hefty commission"
Ambulance / EMSHossain et al., Int'l Journal of Critical Care & Emergency Medicine 8:138, 2022 · TraumaLink, Global Health: Science and Practice, 2022 · BRTA registration data (via The Financial Express, 2021) · BSS (999 service data), 2025 · Prothom Alo (syndicate fares), 2025 · jagonews24 & TBS (syndicate deaths), 2025–26 · Road Safety Foundation & WHO road-death data, 2025–26
Medical tourismAhsan H Mansur, Governor of Bangladesh Bank (via The Daily Star), 2025 · DCCI, 2024–25 · India Ministry of Tourism / Bureau of Immigration arrival data · ORF, "Medical Tourism as a Pillar of India-Bangladesh Relations," 2025 · Al Jazeera, January 2025 (cost comparison) · BSS, Business Today, bdnews24 (visa reopening), June 2026 · MHTC / PR Newswire, April 2026 · Dhaka Tribune & Prothom Alo (Kunming), 2025 · TBS (Rhythm × Manipal), April 2026
CompetitionTracxn (health-tech Bangladesh) · Crunchbase / PitchBook · TechCrunch (Praava, Maya funding) · The Business Standard (Arogga, Shukhee) · Grameenphone official notices (Tonic discontinuation), 2021 · LightCastle Partners Startup Ecosystem report, 2026 · Startup Bangladesh Investment Report 2025
RegulationBMDC Telemedicine Guidelines, July 2020 (full PDF read) · BMDC Code of Professional Conduct, Etiquette and Ethics (full text extracted) · DGHS National Telehealth Guideline (Feb/May 2026 documents, full PDF read) · Medical Practice and Private Clinics and Laboratories (Regulation) Ordinance, 1982 · Personal Data Protection Act (passed 10 April 2026) · Cyber Security Ordinance 2025 · Bangladesh Payment and Settlement Systems Regulations / draft PSO Regulation 2025 · DGHS 8-point directive, 11 September 2025

Research conducted July 2026 across five parallel streams. Where two official sources conflict (health expenditure OOP share; facility counts; road deaths), both are presented and the conflict named rather than resolved by averaging. Where a figure could not be traced to a credible primary source, it has been excluded — see §09.

Mahfuz Akandমূল সাইটে ফিরুন