Observation (CEACR) - adopted 2025, published 114th ILC session (2026)

Bangladesh

Hours of Work (Industry) Convention, 1919 (No. 1) (Ratification: 1972)
Weekly Rest (Industry) Convention, 1921 (No. 14) (Ratification: 1972)
Weekly Rest (Commerce and Offices) Convention, 1957 (No. 106) (Ratification: 1972)

In order to provide a comprehensive view of the issues relating to the application of ratified Conventions on working time, the Committee considers it appropriate to examine Conventions Nos 1 (hours of work in industry), 14 (weekly rest in industry), and 106 (weekly rest in commerce and offices) together.

The Committee notes the observations of the Trade Union’s International Labour Standards Committee (TU-ILS Committee) with respect to all the above Conventions, received on 1 September 2025.

Hours of work

Article 6 of Convention No. 1. Permanent and temporary exceptions. Circumstances, limits to additional working hours and tripartite consultations. The Committee notes that under several provisions of the national legislation the limits on normal working hours (eight hours per day and 48 hours per week) may be exceeded by two hours per day within an overall weekly limit of 60 hours in a week and on average 56 hours per week in a year, provided that the worker concerned is remunerated at an overtime rate (sections 100 and 102(2) of the Bangladesh Labour Act, 2006 (BLA), section 99(1) of the Bangladesh Labour Rules, 2015 (BLR) and sections 238 and 40(2) of the Bangladesh Export Processing Zone Labour Act, 2019 (EPZLA)). The Committee observes that these provisions do not specify the circumstances under which the normal working hours may be exceeded.

The Committee also notes that under section 102(2) of the BLA and section 40(2) of the EPZLA, the Government may either relax the application of the normal weekly working hours’ limits in certain industries or totally exempt these industries from such limits for a maximum period of six months in the public interest or in the interest of economic development. The Committee observes that: (i) these provisions do not provide for the maximum number of additional hours that are permitted; and (ii) the circumstances prescribed therein do not fall under the circumstances provided for under the Convention. In its observations, the TU-ILS Committee indicates that section 102(2) of the BLA provides for the possibility of exemptions, without requiring tripartite consultations and that the Government has been issuing six-month exemptions under this section permitting extended working hours in the apparel and ready-made garment sector.

Recalling the impact that long hours of work can have on workers’ health and the balance between their personal and working life, the Committee emphasizes the importance of national legislation and practice restricting recourse to exemptions to cases of clear, well-defined and limited circumstances provided under Articles 3 and 6 of the Convention. The Committee also recalls that, pursuant to Article 6(2) of the Convention, regulations on additional hours shall fix the maximum number of additional hours in each instance and shall be made only after consultation with the organizations of employers and workers concerned. The Committee requests the Government to provide its comments with respect to the observations of the TU-ILS Committee. The Committee also requests the Government to take the necessary measures to ensure that: (i) overtime is allowed only under clear circumstances as required by the Convention; (ii) the maximum number of additional hours allowed is clearly set; and (iii) consultations are held with social partners when granting exceptions to ordinary limits of working hours. The Committee also requests the Government to provide information on these measures.

Weekly rest

Article 4 of Convention No. 14 and Articles 7(1) and (4) and 8(1) and (2) of Convention No. 106. Permanent and temporary exceptions. Circumstances. Tripartite consultations. The Committee notes that: (i) section 114(5) of the BLA provides for the exemption of a series of establishments from the rule of the closure of one-and-a-half days per week, without indicating the weekly rest schemes that applies for these establishments; (ii) section 104 of the BLA provides for the possibility of exempting an establishment, or the workers therein, from weekly rest through governmental orders, without specifying the circumstances under which these exemptions may be granted; (iii) section 324(1)(2) of the BLA provides for the possibility to exempt, through a Government notification, any employer or class of employers or any establishment or class of establishments or any part thereof or any worker or class of workers from the provisions of weekly rest in the public or national interest for a period not exceeding six months at a time; and (iv) section 324(3) of the BLA provides that the Inspector General may, by notification in the official Gazette, suspend the operation of weekly rest in respect of any establishment or class of establishments for the purpose of any festival, fair or exhibition, for any such period and on such conditions as may be specified in the notification. In its observations, the TU-ILS Committee indicates that there is no institutional process in place for consulting with employers’ and workers’ organizations on adjustments to weekly rest schemes or for approving special weekly rest schemes based on operational needs or service demands. It also indicates that there is need to develop sector-specific special rest schemes for industries where standard weekly rest cannot be uniformly applied. The Committee recalls that exceptions to weekly rest in the industrial sector should only be established having special regard to all proper humanitarian and economic considerations by virtue of Article 4(1) of Convention No. 14. The Committee emphasizes the importance of all authorized exceptions in the commerce and offices sectors to the normal 24-hour weekly rest period remaining limited to the cases enumerated in Articles 7(1) and 8(1) of Convention No. 106 and of paying due regard to all proper social and economic considerations. In addition, the Committee recalls that Article 4 of Convention No. 14 and Article 7(4) of Convention No. 106 require consultations with employers’ and workers’ organizations regarding the adoption of permanent and temporary exceptions. The Committee requests the Government to provide its comments with respect to the observations of the TU-ILS Committee and to provide detailed information in particular on how often the above provisions are applied in practice. The Committee requests the Government to take the necessary measures to ensure that: (i) all proper humanitarian and economic considerations are taken into account when authorizing exceptions in industry and that consultations are held with representative employers’ and workers’ organizations concerned; and (ii) temporary exemptions from the normal weekly rest scheme in commerce and offices are authorized in law and in practice only for the reasons specified in Articles 7(1) and 8(1) of Convention No. 106. The Committee also requests the Government to provide more detailed explanations on the special weekly rest schemes applicable to the workers exempted under section 114(5) of the BLA.

Application in practice

Articles 2 and 8(1) of Convention No. 1, Articles 2(1) and 5 of Convention No. 14 and Articles 6(1), 7(2) and 8(3) of Convention No. 106. Normal hours of work. Posting of notices and record keeping. Weekly rest. Compensatory rest. Application of working time legislation in practice. The Committee notes that in its observations, the TU-ILS Committee indicates that: (i) concerning hours of work, and despite clear legal limits on working hours, there is inadequate implementation and enforcement, with workers in industries such as tannery, printing and binding, construction and transport often working excessively long hours; (ii) working hours, both normal and overtime, are not clearly posted in subcontracting factories, and small establishments and records are often poorly maintained, falsified and rarely audited, particularly in the informal sector; workers in the apparel and ready-made garment factories often receive rest only every 15 days or more and sometimes work up to 30 consecutive days, facing penalties if they refuse to work on rest days; similar issues occur in banking, factories, malls, pharmacies and tourism; and (iii) the right to a compensatory rest day is frequently violated in practice across various sectors, including tanneries, printing and binding, bakeries, tourism, small shops and malls, where workers often do not receive any compensatory rest. The Committee also notes that the TU-ILS Committee indicates that stronger labour inspection and enforcement mechanisms, including regular and unannounced inspections in vulnerable sectors, need to be carried out and penalties for non-compliance with the relevant obligations need to be imposed. The Committee recalls that without the effective notification and recording of working time and rest periods, it is not possible to assess compliance with the relevant standards. It emphasizes the importance of ensuring that effective mechanisms are in place to guarantee compliance with working-time provisions, primarily through labour inspection and the application of dissuasive penalties for non-compliance as well as through the other mechanisms (2018 General Survey concerning working-time instruments, para. 876). The Committee requests the Government to provide its comments with respect to the TU-ILS Committee’s observations. It also requests the Government to take the necessary measures to ensure that the provisions of the Conventions on hours of work and weekly rest are applied in practice, including measures taken to ensure the enforcement activities in sectors facing challenges.

The Committee is raising other matters in a request addressed directly to the Government.