Update | April 2026

Bangladesh: Dhaka Stock Exchange and IIX Partner to Advance the Orange Movement in Bangladesh’s Capital Markets

Matthew Kasdin, GAIL APAC Board Member; General Counsel, Impact Investment Exchange (IIX)

The Dhaka Stock Exchange (DSE) and Impact Investment Exchange (IIX) signed a Memorandum of Understanding to collaborate on the introduction and promotion of Orange capital instruments in Bangladesh on 15 February 2026. Under the MoU, DSE will facilitate the listing of Orange Bonds and Sukuk under a dedicated thematic or sustainable finance category, subject to regulatory approvals. The collaboration will focus on enhancing market readiness, raising awareness, and engaging with regulators to position Orange instruments as credible debt securities on Bangladesh’s capital markets.

The partnership brings together IIX’s global leadership in impact investing and gender-lens finance with DSE’s central role in the development of Bangladesh’s capital market ecosystem. The “Orange Movement,” symbolising the colour of UN Sustainable Development Goal 5 (Gender Equality), aims to mobilise US$10 billion at the intersection of gender equality and climate action. The MoU further outlines plans for joint advocacy, market promotion, and capacity-building initiatives, including workshops, investor engagement programmes, and policy dialogues with key stakeholders.

JAPAN: Blended Finance in Action: Tokyo’s Innovative JPY 10 Billion Affordable Housing Fund

Sotaro Hotta, GAIL APAC Chair; Associate, Nishimura & Asahi

The Tokyo Metropolitan Government (TMG) has launched an Affordable Housing Fund initiative with a total commitment of JPY 10 billion. The primary objective of this initiative is to supply rental housing at approximately 75–80% of prevailing market rates, with a particular focus on supporting child-rearing households struggling with rising rents.

To establish the funds, TMG selected four fund managers through a public solicitation process. TMG will allocate portions of the total JPY 10 billion commitment across these four funds.

Beyond the scale of the commitment itself, what is particularly noteworthy is the structure of TMG’s investment. TMG has adopted a concessional investment approach under which it forgoes returns above a certain threshold and effectively provides preferential terms to other limited partners (LPs).

This structure reflects a blended finance model. As such, it represents a significant example of how blended finance mechanisms can be utilized by local governments in Japan.

MAINLAND CHINA: Charity & Fundraising Regulatory Update – information disclosure and filing 

Giana Lin, GAIL APAC Board Member; Partner of Fuguan Law Firm

In the fourth quarter of 2025, China’s philanthropic sector saw the issuance of significant regulatory documents focusing on information disclosure and the administration of public fundraising activities. Compared with prior regulatory frameworks, this round of reforms places greater emphasis on transparency, front-end compliance, and accountability mechanisms. It marks a shift in regulatory logic from principle-based requirements to more operational and responsibility-driven standards.

I. Administrative Measures for Information Disclosure by Charitable Organizations (Effective January 1, 2026)

On October 1, 2025, the Ministry of Civil Affairs released the revised Administrative Measures for Information Disclosure by Charitable Organizations, which will take effect on January 1, 2026.  Compared with the previous regime, the key changes are reflected in the following aspects: 

First, information disclosure has been upgraded from a principle-based requirement to specifically enumerated obligations. Previously, the scope of disclosure was largely framed in general terms. The new Measures provide more detailed and itemized requirements regarding matters that must be disclosed, including fundraising progress, implementation of charitable programs, and the use of funds. This reduces ambiguity and narrows discretionary interpretation.

Second, disclosure timelines and methods are more clearly defined. Earlier rules were relatively general regarding disclosure timing and update frequency. The new Measures strengthen deadlines for disclosure and set more specific standards for disclosure channels and formats, enhancing verifiability and traceability.

Third, accountability mechanisms have been strengthened. In the past, regulatory focus was often limited to whether information was disclosed. The new Measures emphasize the authenticity, completeness, and accuracy of disclosed information. As a result, false or incomplete disclosures now carry clearer and more direct regulatory risks.

Fourth, disclosure has become a more institutionalized regulatory tool. Information disclosure is expressly positioned as an important basis for inspections, risk identification, and administrative enforcement by supervisory authorities.

Overall, the new Measures elevate information disclosure from a mere compliance obligation to an indicator of governance capacity. Charitable organizations are expected to systematically review the consistency among their financial management, program administration, and disclosure processes, rather than simply completing annual reporting formalities.

II. Guidelines on the Filing of Public Fundraising Plans by Charitable Organizations (Trial) (Issued November 2025)

On November 7, 2025, the Guidelines on the Filing of Public Fundraising Plans by Charitable Organizations (Trial) were issued. Within the existing framework of the Charity Law, the Guidelines further refine the operational aspects of the public fundraising filing system.

Compared with prior practice, the principal changes include:

First, the filing of fundraising plans has shifted from procedural submission to substantive review. Previously, filings were largely formal in nature, focusing on document submission. The new Guidelines emphasize the substantive structure of fundraising plans, including arrangements for the use of funds, risk control mechanisms, and information disclosure plans. Filing documents thus become a key basis for regulatory assessment. In practice, as the new rules have only recently taken effect, many charitable organizations engaged in public fundraising have reported increased difficulty in obtaining filing approval.

Second, clearer standards for cross-regional and collaborative fundraising. Previously, there was greater flexibility in joint fundraising and out-of-region fundraising activities. The new Guidelines provide clearer filing requirements for such circumstances, thereby reducing regulatory uncertainty.

Third, higher requirements for front-end risk control. Fundraising plans must now clearly reflect fund management arrangements and disclosure mechanisms. This means compliance design must be completed before the launch of fundraising activities, rather than supplemented afterward.

Fourth, enhanced traceability of fundraising activities. A clearer institutional linkage is established between filed materials and subsequent information disclosure, making the entire fundraising process more subject to review and verification.

Taken together, the Guidelines strengthen front-end compliance design for fundraising activities, transforming public fundraising from an event-based operational activity into a governance-based institutional process.

Overall Trends and Implications

This round of regulatory updates reflects three notable trends:

First, heightened transparency requirements, moving from “whether to disclose” to “how to disclose in detail.” Second, regulatory front-loading, shifting from post-event correction to pre-event compliance control. Third, strengthened accountability, with clearer governance responsibilities for boards of directors and management.

Malaysia Practitioner Perspective: Upholding the Federal Constitution by Abhilaash Subramanian, Head of ESG Committee at Malaysian Bar and elected Council Member, Malaysian Bar 

Matthew Kasdin, GAIL APAC Board Member; General Counsel, Impact Investment Exchange (IIX)

I represented the Malaysian Bar as amicus curiae in relation to criminal proceedings brought against a protestor for failing to give notice to the police of the intended protest. The protest in question related to potential corruption within the government, particularly in regard to national defence procurement.  The Malaysian Federal Court declared unconstitutional the offence of not giving notice of a protest and struck down the provision citing that the purpose of notification provisions is to facilitate the right to protest and not curtail the same. The court ruled it was an unconstitutional infringement on the right to freedom of speech, assembly and association.