[Blog]Resuming Labor Migration from Bangladesh to Malaysia: Recruitment Costs and the Principle That Labor Is Not a Commodity

2026-11-02

■ Resumption of Labor Migration and Unresolved Recruitment Costs

On October 29, 2026, the Bangladeshi newspaper The Daily Star published an article titled "Malaysia-bound workers may leave from early Nov". The article reported that Bangladeshi workers could begin traveling to Malaysia in early November, while significant uncertainty remained over recruitment and migration costs. Concerns persisted that workers might ultimately bear substantial financial burdens.

Malaysia had suspended new recruitment from Bangladesh at the end of May 2024 amid concerns about excessive recruitment fees and irregularities in the recruitment system. The anticipated resumption represents an important opportunity for both Malaysia, which needs foreign workers, and Bangladesh, which seeks overseas employment opportunities for its citizens. However, reopening a migration corridor does not necessarily mean that fair labor mobility has been achieved.

■ The Gap Between Official Fees and Actual Payments

According to the article, preliminary recruitment costs were estimated at Tk 300,000–400,000 through private recruitment agencies and Tk 155,000–160,000 through the state-run Bangladesh Overseas Employment and Services Limited (BOESL). These figures had not yet been finalized as official rates. A recruitment agency representative suggested that securing job opportunities could involve payments of approximately RM 10,000, potentially pushing total costs above Tk 600,000 once airfare, medical examinations, and other expenses were included.

By comparison, the government-fixed recruitment fee during the previous recruitment period was Tk 78,990. Research by the nonprofit organization Verité found that workers who secured employment in Malaysia between 2022 and 2024 had paid an average of approximately Tk 544,000. This indicates a substantial gap between officially regulated fees and actual recruitment expenses.

The central question is not simply whether recruitment fees are expensive. It is who pays, for what purpose, to whom, and who ultimately benefits from those payments. These questions concern the fundamental allocation of costs and benefits within international labor migration systems.

■ Does Zero-Cost Recruitment Really Mean No Cost?

The Bangladeshi government has proposed a zero-cost recruitment initiative for 10,000 workers through BOESL. However, the responsible minister acknowledged that workers would still need to pay for airfare, medical examinations, and certain service charges. At the time of the original report, the final costs and selection procedures had not been fully clarified.

The existence of some unavoidable expenses does not automatically make a migration system unfair. The problem arises when the promise of free recruitment differs from actual financial obligations, leaving workers unable to make informed decisions before signing contracts or making payments.

Prospective migrant workers generally possess less information and weaker bargaining power than employers and recruitment intermediaries. Without transparent fee structures, they may face unexpected charges or exploitative arrangements that are difficult to challenge.

■ The Balanced Coexistence Model: Labor Is Not a Commodity

This issue directly relates to the fundamental principle of the Balanced Coexistence Model (BCM): labor is not a commodity.

International recruitment necessarily involves administrative procedures, documentation, visa processing, transportation, and other services. However, the existence of recruitment expenses must be distinguished from the idea that workers should purchase access to employment opportunities.

When employers require labor and derive economic benefits from recruitment, the allocation of recruitment costs should reflect those benefits. If workers ultimately pay substantial intermediary fees simply to secure employment, job opportunities risk becoming commodities traded through recruitment networks.

Such arrangements conflict with the BCM's understanding of workers as independent rights-bearing individuals rather than instruments of labor supply.

The BCM does not necessarily demand that every expense associated with international migration be eliminated. Instead, it emphasizes fair cost allocation based on the nature of each expense, the beneficiaries, financial capacity, and inequalities in bargaining power. Costs incurred primarily for the benefit of employers should not automatically be transferred to vulnerable workers.

■ How Recruitment Debt Creates Structural Dependency

When migrant workers borrow large sums to finance overseas employment, repayment obligations may continue long after they begin working. Even if actual working conditions differ from contractual promises, wages are withheld, or employers violate labor standards, workers may find it difficult to leave their jobs because returning home would leave them with substantial unpaid debts.

Recruitment costs can therefore undermine freedom of choice during employment. Financial obligations incurred before departure may create dependency after arrival.

In a related report, The Daily Star reported that migrant rights organizations had called for a legally binding bilateral labor agreement between Bangladesh and Malaysia. Previous recruitment arrangements had raised concerns about excessive fees, unpaid wages, passport confiscation, and inadequate responses to workplace injuries.

These problems demonstrate that recruitment practices cannot be separated from employment conditions and workers' rights after migration.

■ Transparency and Preventive Administrative Governance

Under the renewed recruitment framework, Malaysia reportedly approved 25 principal recruitment agencies, 312 associated agencies, and BOESL, bringing the total to 338 organizations. However, concerns remain that the relationship between principal and associated agencies could concentrate recruitment opportunities and generate additional intermediary costs.

From the BCM perspective, effective governance should not depend solely on punishing violations after exploitation occurs. Administrative systems should also be designed to identify and prevent risks before workers suffer harm.

Recruitment agency registration, itemized fees, employment contracts, payment records, and complaint procedures should be sufficiently transparent and verifiable. Digital information-sharing mechanisms could help authorities identify unexplained charges, inconsistencies, and irregular recruitment practices at an early stage.

On October 31, The Daily Star reported that medical examination fees for Malaysia-bound workers had been fixed at Tk 8,000. The government prohibited additional charges and sought to protect workers' ability to select authorized medical facilities and change recruitment agencies without unnecessary restrictions.

This represents a positive step toward transparency and freedom of choice. Nevertheless, regulating medical examination fees alone cannot resolve broader problems involving recruitment costs and intermediary payments.

■ Mutual Obligations of Sending and Receiving Countries

Fair international labor mobility cannot be achieved through the efforts of sending countries alone.

Sending countries are responsible for regulating recruitment intermediaries, preventing unauthorized charges, and providing accurate information to prospective workers. Receiving countries must also ensure appropriate employer responsibility for recruitment costs, compliance with employment contracts, and effective remedies for violations of workers' rights.

The BCM emphasizes mutual obligations. Workers are expected to comply with laws and fulfill their employment responsibilities, but employers and public authorities must also fulfill obligations corresponding to their respective roles and benefits.

International recruitment creates particular governance challenges because intermediaries may exploit regulatory gaps between sending and receiving countries. Stronger institutional connections are therefore needed to verify recruitment fees, exchange agency registration information, investigate violations, and provide accessible remedies.

Such cooperation should move beyond numerical recruitment targets toward shared accountability for the conditions under which labor migration takes place.

■ Implications for Japan's Foreign Worker Policies

The Bangladesh–Malaysia case also offers important lessons for Japan's Technical Intern Training Program, Specified Skilled Worker system, and forthcoming Employment for Skill Development system.

Japan has similarly faced concerns about recruitment fees, payments to overseas intermediaries, loans, and deposits imposed on prospective foreign workers. Even when regulations and approved recruitment procedures exist, discrepancies between documented expenses and actual payments may undermine their effectiveness.

What matters is not merely how many foreign workers are admitted or whether recruitment procedures formally comply with regulations. Policymakers must also examine the economic conditions under which individuals enter Japan and begin employment.

Administrative authorities should be able to compare declared recruitment expenses with actual payment records and assess whether excessive debt restricts workers' ability to change employers, exercise their rights, or return home.

Under the BCM, the effectiveness of foreign worker policies should be evaluated through transparency, fair cost allocation, institutional accountability, and the practical protection of workers' freedom of choice.

■ Conclusion: How Should the Success of Labor Migration Be Measured?

The resumption of labor migration from Bangladesh to Malaysia may expand employment opportunities and contribute to the economic interests of both countries. However, increasing the number of deployed workers cannot, by itself, establish that the system is successful.

If workers must incur substantial debts to obtain employment and subsequently become unable to escape unfavorable working conditions, the underlying recruitment structure remains problematic.

From the perspective of the Balanced Coexistence Model, the essential question is whether benefits and burdens, rights and responsibilities, are reasonably distributed among workers, employers, sending countries, and receiving countries.

A migration policy that expands labor mobility without clarifying who should bear recruitment costs risks reproducing structural inequalities.

The measure of success should therefore shift from "How many workers have been sent abroad?" to "Under what conditions have workers been given access to employment?"

The principle that labor is not a commodity is more than an abstract ethical statement. Its practical meaning becomes clear precisely when governments and employers determine who pays the costs of recruitment, who receives its benefits, and whose rights the system is designed to protect.

Kenji Nishiyama

Author: Kenji Nishiyama (Certified Administrative Procedures Legal Specialist(Gyoseishoshi), Registration No.20081126)

Kenji Nishiyama is an Immigration and Visa Specialist who has supported many foreign residents with visa applications in Japan. On his firm’s website, he publishes daily updates and practical insights on immigration and residency procedures. He is also well-versed in foreign employment matters and serves as an advisor to companies that employ non-Japanese workers.