Mongolia

Authorise a capped MNT6.5m operating-validation budget and MNT30m reversible tooling envelope for an existing licensed Ulaanbaatar workshop. Release neither a dedicated lease nor franchise rights until the pilot reaches 60 paid orders, validates cold-weather diagnostic coverage, secures lawful battery custody and demonstrates a four-year-or-better payback from signed local costs.

Imports increased from 214 in 2022 to 419 in 2023 and 504 in 2024, then fell to 336 in 2025; 88 more arrived through 12 April 2026 [customs_release]. The 2025 decline was 33.3%, signalling volatility in a thin market rather than fleet contraction. Ulaanbaatar remains the only defensible launch geography: 632 of 709 registered EVs were in the capital in Q1 2023, or 89.1% [registration_2023].

The customs release uses 'electric vehicles' but does not publish a BEV/PHEV split. Registration reports likewise use an electric category. EVS therefore labels the denominator a reported-electric import floor, does not add Mongolia's large hybrid parc, and does not claim an audited active BEV stock. PHEV and EREV vehicles are a commercial adjacency only after VIN-level verification.

Registered EVs rose from 709 in Q1 2023 to 1,061 by December 2023 [registration_2023] [montsame_charging]. These are stock snapshots; the customs series is annual flow and must not be added to them. EVS uses the longer customs flow series because it is current and consistent, while noting that pre-2022 vehicles and attrition are not captured.

Starting from a 1,405 active planning pool, EVS projects 2,596 active vehicles by 2030 with flat annual additions, 3,164 with 15% annual addition growth and 3,914 with 30% growth. These cases deliberately sit far below public programme aspirations of 30,000–50,000 EV demand by 2030 because realised imports have not yet supported those targets [montsame_charging] [green_programme] [evs_model].

A cabinet-linked January 2024 report counted 70 chargers and said at least 1,000 would be needed for a 30,000-EV fleet [montsame_charging]. In May 2026, the programme proposed 80 Ulaanbaatar and 30 regional locations during 2026 and about 500 stations in two years; 95% of owners were still said to charge at home [green_programme]. Charger.mn shows 20+ stations on its own OCPP/QPay network, not the national total [charger_network]. No audited 2026 national connector and uptime census was found.

Of 804,656 vehicles inspected in Ulaanbaatar in 2024, 80% were over ten years old, 44% were hybrids and 0.2% electric [parc_age]. The EV cohort is younger, but Mongolia's cold winters, dust, rough roads and home-charging dependence increase demand for 12V batteries, tyres, suspension, thermal management, charge-port faults, underbody inspection and battery-health evidence. From June 2025, new UB plates require vehicles within ten years and pre-export inspection, which should gradually improve incoming quality [plate_rules].

The sourced floor is 1,561 reported electric-vehicle imports since 2022. EVS assumes 90% active, yielding 1,405 vehicles. At 1.2 paid events and MNT225,000 average revenue, national TAM is 1,686 jobs and MNT379.35m. Applying the sourced 89% capital concentration and a 45% independent-reach assumption gives a 563-vehicle, 675-job, MNT151.96m Ulaanbaatar SAM. Base pilot SOM is 240 jobs and MNT54.0m annual revenue [registration_2023] [customs_release] [evs_model].

Prioritise corporate and mining-company urban fleets; taxi and ride-hail operators; private owners of Chinese EVs; importers without deep aftersales; used-EV buyers needing battery-health reports; insurers and finance companies; charger operators; and government or development-project fleets. Retail walk-in demand alone is insufficient for the pilot.

China supplied 76.3% of the 2022–April 2026 import cohort, Japan 10.2% and the United States 5.1% [customs_release]. Public dealer evidence confirms BYD Han EV and Tang EV, plus IM Motors, Naxeon and mixed EV/hybrid offerings from Sequoia/NEV [msm_automotive] [emc_dealer] [nev_platform]. No official model-level registration ranking was located; tooling coverage must be validated from 150 anonymised VINs before any 'multi-brand' claim.

MSM expanded BYD retail presence in March 2026 and has an established automotive operation [byd_showroom] [msm_automotive]. NEV/Sequoia claims 300+ delivered EV/hybrid vehicles and parts support [nev_platform]. EMC markets IM Motors, Li Auto and Naxeon [emc_dealer]. General independents such as PPM have parts and diagnostics history but no publicly evidenced multi-brand high-voltage capability [independent_ppm]. EVS must compete on auditable diagnostics, cold-weather battery evidence and fleet uptime rather than price-only mechanical work.

Launch only in Ulaanbaatar, preferably Khan-Uul/Bayanzurkh industrial-access corridors near importers, fleet depots and chargers. Darkhan and Erdenet are referral spokes; Zamiin-Uud is a future corridor opportunity tied to Chinese imports and proposed green-station infrastructure. Region scores are EVS assumptions because no current province-level EV stock table was found.

Government Resolution 317 was reported to add electric and gas vehicles to customs/VAT exemption lists, and low-emission vehicles were reported exempt from the air-pollution fee [registration_2023]. The Customs Administration publishes an EV excise schedule of MNT375,000 for vehicles aged 0–3 years, MNT800,000 at 4–6, MNT1.675m at 7–9 and MNT5m at ten-plus years [customs_excise]. Because the exemption source is older and the current consolidated tariff was not located, obtain a binding customs classification before quoting landed-cost savings.

A foreign-invested company with 25%+ foreign ownership requires at least USD100,000 capital per foreign investor; incorporation normally takes about one month and requires subsequent tax and social-insurance registration [invest_mongolia]. Standard VAT is 10%, with mandatory registration once twelve-month sales reach MNT50m [pwc_tax]. Land-use and tax-stabilisation incentives may be available, but EVS should prefer a local managed-partner contract during validation rather than trigger avoidable foreign-capital overhead.

The transport licensing portal moved applications to the unified License.mn system from 1 April 2026 [transport_licensing]. EVS must obtain written confirmation on whether an existing workshop licence covers high-voltage diagnostics, mobile assistance and charger work. Grid-connected chargers also sit under energy and licensing laws listed by the Energy Regulatory Commission [energy_legal]. Incorporation is not permission to operate.

The minimum wage is MNT792,000 per month from 1 April 2025 [minimum_wage]. Mongolia's ministry is running nationwide risk-assessment and health-screening activity, while OSH law reform remains in progress [osh_campaign] [osh_reform]. No national EV high-voltage technician licence was found. EVS should impose competence levels, lockout/tagout, live-dead-live verification, insulated tools, arc-rated PPE, two-person rescue rules, cold-soaked battery handling and zero live pack-opening at launch.

The Waste Law sets ventilation, time limits, recordkeeping, waybill and licensed-transfer duties for hazardous waste [waste_law]. A producer-responsibility order covers batteries and accumulators [battery_order], while ITU reports that Mongolia is still developing broader e-waste registration, fee and producer-responsibility regulation [ewaste_policy]. EVS should quarantine sealed packs, record serials and state of charge, prohibit module opening, and transfer only against a licensed handler's written acceptance.

Phase 1: digital safety inspection, battery state-of-health screening, scan and fault triage, 12V testing, charge-port and AC charging diagnosis, tyres, alignment, brakes, suspension, thermal loops, cabin heat, underbody inspection, pre-purchase reports, fleet maintenance, roadside isolation and charger inspection. Exclude cell repair, opened-pack work, accident structural repair and public DC charging until specialist partners and permits are proven.

Use one EVS-managed bay inside an established Ulaanbaatar workshop, a mobile inspection kit and central technical QA. Keep pricing, safety, scan coverage, battery reports and customer records under EVS control. Do not sell a franchise until the market exceeds 3,000 active serviceable vehicles, two consecutive profitable quarters are achieved, audit scores exceed 90% and a lawful battery-return chain operates.

The 90-day base case assumes 60 paid orders at MNT225,000, 52% gross margin and MNT6.5m operating cost, producing MNT13.5m revenue and MNT0.52m EBITDA. Break-even is 56 orders. At annual steady state, 240 orders produce MNT54m revenue, MNT8.08m EBITDA and a 3.71-year simple payback on MNT30m reversible tooling. The cautious case loses MNT8.28m annually, so permanent premises are not justified [evs_model].

Principal risks are tiny market size, import volatility, rounded stock data, PHEV/BEV ambiguity, OEM software lockout, Chinese-model proliferation, winter range and thermal failures, home-charging electrical safety, technician scarcity, battery-waste uncertainty, foreign-capital threshold and weak rural economics. Mitigate through a partner bay, VIN whitelist, fleet LOIs, reversible tools, fixed safety scope, written customs/licensing opinions and quarterly gate review.

Days 1–30: confirm licence and tax treatment; inspect three partner workshops; collect 150 VINs; sign two fleet LOIs; contract towing and hazardous-waste transfer; audit power and fire systems.

A workshop-licence, fire, insurer, battery-transfer or high-voltage failure is an absolute no-go. Demand and margin misses may receive one 30-day correction cycle. Permanent premises require a verified active pool above 3,000, contracted fleet volume and simple payback at or below four years.

Research prioritised Mongolian government, customs, regulator, UN and observed-market sources accessed 10 August 2026. Stock and flow are never added. The 1,561 customs cohort is a floor, not active registrations. Forecast, survival, service incidence, revenue, reach, city scores and economics are EVS assumptions. Currency is nominal MNT with no FX conversion. Every quantitative fact resolves to a source or calculation row.

Obtain the national vehicle-register extract by fuel, model, province and active status; separate BEV, PHEV and EREV VINs; audit charger connectors and uptime; collect insurer and lender acceptance of battery-health reports; confirm OEM warranty boundaries; price three workshops; verify customs/VAT/excise treatment; and obtain written workshop, fire, grid, labour and waste opinions. Until then the decision remains a partner-pilot conditional go, not a fixed-site approval.

Publication and access dates, definitions and material caveats are recorded below. EVS assumptions use the internal model URI and the calculation register.