Myanmar

Do not lease premises, transfer diagnostic technology, appoint a franchisee, send staff, sign a local revenue contract or release tooling. Authorise only screened legal, sanctions and market diligence. If all absolute gates later clear, return to the board for a capped 90-day one-bay partner pilot with an MMK8m operating envelope and MMK28m reversible-tooling cap. Current executable SOM is zero.

Registered electric cars rose from 6,191 at 27 December 2024 to 9,026 by August 2025, a 45.8% increase on the published category figures [rtad_dec_2024] [rtad_aug_2025]. Yet electric vehicles of every class represented only about 0.49% of the more than 5.5m-vehicle parc at December 2025 [national_parc_2025]. Growth is rapid from a small base and depends heavily on policy, imported vehicles, electricity reliability and political conditions.

The 27,000 December 2025 number covers all EV classes. The December 2024 register separated 6,191 four-wheel EVs from 10,861 two-wheelers and 548 three-wheelers [rtad_dec_2024]. EVS therefore uses 9,026 registered electric cars—including four buses—as the latest category-specific four-wheel baseline [rtad_aug_2025]. PHEV/EREV counts were not found and are excluded rather than inferred.

Import permits began in late 2022. RTAD recorded 5,816 electric cars in October 2024, 6,191 four-wheel EVs in December 2024 and 9,026 electric cars in August 2025 [rtad_dec_2024] [rtad_aug_2025]. These are registrations/stock observations, not annual sales. The national 27,000 all-class observation is retained as context only. No authoritative BEV-versus-PHEV history was located.

From the 9,026-car evidence base, EVS applies five annual planning steps: 15% cautious growth to 18,155 cars by 2030, 25% base growth to 27,545 and 35% high growth to 40,473. These are not government forecasts. They reflect a young market, policy support, fuel constraints and local assembly upside, offset by new taxes, grid unreliability, foreign-exchange pressure and conflict [fuel_rationing_2026] [deepal_2026] [evs_model].

The Ministry of Construction reported 19 established charging stations in January 2025: four in Nay Pyi Taw, five in Yangon, five in Mandalay and five on the Yangon–Mandalay Expressway [charging_2025]. A 31-location pilot plan comprised six in Nay Pyi Taw, eight each in Yangon and Mandalay and nine on the expressway, but the September 2024 opening was described as only the twentieth live station [charging_plan_2024]. Counts must not be added. Obtain a connector, uptime, ownership and grid audit; users report frequent power cuts [power_cuts_2025].

Myanmar had more than 5.5m vehicles at December 2025 [national_parc_2025]. No current authoritative car-parc age distribution was found. A May 2026 replacement programme explicitly targets vehicles more than 20 years old, unserviceable vehicles and voluntary scrappage, confirming an aged ICE-parc problem but not an aged EV fleet [old_vehicle_2026]. The EV cohort is young; near-term demand is diagnostics, tyres, suspension, air-conditioning, thermal management, 12V, charge ports, underbody/flood checks and battery evidence—not opened-pack refurbishment.

EVS applies 95% active survival to 9,026 registered electric cars, producing a rounded 8,575-vehicle planning pool. At 1.3 paid events and MMK180,000 average revenue, annual TAM is 11,148 jobs and MMK2.007bn. An assumed 60% Yangon concentration and 35% independent reach produce a 1,801-vehicle, 2,341-job, MMK421.376m SAM. Current executable SOM is zero. The post-gate one-bay SOM is 420 jobs and MMK75.6m [rtad_aug_2025] [evs_model].

If the market becomes executable, prioritise private Chinese-EV owners, parallel-import owners without dependable OEM support, electric taxi operators, corporate and development-agency fleets, hotels and urban logistics, insurers and lenders needing battery reports, importers with incomplete aftersales, and charging operators. Do not contract government, military-linked, sanctioned or beneficially opaque counterparties.

RTAD-linked reporting identifies BYD, MG, Leapmotor and Dongfeng as leading Chinese brands, while the December 2024 register also described Toyota, BYD and MG as popular among more than 50 brands imported by about 80 companies [rtad_aug_2025] [rtad_dec_2024]. MG markets MG4 Electric and ZS EV; Changan/Deepal is establishing local S07 output [mg_myanmar] [deepal_2026]. No model-share table is published. A 250-VIN evidence pack is mandatory before tooling or parts decisions.

MG operates official Yangon, Mandalay and Nay Pyi Taw channels with service hotlines [mg_myanmar]. Changan advertises 4S workshops and mobile service in Yangon and Mandalay [changan_myanmar]. Prime Automotive lists BYD and Wuling service centres in Yangon [prime_auto]. Independent 8M Auto Service advertises EV diagnostics, while PIT&GO has a wider conventional workshop network [independent_8m] [pitgo]. EVS would need insurer-grade multi-brand battery evidence and audit controls to differentiate.

Yangon is the only plausible first market because it concentrates importers, authorised service, corporate fleets and five of the 19 reported chargers. Mandalay is a future second hub but current UK travel advice covers the wider region with an all-but-essential warning; many states and regions carry an all-travel warning [charging_2025] [fcdo_2026]. Nay Pyi Taw is government-centric and unsuitable without enhanced sanctions screening. No regional EV-stock table is available; scores are EVS assumptions.

The 2026 Union Tax Law introduced a 5% special-goods tax on the landed value of imported BEVs from 1 April 2026 [union_tax_2026]. RTAD also ended free initial registration: CBU passenger EV fees now vary by battery capacity, including 20% for 31–60kWh vehicles and up to 40% for larger capacity bands, while qualifying commercial vehicles and larger buses pay 3% [registration_fees_2026]. Earlier zero customs duty applied through 31 March 2026 and must not be treated as current [customs_2025].

Myanmar Investment Law incentives can provide three-, five- or seven-year income-tax holidays by zone only for promoted investment sectors; SEZ regimes can provide five- or seven-year holidays [pwc_incentives]. A service centre must not assume eligibility. More importantly, sanctions, banking, beneficial-ownership, foreign-exchange and reputational gates override any tax benefit. Obtain DICA/MIC, tax, bank and sanctions opinions before any local commitment.

A future operator would require a registered entity, locally valid business and premises approvals, RTAD-aligned vehicle controls, fire/environment permissions, labour compliance and any township/industrial-zone licences. The Vehicle Safety and Motor Vehicle Management Law 2020 is the core vehicle framework [vehicle_law_2020]. No dedicated EV high-voltage technician licence was located. EVS must therefore impose competence tiers, lockout/tagout, live-dead-live testing, insulated tools, arc-rated PPE, rescue drills and a no-live/open-pack rule.

Notification 1/2025 raised the combined minimum daily wage to MMK7,800 for an eight-hour day from 1 October 2025 for employers with at least ten workers [minimum_wage_2025]. The Occupational Safety and Health Law was enacted on 15 March 2019 and requires workplace-level safety governance [osh_2019]. Local counsel must confirm implementing rules, employment contracts, social-security registration, foreign specialist permissions and emergency obligations before launch.

Notification 70/2024 specifically addresses waste batteries and other EV waste [battery_notification_2024]. Official guidance prioritises recycling and prohibits imports of waste batteries/EV components, while a May 2025 government meeting was still drafting a fuller battery-waste policy [ewaste_2024] [battery_policy_2025]. The Environmental Conservation Law/Rules regulate hazardous waste, effluent and environmental assessment [dica_environment]. EVS must not open packs; quarantine sealed units and transfer only to a verified authorised downstream party.

Post-gate scope: digital safety inspection, multi-brand scan/fault triage, battery state-of-health reporting, 12V systems, tyres, alignment, brakes, suspension, air-conditioning, cooling loops, charge-port and AC-charging diagnosis, flood/underbody inspection, pre-purchase reports, fleet maintenance and roadside isolation. Exclude opened-pack work, cells/modules, structural collision repair, public-charger construction and remote software modification until legal, OEM, insurer and battery gates clear.

Current model is remote market monitoring only. If all absolute gates clear, use one EVS-managed bay inside a screened licensed Yangon workshop, with local staff and remote technical QA; no foreign travelling staff initially. EVS controls pricing, customer data, VIN whitelist, battery reports and HSE audits. Do not franchise before verified relevant stock exceeds 20,000, two profitable quarters, audit scores exceed 90%, sanctions screening is continuous and lawful battery transfer is proven.

Current revenue, EBITDA and SOM are zero because entry gates fail. If the board later reopens the market, the 90-day base case is 105 orders at MMK180,000, 52% gross margin and MMK8m operating cost: MMK18.9m revenue and MMK1.828m EBITDA, with 86-order break-even. Annualised post-gate base economics are 420 orders, MMK75.6m revenue, MMK7.312m EBITDA and 3.83-year simple payback on MMK28m reversible tooling. The cautious case loses MMK13.62m [evs_model].

Principal risks are civil conflict and staff safety; sanctioned or military-linked counterparties; banking/FX failure; opaque beneficial ownership; abrupt tax/import changes; power cuts; parallel-import software/parts fragmentation; weak provincial coverage; battery downstream uncertainty; flood/fire exposure; and currency distortion. Mitigation is chiefly deferral. Any future pilot requires independent ownership screening, transaction-bank pre-clearance, insurer acceptance, a Yangon-only security plan, reversible tools, sealed-pack scope and weekly stop/go authority.

Days 1–30 — remote only: appoint independent sanctions/security/tax counsel; screen five partners and beneficial owners; confirm bankability; obtain register and charger extracts.

Sanctions, beneficial ownership, transaction banking, insurance, staff security and battery transfer are absolute gates with no correction period. Workshop legality, fire commissioning, grid resilience and diagnostic access are also mandatory. Commercial gates require 105 paid-equivalent orders in validated demand, two private-fleet anchors and tool payback no worse than four years. Permanent entry requires at least 20,000 verified relevant four-wheel EVs and two profitable quarters.

Research prioritised RTAD-linked official reporting, Myanmar ministries and legal portals, ILO, DICA, official tax notices, international sanctions authorities and observable OEM/service networks, accessed 10 August 2026. Four-wheel registrations are separated from all-class EVs. The active rate, regional concentration, independent reach, service incidence, pricing, forecasts and economics are EVS assumptions. MMK values are nominal; no official/parallel FX conversion is embedded.

Obtain a current active register by BEV/PHEV/EREV, class, model, province and owner type; audit charger connectors/uplift; collect 250 VINs; verify counterparties and ultimate beneficial owners against all applicable lists; secure bank and insurer pre-clearance; price three workshops; validate OEM warranty and data access; confirm taxes and permits; and identify an authorised battery handler. Until all evidence is written and current, the no-go remains.

Every material source records publisher, displayed publication/update date where available, access date, definition and caveat. State-controlled reporting is used for RTAD and policy facts but triangulated and labelled. Undated live pages use null rather than invented dates. EVS assumptions resolve to the internal model URI and calculation register.