Ukraine.

Do not approve a greenfield centre or passive franchise while martial law, active attacks and bindable war-risk cover remain unresolved [rada_martial][worldbank_rdna5]. Authorise only diligence and a 90-day, two-bay Lviv partner pilot after security, insurer, labour/fire/waste and HV gates are green. Ukraine nevertheless has a large service base: 182,005 electric-only vehicles were officially recorded in August 2025 and a secondary series reached 251,491 all-class EVs by April 2026 [hsc_stock][autogeek_apr].

Why preserve the option: the inferred passenger-service base is about 245,154, the used-import mix is dominant and Lviv has high stock and flow [unn_2025][oneup][komersant_q1]. Why no fixed capital: RDNA5 records severe energy/transport damage and martial law is current [worldbank_rdna5][rada_martial]. Portable tools, partner bays and automatic stop-work triggers are mandatory.

The hard primary anchor is 182,005 electric-only vehicles as of 15 August 2025 [hsc_stock]. A secondary register analysis reports 251,491 EVs at 1 April 2026 [autogeek_apr]. EVS applies the 97.4802% passenger share of 2025 additions to that all-class figure, producing a 245,154 passenger-service planning proxy. This is derived—not an official passenger-BEV stock.

Ukravtoprom-derived additions rose from 37,600 in 2023 to 51,700 in 2024 and a rounded 110,200 in 2025 [ukrnews_2024][unn_2025]. The 2025 components sum to 110,248, 48 above the rounded headline. H1 2026 fell to 15,221 after the VAT-exemption expiry and the 2025 pull-forward [open4_h1][tax_ev_vat]. No defensible PHEV-only stock/flow series was located.

HSC’s 182,005 figure is electric-only but all vehicle classes; its separate 121,392 “hybrids” includes non-plug-in vehicles, so it is excluded [hsc_stock]. Autogeek’s 251,491 is newer but secondary and does not fully document active/class filters [autogeek_apr]. The model does not blend PHEVs, registrations, sales and live stock.

EVS compounds the 245,154 passenger-service proxy for five years at 5%, 12% and 20%, producing 312,886, 432,045 and 610,022 in 2031. These are scenarios, not forecasts. The low case reflects VAT normalisation, war and H1 2026 contraction; every case must be rebased to official class/status data [open4_h1][evs_model].

A ministry-derived statement counted about 11,000 charging stations by end-2025, versus about 3,000 several years earlier, but did not define site/device/connector or operating status [min_charge]. Another ministry statement counted more than 470 stations along national highways as of July 2025 [interfax_highway]. These are contextual, not additive.

OKKO reports 100 ultra-fast chargers at 63 locations and more than USD6m invested, with an EBRD-backed expansion [okko_charge]. RDNA5 says damaged/destroyed energy assets rose about 21% from RDNA4 [worldbank_rdna5]. EVS therefore requires backup power, surge protection and no service-demand uplift from connector counts.

Cars transacted on Ukraine’s internal market averaged 16.1 years in August 2025; Kyiv was 11.2 and Lviv 14.7 [ida_age]. This is transaction-flow age—not live fleet or EV age. It supports chassis/brake/thermal inspection context, but it is not used to infer battery failures.

Used Tesla, Leaf, Niro and Kona imports dominate 2025 model counts [unn_2025]. Demand should concentrate on collision history, battery evidence, charging, thermal, electronics and aged chassis. EVS assumes 0.65 paid events and UAH18,000 spend annually; neither is sourced market data [evs_model].

TAM is UAH2.868bn: 245,154 passenger-service proxy × 0.65 events × UAH18,000. Applying 65% independent eligibility gives UAH1.864bn; 45% Lviv/west reach gives UAH838.978m SAM; 3% year-one share gives UAH25.169m SOM. Stock is derived and all conversion parameters are EVS assumptions [autogeek_apr][unn_2025][evs_model].

At 0.45–0.80 events and UAH12,000–UAH25,000 spend, TAM spans about UAH1.324bn–UAH4.903bn before stock uncertainty. The crucial variables are active passenger-BEV stock, territory/security availability, paid-event frequency, ARO and OEM/warranty exclusion.

Prioritise used-import buyers/dealers, out-of-warranty Tesla/Leaf owners, China-EV grey imports, fleets/delivery/rental and body-shop/insurer depower referrals. OEM-warranty work is referred unless lawful access and authorisation are proven.

2025 used-import leaders were Tesla Model Y (10,683), Model 3 (9,348), Nissan Leaf (7,559), Kia Niro (5,154) and Hyundai Kona (4,145) [unn_2025]. New leaders included Volkswagen ID.Unyx (3,162) and BYD Song Plus EV (2,948). Platform readiness should follow these cohorts, not global brand rankings.

Kyiv has Tesla specialists TrueTesla, TSK and NikolaCars; Lviv has Bosch Service 112; Dnipro has D-Volt [truetesla][tsk][nikola][bosch_lviv][dvolt]. Nissan retains an authorised network and a BYD official network is forming [nissan][byd_entry]. EVS must compete on evidence, multi-brand scope, fleet SLA and audited safety—not unsupported superiority.

Lviv is the pilot preference: 32,703 registered EVs on the 1UP dashboard and 667 Q1 2026 passenger additions, the highest cited regional flow [oneup][komersant_q1]. Kyiv city/oblast is larger at 35,642 plus 19,784 but higher fixed-capital exposure. Dnipro and Odesa remain later referral markets.

The temporary BEV VAT exemption ended on 1 January 2026 [tax_ev_vat]. HSC says the first-registration pension-fee exemption remains [hsc_pension]. No current nationwide purchase grant, import-duty or excise treatment was verified sufficiently to include in economics; obtain a vehicle-specific customs opinion.

UkraineInvest lists standard 18% corporate income tax and 20% VAT [ukraineinvest_tax][ukraineinvest_vat]. EBRD/EU programmes may offer eligible SME finance, grants or insurance support, but EVS includes no award [ebrd_sme][ebrd_insurance]. War-risk cover must be a written precondition, not an assumed incentive.

Register the operating structure and employee notifications through the applicable process; Diia combines relevant business services [diia_ep]. Before opening, secure a Ukraine legal memo on premises, labour protection, fire, shelter/curfew, tax, customer, data and repair scope. This report is commercial diligence, not Ukrainian legal advice.

State Labour guidance covers work in electrical installations up to/above 1,000V and permit-to-work; Resolution 1107 applies to specified high-risk work/equipment [dsp_electrical][dsp_permit]. Most EV traction systems are below 1,000V, so counsel must map rather than assume permit scope. Contract authorised battery transport/treatment and confirm storage/processing permit triggers [mepr_waste][rada_waste].

Launch inspections/SOH evidence, multi-brand diagnostics, charging/thermal faults, brakes, steering, suspension, tyres and fleet pickup. Use partners for lawful localisation. Defer pack opening until competence, insurer, fire, quarantine, waste, parts and paid-demand gates are green.

Use an EVS-controlled managed licence with two existing Lviv partner bays. EVS owns brand, SOP, platform whitelist, training, audit and stop-work rights; the Ukrainian operator owns premises, employment, permits, insurer/waste contracts and customers. No territory exclusivity or passive franchise during the pilot.

Base case: 450 orders × UAH18,000 = UAH8.10m revenue; 50% gross margin yields UAH4.05m gross profit and UAH0.15m EBITDA after UAH3.90m OPEX. Break-even is 434 orders. Cautious EBITDA is −UAH1.725m; high is UAH4.425m. Figures exclude VAT, tax, financing, FX and grants [evs_model].

War/security, insurance exclusions, power disruption and staff continuity dominate ordinary market risk [worldbank_rdna5][rada_martial]. Secondary stock, demand pull-forward, strong specialists, OEM access and battery/fire exposure follow. Controls are partner bays, written stop triggers/cover, official extract, anchors, platform whitelist and quarantine.

Days 0–30: counsel, security/insurance/fire/waste review, official stock extract, Lviv partner/competitor sprint and channel presales. Days 31–60: authorise team, portable tools, backup power, two paid anchors and drills. Days 61–90: two partner bays with weekly security, P&L, quality and access review.

No public HV work until security/continuity, war-risk insurance and labour/fire/waste/legal gates are green. Advance only with ≥450 paid orders, ≥50% gross margin, ≤2.5% comeback, two anchors, ≥80% platform coverage and zero uncontrolled HV events. Any red safety/security/insurance gate stops operations.

Primary sources were prioritised: HSC, State Tax Service, Verkhovna Rada, State Labour Service, environment ministry, NBU and the joint RDNA5. Ukravtoprom figures are cited through reputable media and labelled. Dates, vehicle classes, stock/flow and station definitions are reconciled rather than averaged.

No exact official active passenger-BEV or PHEV stock, EV age profile, authorised-service capacity, workshop throughput, insurer loss series, tariff survey or stable subnational security forecast was available. The 251,491 stock is secondary and the passenger factor is inferred. These gaps prohibit a fixed-site recommendation.

HSC reports electric-only register stock and a broader “hybrid” category [hsc_stock]. Ukravtoprom-derived sources report additions, not net stock [unn_2025][open4_h1]. Autogeek reports all-class registered EVs [autogeek_apr]. “Charging station” is source terminology and cannot be converted to connectors without metadata [min_charge].

All economics are nominal UAH and exclude VAT, corporate tax, financing, working capital and FX. NBU publishes the official accounting exchange rate; no EUR/USD conversion is embedded [nbu_fx]. Obtain fresh rent, wage, energy, parts, insurance and generator quotes before day 31.

The 2025 leaders are overwhelmingly imported used Teslas, Leaf, Niro and Kona, while new Volkswagen/BYD/Zeekr cohorts grew [unn_2025]. This supports salvage/collision history, SOH and software/access evidence. Intake must record origin, title, damage, warranty, firmware and battery condition.

Target delivery, ride-hail, rental, leasing, importer and body-shop/insurer channels with uptime SLAs. National fleet BEV stock was not sourced, so no fleet uplift is added to TAM. Two paid anchors of at least 50 addressable vehicles each are mandatory [evs_model].

Book by VIN/symptom and location-security window; disclose access limits; scan, isolate and photograph; issue evidence-backed estimate; obtain approval; record torque/software/battery state; test and deliver digital findings. High-risk batteries use separate towing and quarantine.

“Evidence before replacement”: multi-brand diagnosis, explainable battery-health reporting, collision/salvage transparency, lawful access and documented safety. Promise a clearer decision and accountable custody—not universal pack repair, OEM warranty equivalence or uninterrupted wartime operation.

Use fixed-fee inspections/diagnostics, menu pricing for chassis/thermal work and authorised estimates for HV jobs. Quote testing must separate VAT, warranty, parts, data, pickup and interruption risk. No comparable national competitor-price survey was available.

Lead with importers/dealers, fleets, leasing/rental, insurers/body shops, charging operators and owner communities. Use OKKO/ECOFACTOR only as potential channels [okko_charge][ecofactor]. Partners may not imply OEM authorisation or make unsupported battery claims.

Track named fleet/importer, vehicle count, model/warranty/damage mix, current provider, downtime, location/security limits, price and procurement date. Require paid contracts; letters of interest do not clear the demand gate.

Shortlist existing Lviv premises with segregable HV bay, external quarantine, shelter access, backup power, towing route, drainage/waste controls and fire/insurer acceptance. Weight security, operational flexibility and technical readiness above rent. No bespoke fit-out.

Use one diagnostic/mechanical bay and one controlled HV-capable bay, secure tool/parts store, clean electronics bench, isolated charging and monitored external quarantine. Mark exclusion/evacuation routes and shelter/alert procedure. Keep all assets removable.

Day-one kit covers CAT-rated testing, insulated tools/PPE/LOTO, multi-brand diagnostics, programming power, EV lifts, wheel/brake work, thermal inspection, surge protection and backup power. Pack-opening equipment is withheld until the battery gate.

Start with a Ukraine pilot manager, named HV technician, EV mechanical technician, service adviser/mobile coordinator and 0.5 remote technical support. Labour costs are EVS assumptions; obtain three local recruitment/payroll quotes and include absence, mobilisation and continuity scenarios.

Create a task/platform/voltage-state matrix and have Ukrainian counsel map electrical/high-risk rules [dsp_electrical][dsp_permit]. Require isolation, first aid/rescue, battery chemistry, fire, air-raid, power-loss and supervised sign-off before independent work.

Identify vehicle/battery/damage state, zone, shut down, isolate, prove absence of voltage, lock/tag, wait OEM interval, verify residual energy and control keys. Maintain rescue capability and independent re-energisation check. Security alerts trigger safe suspension, not rushed closure.

Use VIN-level pre/post scans, approvals, torque/parts/software evidence, custody log, road-test and 30-day outcome. Review every comeback, access failure and near miss weekly. Safety and evidence metrics outrank billable hours.

Maintain a lawful platform whitelist for read/write functions, subscriptions, gateways, programming support, battery parameters and offline operation. Encrypt credentials/backups and audit access. Reports separate measured values, interpretations and unavailable OEM data.

Stock brakes, chassis, thermal consumables and safety items; order modules/packs against confirmed jobs. Imported/salvage parts require provenance, compatibility, test evidence and consent. Track FX, lead time, warranty, firmware and return rights.

Approve suppliers, tow firms and waste partners by legal status, insurance, traceability, response and battery capability [mepr_waste][rada_waste]. Maintain damaged-battery custody. Confirm producer/importer obligations separately if EVS imports batteries, modules or vehicles.

Launch quietly with evidence-led inspections and fleet uptime; do not market pack opening until cleared. Publish method/limitations and sample reports, not war-resilience guarantees, unsupported certificates or superlatives. Use Ukrainian-first customer materials.

Use EVS black/charcoal, EVS Green #5BCC12, EVS Silver #A7B3BB, white/light grey and Inter. Display pricing logic, independent status, insurance/complaint route and safety limits. Do not use blue or mimic Tesla/BYD/OEM identity.

Ukraine is not ready for passive franchising. The first unit must be managed, removable and audited weekly. Consider a franchise only after 12 green weeks, stable local cover, repeatable training, tool/supplier redundancy and no unresolved security red line.

Board owns country-risk appetite; Ukraine lead owns security/compliance/demand; technical lead owns platform/SOP/authorisation; finance owns model/insurance; legal/brand owns contracts/claims. EVS retains immediate stop-work and brand-suspension rights.

Track orders, conversion, ARO, margin, utilisation, first-time-fix, comeback, cycle time, fleet mix, diagnostic coverage, unresolved faults, near misses, power/security interruptions and waste exceptions. No growth KPI overrides a red gate.

Monday: security, staffing, pipeline and capacity. Wednesday: technical cases, access, parts and waste. Friday: P&L, comeback, alerts, safety and gates. Archive day-30/60/90 packs and the assumptions then in force.

Stage 0 is two Lviv partner bays. Stage 1 adds western mobile/partner routes after 12 green weeks. Kyiv is partner/referral only until security and insurance gates support a satellite. Odesa/Dnipro follow only with local safe-logistics proof.

A security/insurance breach stops operations and evacuates portable assets. If retail misses but fleets convert, retain mobile/fleet service. If access is weak, focus on inspections/mechanical/thermal/depower. If safety/legal gates fail, stop HV work and refer.

Extend vehicle/battery life through diagnosis before replacement, safe lawful repair and authorised treatment. Track repaired/referred packs and waste mass without inventing carbon savings. Charging expansion and reconstruction are not EVS environmental credits.

Obtain workshop liability, professional indemnity, property/business interruption, cyber, customer-vehicle custody and explicit HV/battery/fire/war cover. EBRD-backed market capacity exists but is limited [ebrd_insurance]. Bindable written cover and accepted exclusions are preconditions.

The UAH3.9m base OPEX is an EVS envelope. Obtain three labour/payroll quotes, two partner-bay quotes, energy/backup and insurance quotes by day 31. Model 18% CIT and 20% VAT separately [ukraineinvest_tax][ukraineinvest_vat]. Recompute break-even if loaded OPEX or ARO moves >10%.

Mystery-shop TrueTesla, TSK, NikolaCars, Bosch Service 112, D-Volt, EV House and two authorised dealers for lead time, fee, platform, warranty, battery, software and logistics [truetesla][tsk][nikola][bosch_lviv][dvolt][evhouse][nissan]. Websites evidence offers—not competence or share.

Tier 1: Ukrainian authorities, official legislation, NBU and joint RDNA. Tier 2: Ukravtoprom-derived media, EBRD and operator primary claims. Tier 3: secondary registration, research and competitor pages. Definition/date control conflicts; unknowns become gates.

Approve only an UAH-capped diligence and 90-day Lviv partner pilot after all red preconditions are green. Do not approve a greenfield lease, passive franchise, territory exclusivity, battery-opening marketing or Kyiv/Dnipro/Odesa capex while the security/insurance case is unresolved.

The complete registry is embedded in sources with publisher, publication/access dates, links and use notes. Quantitative narrative claims carry source IDs. EVS assumptions/calculations are explicitly labelled and source-definition conflicts are recorded.