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Thailand vs Malaysia vs Singapore vs Indonesia: Which ASEAN Market Lands a Chinese EV Cheapest? - China EV Mart

Thailand lands a Chinese EV cheapest on customs — 0% ACFTA duty and 7% VAT put a BYD Seal at $31,068 (+25.8%). Malaysia follows at $33,167 (5% duty + 10% SST), Singapore at $37,155 (20% excise + 9% GST) before its COE gate, and Indonesia is hardest at $45,809 (50% duty after the CBU exemption expired). Four markets, four different gates — the full matrix, model by model.

Wei Wang September 20, 2026 20 min read
thailand malaysia singapore indonesia asean southeast-asia landed-cost market-comparison ev-import

TL;DR

On the border, Thailand is the cheapest ASEAN market for a Chinese EV: 0% import duty under ACFTA plus 7% VAT land a BYD Seal at $31,068 (+25.8%). Malaysia follows at $33,167 (5% duty plus 10% SST), Singapore at $37,155 (20% excise duty plus 9% GST), and Indonesia is hardest at $45,809 (+85.5%, after its CBU exemption expired into a 50% duty). But the border number is only half the story in every one of these markets: Thailand’s real constraint is the incoming three-tier excise, Malaysia’s is the CBU minimum CIF and power gate, Singapore’s is the COE auction — where September 2026 certificates closed at S$133,009 and up — and Indonesia’s is the localisation programme. The tariff headline is the least decisive number in all four.

Key statistics

  • Thailand: 0% duty (ACFTA entitlement, not a subsidy) + 7% VAT; the 10% excise on imported EVs sits outside our model, and the EV Board agreed a three-tier structure on 10 September 2026 with the top tier for fully built-up imports signalled above 10%
  • Malaysia: 5% duty + 10% sales tax in our model; the full statutory stack for China-origin CBU cars is 5% + 10% excise + 10% sales tax since 1 January 2026, and since 1 July 2026 CBU imports need a RM200,000 minimum CIF value and 180 kW minimum power; CKD EVs keep exemptions until 31 December 2027
  • Singapore: 20% excise duty + 9% GST; the model excludes the COE (September 2026 first exercise: A S$133,009 · B S$135,001 · E S$137,890) and the ARF (100% to 320% of OMV)
  • Indonesia: 50% duty + 11% VAT after the CBU exemption expired on 31 December 2025; the way around it is the 2026–2027 localisation programme (1:1 production commitment, bank guarantee)
  • Worked example: BYD Seal $24,690 → $31,068 Thailand · $33,167 Malaysia · $37,155 Singapore · $45,809 Indonesia
  • The gaps are exact: Malaysia−Thailand = +8.5% of the China base; Singapore−Malaysia = +15.3% + $210; Indonesia−Singapore = +35.7% − $160 — customs formulas, not estimates
  • Direction of travel: every one of the four is repricing imports — excise reform (TH), CBU gates and a CKD clock (MY), rebate expiry (SG), localisation deadlines (ID)

The terms that decide these four markets

  • Landed cost — the buyer-side cost to bring a China-market car into a market, customs-paid and registered: base price → duty → consumption taxes → VAT/GST → freight → clearance → certification → registration → inland. The full formula is in our landed-cost methodology.
  • ACFTA — the ASEAN–China Free Trade Area. It is why Chinese EVs enter Thailand at 0% and Malaysia at 5%, while Korean- or Japanese-origin cars face their own schedules. The rate needs origin paperwork (Form E), not just a Chinese badge.
  • CBU vs CKD — completely built-up (a finished import) versus completely knocked-down (kits for local assembly). Thailand and Malaysia are both rewriting their tax codes around this split; it now decides more than the duty line does.
  • Excise duty — a domestic consumption tax, separate from import duty. Thailand charges 10% on imported EVs (2% for BOI-promoted local production); Malaysia reinstated a 10% excise on CBU EVs in January 2026.
  • SST — Malaysia’s Sales and Service Tax; the sales-tax component on cars is 10%, charged on the duty-paid value.
  • OMV, COE, ARF — Singapore’s three registration concepts: Open Market Value (the Customs-assessed value everything keys off), the Certificate of Entitlement (a ten-year right to own a car, auctioned twice a month), and the Additional Registration Fee (a tiered 100–320% tax on OMV).
  • PPN — Indonesia’s value-added tax, 11% on the duty-paid value.
  • TKDN — Indonesia’s domestic-content requirement; hitting it is the price of staying inside the localisation window.
  • Compounding, not adding — every stack here multiplies in sequence, so effective loads differ from the sum of the headline rates.

Four markets, four different gates

The single most useful thing to understand about ASEAN is that no two of these markets gate the same way — and three of the four gates sit outside the customs formula:

MarketThe gate that actually decidesWhere it sits
ThailandThree-tier excise, agreed 10 Sep 2026; Tier 3 (fully built-up imports) signalled above 10%Domestic tax, outside our model
MalaysiaCBU entry test: ≥ RM200,000 CIF value and ≥ 180 kW power, since 1 July 2026Import licensing, outside our model
SingaporeCOE auction: S$133,009–137,890 in September 2026, plus ARF up to 320% of OMVRegistration, outside our model
IndonesiaLocalisation: 1:1 production commitment inside the 2026–2027 windowIndustrial policy, outside our model

That table is the honest map of the region. A tariff is a cost you can pay and pass on; a gate is a condition you either satisfy or don’t. In three of these four markets, the bigger number is the gate.

The rate stacks, side by side

LayerThailandMalaysiaSingaporeIndonesia
Import duty0% (ACFTA)5% (ACFTA; 30% for non-FTA origins)20% excise on OMV50%
Countervailing dutyNoneNoneNoneNone
Sales / luxury tax10% excise on imports — excluded from model10% excise reinstated Jan 2026 — excluded from modelARF 100–320% of OMV — excludedPPnBM (band unverified — UNKNOWN)
VAT / GST7%10% SST9% GST11% PPN
Registration & plates (our model)~$50~$50$260~$100

None of these four markets applies an EU-style countervailing duty on Chinese EVs — that is an EU measure, not a regional one. The stacks differ entirely in their own design choices.

Same car, four markets

Seven models spanning the catalog, landed through all four markets on our model. Base price is ex-factory China; totals include duty, consumption tax where the model counts it, VAT/GST and the fixed import block.

ModelBase (China)ThailandMalaysiaSingaporeIndonesia
Wuling Hongguang MINI EV$5,000$10,000$10,425$11,400$13,025
Neta V$8,320$13,552$14,260$15,743$18,553
MG 4$9,690$15,018$15,842$17,535$20,834
Ora Good Cat$11,800$17,276$18,279$20,294$24,347
BYD Atto 3$16,260$22,048$23,430$26,128$31,773
BYD Seal$24,690$31,068$33,167$37,155$45,809
Zeekr 001$38,000$45,310$48,540$54,564$67,970

The ranking never moves — Thailand, Malaysia, Singapore, Indonesia, on every row — but the percentages flip as prices fall. Thailand runs from +100.0% on the $5,000 Wuling down to +19.2% on the Zeekr 001; Indonesia runs from +160.5% to +78.9%. Cheap cars wear the fixed import block ($4,650–$4,860 across these four markets) proportionally harder, exactly as in every market we track. Absolute dollars are the comparison that survives.

Note what the table does not include: Singapore’s COE and ARF, Thailand’s and Malaysia’s excise layers, and Indonesia’s PPnBM. Each is quantified in the sections below — and each is large enough to change what the ranking means in practice.

What the gaps contain

Run the formulas and each step between markets comes out as an exact coefficient on the China base — useful for pricing any model, not just the seven above:

StepGap formulaOn the BYD Seal
Thailand → Malaysia+8.5% of base (5% duty, then 10% SST vs 0% then 7% VAT)+$2,099
Malaysia → Singapore+15.3% of base, +$210 (20% excise and 9% GST compound harder; fixed block rises $210)+$3,988
Singapore → Indonesia+35.7% of base, −$160 (the 50% duty and 11% PPN against 20% + 9%; fixed block falls $160)+$8,654
Thailand → Indonesia+59.5% of base, +$50 (the full spread across the region)+$14,741

Applied per model, the same coefficients reproduce every figure in the matrix:

ModelMalaysia − ThailandSingapore − MalaysiaIndonesia − Singapore
Wuling Hongguang MINI EV$425$975$1,625
Neta V$707$1,483$2,810
MG 4$824$1,693$3,299
Ora Good Cat$1,003$2,015$4,053
BYD Atto 3$1,382$2,698$5,645
BYD Seal$2,099$3,988$8,654
Zeekr 001$3,230$6,024$13,406

The takeaway is arithmetic, not opinion: the customs spread between Thailand and Malaysia is small and predictable (8.5 points of base), while the steps beyond it get steep fast — and none of them accounts for the gate layers, which is where the real separations live.

Worked example: a BYD Seal in all four markets

LineThailandMalaysiaSingaporeIndonesia
Base price (ex-factory China)$24,690$24,690$24,690$24,690
Import duty (0% / 5% / 20% / 50%)$0$1,234.50$4,938$12,345
Sales tax / GST / PPN$1,728.30 (7% VAT)$2,592.45 (10% SST)$2,666.52 (9% GST)$4,073.85 (11% PPN)
Freight, clearance, certification, registration, inland$4,650$4,650$4,860$4,700
Total landed (model)$31,068.30$33,166.95$37,154.52$45,808.85
Excluded layer10% import excise → ~$33,700 practical10% reinstated excise → ~$36,019COE + ARF (six figures, S$)PPnBM (band UNKNOWN)

Formula: base × (1 + duty) × (1 + consumption tax) × (1 + VAT/GST) + fixed costs, applied with each market’s own stack. Inputs from China EV Mart’s tariff and vehicle records dated 15 September 2026.

Where each market’s number stops

Thailand — the excise layer. Imported EVs carry a 10% excise that our uniform model excludes; compounded conventionally it adds roughly $2,640 to the Seal, moving the practical floor to about $33,700. The three-tier reform agreed on 10 September 2026 will tax fully built-up imports hardest, with the Excise Department saying it will set the Tier 3 rate first and give importers a grace period. The final rates still need cabinet approval — the specific mechanic, and the statutory base for imported-car excise, remain UNKNOWN and should be confirmed with a Thai broker.

Malaysia — the excise plus the gate. The catalog model applies 5% duty and 10% sales tax; the statutory stack for China-origin CBU cars since January 2026 is 5% + 10% excise + 10% sales tax. Compounded in the same convention, the Seal’s all-in tax-plus-base figure reaches roughly $36,019 (+45.9%), about $2,850 above the modelled number. Separately, from 1 July 2026 a CBU import must carry at least RM200,000 of CIF value and 180 kW — a filter that most mid-range models cannot clear as finished cars at all. MITI’s own worked example: a car at the RM200,000 CIF floor carries about RM250,000 in cost after the 5/10/10 stack, and arrives at an RRP north of RM300,000 with margins.

Singapore — the ownership gate. The border figure excludes the two items that decide Singapore: the COE and the ARF. In the September 2026 first exercise, Category A closed at a record S$133,009 and Category B at S$135,001 — roughly US$105,000 for the mainstream certificate, more than six times the entire border cost of a BYD Seagull and nearly three times the Seal’s. Power output decides your auction (110 kW or below is Category A; the Seal’s 170 kW is Category B). On top, the ARF runs 100% to 320% of OMV, offset for now by VES Band A (up to S$22,500) and EEAI (45% of ARF, capped at S$7,500, expiring 31 December 2026). Budget the certificate before you budget the car.

Indonesia — the localisation gate. The 50% duty is the outside-the-programme cost. Inside the 2026–2027 window, producers must manufacture in volumes equivalent to their CBU imports (a 1:1 ratio) against TKDN content requirements, backed by a bank guarantee that is forfeit if they miss. Six automakers enrolled, pledging about 15.5 trillion rupiah (roughly USD 950 million) and capacity of up to 305,000 units a year. Also excluded from our model: PPnBM, the luxury-goods tax, whose current BEV band we could not verify — treat it as UNKNOWN and check any quotation for it separately.

Why every brand is building instead of shipping

The gates explain the factory map, and the factory map explains the medium term. Thailand has built out a full Chinese EV production belt across 2023–2025 — BYD’s Rayong plant (150,000 units a year, opened July 2024, with 130,000 Thai deliveries by its second anniversary and exports to the UK, Germany and Belgium), GWM’s ex-GM Rayong facility with a Svolt battery line, Neta’s Bangkok assembly, Changan’s Rayong plant (100,000 a year, planned to reach 200,000), and GAC Aion’s Rayong line (50,000, expandable to 100,000). Malaysia’s version runs through Geely’s 49.9% stake in Proton: the eMAS 7 — a Geely Galaxy E5 by another name — moved from CBU import at RM110,000 to CKD assembly at Tanjong Malim from RM103,800, and Proton took 45.6% of Malaysia’s EV market in the first five months of 2026. Indonesia converted its incentive into exactly this kind of commitment, and is collecting on it through 2027. Singapore is the exception that proves the rule: with no local industry to protect and an auction on ownership, its lever has never been the tariff.

For importers the strategic reading is blunt: in three of these four markets, the tax code now pays you to stop being an importer.

What buyers should ask before committing

  1. “Which gate applies to my model, and can I pass it?” — Thai excise class, Malaysian CIF and power floors, Singapore COE strategy, Indonesian localisation plan. The tariff is the easy part.
  2. “Is my ACFTA origin file complete?” — the 0% Thai rate and the 5% Malaysian rate stand on Form E origin documentation. Models assembled outside China may not qualify; the rate is an origin benefit, not a model benefit.
  3. “Have I priced the excluded layer?” — add excise in Thailand and Malaysia, the COE and ARF in Singapore, PPnBM in Indonesia. Our border figures are floors by design.
  4. “Am I selling into demand that exists at the new price?” — Thailand crossed 20% NEV penetration before the excise reform; Chinese brands reached 8.9% of Malaysian registrations in the first five months of 2026; Indonesia’s is programme-shaped. The demand is real, but it is priced to the local rules.
  5. “What happens at the deadline?” — Malaysia’s CKD exemption ends 31 December 2027; Indonesia’s localisation window runs through 2027; Thailand’s Tier 3 rate comes with a grace period; Singapore’s EEAI rebate dies on 31 December 2026. In this region, timing is a cost line.

Frequently asked questions

Is Thailand really the cheapest ASEAN market for a Chinese EV? On customs, yes — 0% ACFTA duty and 7% VAT give it the lowest border cost of the four, at +25.8% on a BYD Seal. The caveat is the excise layer: with the current 10% import excise included, the practical floor is nearer $33,700, and the announced three-tier reform is designed to lift it further.

Does any ASEAN market charge an EU-style countervailing duty on Chinese EVs? No. The CVD regime we track is an EU measure under Regulation 2024/2754. Thailand, Malaysia, Singapore and Indonesia apply no anti-subsidy tariff on China-origin EVs — their trade defences run through domestic taxes and licensing instead.

Why doesn’t Singapore top the table if it’s the most expensive market? Because the table is a border estimate. Singapore’s border stack is mid-pack; its ownership system is the world’s most expensive. The COE alone — S$133,009 to S$137,890 in the September 2026 first exercise — exceeds the entire border cost of every model we track, and the ARF adds up to 320% of OMV on top.

Can importers still get Indonesia’s old duty-free treatment? Only inside the localisation programme: a 1:1 production commitment backed by a bank guarantee, inside the 2026–2027 window, with TKDN content requirements. Outside it, the 50% duty applies — a roughly $13,700 swing on a mid-size sedan versus the expired regime.

The Author’s Take

Position. In my view the ASEAN import story has moved off the border entirely, and the four markets now sort by which gate they charge — excise in Thailand, CIF and power floors in Malaysia, the COE auction in Singapore, localisation in Indonesia. If I had to place a bet for each: Thailand for pure customs cost while the excise window is still open, Malaysia only behind a CKD plan or with a compliant premium model, Singapore only with a certificate strategy funded, Indonesia only inside the programme. Shipping finished cars and hoping is the strategy every one of these governments is actively written against.

Reasoning. First, the border math is now too small to be decisive: the whole Thailand-versus-Malaysia spread is 8.5 points of base — real, but dwarfed by layers the model excludes, like a six-figure COE or a 10% excise redesign. Second, the direction of travel is uniform: Thailand’s Tier 3 rate is signalled above 10%, Malaysia’s July 2026 rules superseded a January 2026 regime within six months, Singapore’s EEAI rebate expires at the end of this year, and Indonesia’s window closes at the end of 2027. Third, the industry has already voted — Thailand’s factory belt, Geely’s Proton pipeline and Indonesia’s pledged capacity show where brands think the taxes will be. Fourth, the demand side supports the pivot: Chinese brands approaching a 9% share in Malaysia, more than 20% NEV penetration in Thailand, programme-driven volumes in Indonesia. The buyer-side conclusion is conditional, not uniform: pay a tariff where you can (Thailand today), pass a content test where you must (Indonesia, Malaysia), and treat Singapore as a certificate business rather than an import business.

Disclosure. This is my analysis of published rules, press reporting and China EV Mart’s landed-cost records — opinion, not legal, tax or customs advice, and not a quotation. Landed-cost figures are model estimates with dated inputs; the excise base in Thailand, excise carve-outs in Malaysia, the PPnBM band in Indonesia and GST recovery in Singapore are flagged UNKNOWN or unverified where noted. Confirm current rates, gates and deadlines with local authorities or a licensed broker before committing capital.

Sources

  1. Bangkok Post — “EV Board introduces 3-tier tax structure” (Tier 1 lowest for local-content/local production; Tier 3 highest for CBU imports; importers to get a grace period; current rates 2% / 8% / 10%) — https://www.bangkokpost.com/business/general/3317548/ev-board-introduces-3tier-tax-structure — September 2026; accessed 20 September 2026
  2. Bloomberg via CNBC-TV18 — “Thailand moves to impose tax on imported EVs more than local models” — https://www.cnbctv18.com/auto/thailand-moves-to-impose-tax-on-imported-evs-more-than-local-models-19988990.htm — 11 September 2026
  3. Fulcrum (ISEAS–Yusof Ishak Institute) — “Thailand’s Trade Imbalance and Stunted Industrialisation: Will the Upgraded ASEAN–China Trade Agreement Help?” (unequal treatment debate on zero tariffs for Chinese EVs) — https://fulcrum.sg/article/commentaries/thailands-trade-imbalance-and-stunted-industrialisation-will-the-upgraded-asean-china-trade-agreement-help/ — 9 February 2026
  4. EY Global Tax News — “Thailand | Subsidies, duties, excise-tax incentives to encourage development and use of battery electric vehicles” (BEV 3.5 rules, including import-duty cuts and excise rates) — https://www.ey.com/en_gl/technical/tax-alerts/thailand---subsidies—duties—excise-tax-incentives-to-encourage — January 2024; accessed 16 September 2026
  5. Paul Tan’s Automotive News, citing the Malaysian Automotive Association — “Tax and duties for CBU EVs set at 30%+10%+10% or 5%+10%+10% depending on country of origin” — https://paultan.org/2026/01/20/tax-and-duties-for-cbu-evs-set-at-301010-or-51010-depending-on-country-of-origin-fta/ — 20 January 2026
  6. Paul Tan’s Automotive News, citing MITI — “MITI issues new rules for CBU EVs, effective min price RM300k, 245 PS from July” (RM200,000 minimum CIF value; 180 kW minimum power) — https://paultan.org/2026/05/06/miti-issues-new-rules-for-cbu-evs-effective-min-price-rm300k-245-ps-fr-july-promote-ckd-protect-proton/ — 6 May 2026
  7. Paul Tan’s Automotive News — “MITI says government has no plans to reverse new CBU EV policy” — https://paultan.org/2026/07/15/miti-says-government-has-no-plans-to-reverse-new-cbu-ev-policy/ — 15 July 2026
  8. Paul Tan’s Automotive News — “Proton’s dedicated EV plant in Tg Malim launched — CKD eMas 7 kicks off production” (RM82 million facility; 20,000 units first phase, scalable to 45,000) — https://paultan.org/2025/09/04/protons-dedicated-ev-plant-in-tg-malim-launched-ckd-emas-7-kicks-off-production-emas-5-next-up/ — 4 September 2025
  9. Paul Tan’s Automotive News — “2026 Proton eMas 7 CKD — local assembly adds spec upgrades, price now under RM100k” (RM103,800 Prime / RM119,800 Premium vs RM110,000 CBU launch; rebate to RM99,800) — https://paultan.org/2026/01/20/2026-proton-emas-7-ckd-local-assembly-adds-spec-upgrades-price-now-under-rm100k-rm6k-cheaper/ — 20 January 2026
  10. Paul Tan’s Automotive News — “The eMas phenomenon: Proton is now Malaysia’s best-selling EV brand, with 46% of the market in 2026” — https://paultan.org/2026/06/14/the-e-mas-phenomenon-proton-is-now-malaysias-best-selling-ev-brand-with-46-of-the-market-in-2026/ — 14 June 2026
  11. Paul Tan’s Automotive News — “Malaysia missed out on RM3.3 billion during four years of tax-free CBU EV sales” — https://paultan.org/2026/08/03/malaysia-missed-out-on-rm3-3-billion-during-four-years-of-tax-free-cbu-ev-sales-public-chargers-still-lacking/ — 3 August 2026
  12. LTA (OneMotoring) — “Certificate of Entitlement (COE)” and “COE Open Bidding” (categories; ten-year validity; September 2026 first exercise results: A S$133,009 / B S$135,001 / E S$137,890) — https://onemotoring.lta.gov.sg/content/onemotoring/home/buying/coe-open-bidding.html — accessed 20 September 2026
  13. LTA (OneMotoring) — “Vehicle Tax Structure” and “Vehicle Import and Registration” (excise duty 20% of OMV; ARF tiers 100–320%; GST on import cost) — https://onemotoring.lta.gov.sg/content/onemotoring/home/buying/upfront-vehicle-costs/tax-structure.html — accessed 16 September 2026
  14. LTA (OneMotoring) — “Vehicle Emission Schemes” (VES Band A rebate up to S$22,500 for 2026; EEAI 45% of ARF capped at S$7,500, expiring 31 December 2026) — https://onemotoring.lta.gov.sg/content/onemotoring/home/buying/upfront-vehicle-costs/emissions-charges.html — accessed 16 September 2026
  15. IRAS — “Current GST rates” (GST at 9%) — https://www.iras.gov.sg/taxes/goods-services-tax-(gst)/basics-of-gst/current-gst-rates — accessed 16 September 2026
  16. The Business Times — “Longer bidding interval pushes up COE premiums; Cat A at all-time high” — https://www.businesstimes.com.sg/singapore/longer-bidding-interval-pushes-up-coe-premiums-cat-all-time-high — 9 September 2026
  17. Indonesia Business Post — “Indonesia to tighten fiscal policy on electric vehicles starting 2026” (no extension of CBU incentives beyond 2025; 2026–2027 localisation window) — https://indonesiabusinesspost.com/5843/markets-and-finance/indonesia-to-tighten-fiscal-policy-on-electric-vehicles-starting-2026 — 22 December 2025
  18. Kompas — “Indonesia to End EV Import Incentives, Eyes Billions in Tax Gains” (1:1 production commitment; bank guarantee; 15.5 trillion rupiah pledged) — https://go.kompas.com/read/2025/09/01/230700074/indonesia-to-end-ev-import-incentives-eyes-billions-in-tax-gains — 1 September 2025
  19. MUC Consulting — “Ministry of Finance Extends 0% Import Duty on Electric Vehicles Until 2025” (PMK No. 10 of 2024) — https://muc.co.id/en/article/ministry-of-finance-extends-0-import-duty-on-electric-vehicles-until-2025 — 22 February 2024
  20. CnEVPost — “BYD Thailand plant opens as its 8 millionth NEV rolls off line” (150,000 units a year; Rayong) — https://cnevpost.com/2024/07/04/byd-thailand-plant-opens-8-millionth-nev/ — 4 July 2024; and “BYD Thailand deliveries surpass 130,000 as local plant marks second anniversary” — https://cnevpost.com/2026/07/14/byd-thailand-deliveries-130000-local-plant-2nd-anniversary/ — 14 July 2026
  21. CnEVPost — “Changan Thailand plant goes into operation, its 1st overseas EV plant” (100,000 units a year, planned 200,000) — https://cnevpost.com/2025/05/19/changan-thailand-plant-goes-into-operation/ — 19 May 2025; and “GAC Aion opens its 1st overseas plant in Thailand” (50,000 units, expandable to 100,000) — https://cnevpost.com/2024/07/17/gac-aion-opens-thailand-plant/ — 17 July 2024
  22. China EV Mart — tariff, market and vehicle landed-cost records (src/data/tariffs.json, src/data/market-master.json, src/content/vehicles/*.md; Thailand duty 0% / VAT 7%; Malaysia 5% / 10%; Singapore 20% / 9%; Indonesia 50% / 11%) — internal dataset, last verified 15 September 2026