Country intelligence • Myanmar
Myanmar: market-entry intelligence
Three decisions an EU company faces with Myanmar. Myanmar is the template's highest-risk operating environment: a military coup (February 2021) triggered an ongoing civil war, EU trade preferences (GSP/EBA) were suspended in 2024, EU sanctions target military-linked entities, the banking system is dysfunctional, and the kyat trades at less than half its official rate on the parallel market. Before the coup, Myanmar's garment sector was the fastest-growing EU supplier. The Thilawa SEZ (Japan-developed) is the only operational SEZ. Any EU company considering Myanmar operations faces acute reputational, legal, and operational risk that outweighs the 25% CIT and 0% dividend WHT on paper.
How to read this page: ● measured sourced data · ◐ inferred analyst reading, basis linked · ○ projected anchored to a real starting point. Bracketed citations link to the sources at the foot of the page.
1. Trade with Myanmar
EU-Myanmar FTA
EU preferences SUSPENDED (2024)[3]
● measured EU-Myanmar trade is in a state of collapse. GSP/EBA preferences suspended (2024). Entity sanctions on military-linked businesses. Most major EU brands have exited or suspended Myanmar sourcing. Remaining EU-Myanmar trade is minimal and carries significant reputational and compliance risk. Any EU company considering Myanmar operations must conduct enhanced due diligence under CSDDD and assess forced labour risk under EUDR/CSDDD frameworks.[3,6]
EU exports to Myanmar by sector
| SITC section | Latest month (EUR) |
|---|---|
| 5. Chemicals | EUR 9M |
| 0. Food and live animals | EUR 2M |
| 6. Manufactured goods (by material) | EUR 2M |
| 8. Miscellaneous manufactured articles | EUR 2M |
| 7. Machinery and transport equipment | EUR 1M |
| 1. Beverages and tobacco | 302,573 |
| 4. Animal and vegetable oils/fats | 73,601 |
| 2. Crude materials (excl. fuels) | 6,765 |
| 9. Not classified elsewhere | 1,397 |
| 3. Mineral fuels and lubricants | 184 |
Source: Eurostat COMEXT (ds-059331). [5]
The Nordic lens: Finland's position
Finland's largest export sections: Machinery and transport equipment (35,207), Chemicals (15,989), Miscellaneous manufactured articles (7,029). Same COMEXT series, Finland as reporter.
Certification gate
● measured Myanmar's standards and certification infrastructure is severely underdeveloped and further degraded by the post-coup institutional collapse. The Department of Research and Innovation (DRI, under the Ministry of Education) nominally sets standards. FDA (Food and Drug Administration) under the Ministry of Health regulates pharmaceuticals and food. In practice, enforcement is minimal outside Yangon.[6]
- FDA registration for pharmaceuticals and food products: processing times unpredictable post-coup
- No functioning conformity assessment infrastructure comparable to ASEAN peers
- ASEAN MRA (Mutual Recognition Arrangements) for cosmetics, electrical equipment: Myanmar is a party but implementation is disrupted
- Garment sector historically relied on buyer-mandated audits (BSCI, WRAP, SA8000) rather than local standards
- Post-coup: international audit firms have largely withdrawn, making third-party verification extremely difficult
◐ inferred Myanmar's standards infrastructure is not a meaningful barrier to market entry because it barely functions. The binding constraints are operational (banking, logistics, conflict) and reputational (sanctions, forced labour, CSDDD exposure). For any remaining trade, buyer-mandated standards and international certifications substitute for non-existent local enforcement.
Free Trade Agreement
● measured EU suspended GSP/EBA (Everything But Arms) trade preferences for Myanmar effective 2024, citing serious and systematic violations of human rights following the February 2021 military coup. Previously, Myanmar enjoyed duty-free, quota-free access to the EU market as a Least Developed Country under EBA. The suspension means Myanmar exports now face EU MFN tariffs. EU entity sanctions apply to military-linked conglomerates (MEHL, MEC). Myanmar remains an ASEAN member and party to RCEP (though practical trade facilitation is disrupted by conflict).[3] Ratification status: EBA suspended by EU Council decision. Reinstatement would require demonstrated improvement in human rights and governance conditions.
2. Establish in Myanmar
Entity forms
| Type | What it can do | Route / approval | Timeline |
|---|---|---|---|
| Company Limited by Shares | Most common structure for FDI under Myanmar Companies Law 2017. 100% foreign ownership permitted in most sectors. Minimum 1 shareholder, 1 director. No minimum capital requirement in the Companies Law (MIC may set minimums for specific sectors). Must register with DICA (Directorate of Investment and Company Administration). MIC (Myanmar Investment Commission) permit required for MIC-permitted activities and restricted sectors. POST-COUP STATUS: DICA registration technically continues but regulatory environment is severely disrupted. | Pre-coup: DICA 1-2 weeks, MIC 4-8 weeks. Post-coup: timelines unpredictable; regulatory capacity severely degraded | Pre-coup: 4-12 weeks. Post-coup: unpredictable |
| Branch of Foreign Company | Registration of foreign company to operate in Myanmar. Parent company has unlimited liability. Must appoint a local authorised officer. Historically used by oil/gas companies and banks. POST-COUP STATUS: most international companies have withdrawn or suspended operations. | Pre-coup: 2-4 weeks. Post-coup: unpredictable | Pre-coup: 4-8 weeks. Post-coup: unpredictable |
| Representative Office | Cannot conduct commercial activity or generate revenue. Used for market research and liaison only. Must register with DICA. No tax obligations (no income generation permitted). Limited to marketing, research, and coordination activities. | Pre-coup: 1-2 weeks. Post-coup: unpredictable | Pre-coup: 2-4 weeks. Post-coup: unpredictable |
FDI sectors: automatic vs government route
| Sector | FDI cap | Route | Note |
|---|---|---|---|
| Garments (CMP: cut-make-pack) | 100% | Automatic (DICA registration) | Was Myanmar's fastest-growing export sector pre-coup. EU was the largest market (~EUR 2.5bn/year, 2019). Cut-make-pack model: fabrics imported, garments assembled, exported. Low labour costs were the key competitive advantage. POST-COUP: EU suspended GSP/EBA preferences (2024), removing duty-free access. Many EU brands have exited or suspended sourcing. Remaining production serves non-EU markets (Japan, South Korea). |
| Oil and gas | Varies (PSC terms) | Conditional (Ministry of Energy + MIC) | Yadana field (Total/Chevron, offshore), Shwe field (POSCO/ONGC, offshore). Total withdrew Jan 2022 citing human rights. Chevron followed. PTTEP (Thailand) continues operations. Myanmar Oil and Gas Enterprise (MOGE, military-controlled) is the state partner in all PSCs. EU and US sanctions target MOGE revenues. Gas revenue is a primary funding source for the military junta. |
| Gems (jade, rubies) | Joint venture with Myanmar partner required | Conditional (Ministry of Natural Resources + MIC) | Myanmar produces ~90% of the world's jade (Hpakant mines, Kachin State) and is a major source of rubies (Mogok). The gem sector is heavily linked to military and militia interests. EU and US sanctions apply to military-linked gem entities. Kachin State is an active conflict zone. The jade trade is estimated at USD 30-50bn/year (Global Witness), mostly informal and smuggled to China. |
| Agriculture (rice, beans, pulses) | 100% (processing); land ownership restricted | Conditional (MIC permit for large-scale) | Myanmar is a major rice exporter and the world's largest exporter of black-eyed beans/pulses (primarily to India). Agriculture employs ~50% of the workforce. Foreign companies cannot own agricultural land. Processing and trading is open to foreign investment but logistics and banking disruption post-coup make operations extremely difficult. |
| Thilawa SEZ | 100% | Automatic (Thilawa Management Committee) | Myanmar's only operational SEZ. Japan-developed (JICA-backed). Located 25 km south of Yangon. ~115 enterprises pre-coup (Japanese, Thai, Korean manufacturers). CIT exempt 5 years then 50% reduction 5 years. POST-COUP: some tenants have paused or exited. Zone continues to operate but at reduced capacity. Infrastructure (power, water) is more reliable than outside the zone but still subject to national grid constraints. |
Corporate tax rates
| Scenario | Basic rate | Effective rate | Note |
|---|---|---|---|
| Standard | 25% | 25% | One of the lowest CIT rates in ASEAN. Applies to resident companies on worldwide income and non-resident companies on Myanmar-source income. |
| Thilawa SEZ (first 5 years) | 0% | 0% | CIT exempt for first 5 years from commencement of commercial operations. |
| Thilawa SEZ (years 6-10) | 12.5% | 12.5% | 50% CIT reduction for years 6-10 (effective rate: 12.5%). |
MAT: No minimum alternative tax.. Foreign company PE rate: 25% on Myanmar-source income..[1]
Commercial tax (equivalent to VAT)
5%[1]
Commercial tax at 5% standard rate on goods and services. Applied at the point of sale (not a multi-stage VAT). Higher rates for specific goods: alcohol (60%), cigarettes (60%), gems/jade (15-30%). Zero-rated: exports. Exempt: basic foodstuffs, agricultural produce, electricity.
Withholding tax / TDS (key rates for EU parent)
| Type | Rate | Note |
|---|---|---|
| Dividends to non-resident | 0% | Myanmar does NOT levy WHT on dividends. No dividend withholding tax regardless of treaty status. |
| Interest to non-resident | 15% | 15% on interest payments to non-residents. Reduced under DTAs. |
| Royalties to non-resident | 15% | 15% on royalties paid to non-residents. Reduced under DTAs. |
| Service fees to non-resident | 2.5% | 2.5% on payments for services to non-residents. |
Payment and currency
● measured Managed float in name, heavily controlled in practice. The Myanmar kyat (MMK) was floated in 2012 but the Central Bank of Myanmar (CBM) has imposed severe controls since the Feb 2021 coup. Official rate: ~2,100 MMK/USD. Parallel (black market) rate: ~4,500-5,000 MMK/USD (mid-2026). The gap between official and parallel rates creates a de facto dual exchange rate. The MMK is NOT convertible in practice. Foreign exchange rationing by CBM. Mandatory conversion of export proceeds. Capital controls are severe.[6] Extremely difficult post-coup. CBM requires mandatory conversion of foreign currency proceeds. Repatriation of profits, dividends, and capital requires CBM approval, which is subject to foreign exchange availability and political discretion. In practice, many companies report inability to repatriate funds. The banking system is dysfunctional (bank runs in 2021, ATM withdrawal limits, digital payment disruptions).
◐ inferred The Myanmar banking system is dysfunctional post-coup. Bank runs in early 2021 depleted cash reserves. ATM withdrawal limits imposed. International wire transfers are extremely difficult. Correspondent banking relationships severed by many international banks. Cash-based transactions have increased. Hundi (informal value transfer) networks have expanded. Letters of credit are unreliable. For the small number of companies still operating, payment is primarily in USD cash or through Singapore/Thailand banking channels.[6]
Production-Linked Incentives
● measured Myanmar's investment incentive framework (MIC permits, Thilawa SEZ, sector-specific tax holidays) technically remains in law but is largely irrelevant in the current environment. The military junta (State Administration Council, SAC) continues to seek foreign investment, particularly from China, Thailand, and India, but most Western and many Asian investors have withdrawn. The investment climate is defined by civil war, sanctions, banking collapse, and reputational risk, not by tax incentives.[6,3,7,8]
| Sector | Status |
|---|---|
| Garments (CMP) | Was the flagship FDI success story: exports grew from ~USD 0.5bn (2012) to ~USD 5bn (2019). EU was the largest market. Post-coup and post-EBA suspension: EU sourcing has collapsed. Remaining production serves Japan, South Korea, and domestic markets. Many factories have closed. Labour rights monitoring has collapsed. |
| Gas (Yadana, Shwe) | Offshore gas fields remain in production. Total withdrew (Jan 2022), Chevron followed. PTTEP (Thailand) continues. MOGE (military-controlled state enterprise) is the counterparty for all gas PSCs. Gas revenue is a primary funding source for the junta. EU and US sanctions target MOGE. Gas exports primarily to Thailand via pipeline. |
| Thilawa SEZ | Japan-developed SEZ, 25 km south of Yangon. ~115 enterprises pre-coup (Japanese, Thai, Korean manufacturers). Zone continues to operate at reduced capacity. Infrastructure (power, water) more reliable than national average. Some Japanese manufacturers continue operations. |
| Agriculture | Rice and pulses/beans are major exports. India is the largest market for beans/pulses. Agriculture employs ~50% of workforce. Operates largely outside the formal economy and continues despite the conflict, though logistics disruption affects exports. |
| Gems (jade, rubies) | Myanmar produces ~90% of world jade and is a major ruby source. Sector is heavily linked to military/militia interests. EU/US sanctions apply. Global Witness estimates jade trade at USD 30-50bn/year (mostly informal, smuggled to China). Not accessible for legitimate EU investment. |
CRITICAL: Myanmar is in a state of civil war. The military junta (SAC) controls major cities and transport corridors but faces armed resistance from the NUG (National Unity Government), PDF (People's Defence Force), and ethnic armed organisations across much of the country. EU sanctions, EBA suspension, forced labour documentation, banking collapse, and reputational risk make Myanmar effectively uninvestable for EU companies. This section documents the legal framework for completeness; it should not be read as an invitation to invest.
Labour framework
● measured Myanmar's Employment and Skills Development Law (2013) and other labour legislation govern employment. Minimum wage: MMK 4,800/day (approx. USD 1-2/day at parallel rate). Standard working week: 44 hours (8 hours/day, 5.5 days). Overtime: 2x. Annual leave: 10 days. Employer social security contribution: 3% of salary (Social Security Board). POST-COUP: labour law enforcement has collapsed outside Yangon. Military conscription law enacted Feb 2024 (all citizens 18-35 eligible for 2 years military service). Labour law is national. Ministry of Labour administers (under SAC control). POST-COUP: ILO has documented widespread forced labour by the military (forced portering, forced construction, land confiscation). Military conscription law (Feb 2024) allows conscription of all citizens aged 18-35 for up to 2 years. Independent trade unions have been suppressed. CTUM (Confederation of Trade Unions of Myanmar) leaders arrested or in exile.[6,8]
- Minimum wage: MMK 4,800/day (approx. USD 1-2/day at parallel rate); not adjusted since 2018; real value eroded by inflation and kyat depreciation
- Military conscription law (Feb 2024): all citizens aged 18-35 eligible for 2 years military service; creates workforce disruption for all employers
- ILO documented forced labour: forced portering, forced construction, land confiscation by military in conflict zones
- Independent trade unions suppressed since Feb 2021 coup; CTUM leaders arrested or in exile
- Employer social security: 3% of salary; employee: 2%; system functioning in Yangon only
- CSDDD/EUDR red flag: any EU company with Myanmar supply-chain exposure faces mandatory human rights due diligence obligations and forced labour risk
The opportunity
Myanmar's opportunities are conditional and suspended pending political resolution. Before the coup: garments were the fastest-growing EU supplier, CIT 25%, 0% dividend WHT, and the Thilawa SEZ was operational. Current status: all of these are effectively inaccessible to EU companies due to sanctions, civil war, and operational collapse.
Pre-coup: garments fastest EU growth
● measured Before the February 2021 coup, Myanmar's garment sector was the fastest-growing supplier to the EU market, benefiting from EBA duty-free access and low labour costs. This trade relationship is now effectively frozen.[6]
On paper: 25% CIT, 0% dividend WHT
● measured Myanmar's headline tax rates (25% CIT, 0% dividend WHT) appear competitive. In practice, profit repatriation is effectively blocked post-coup due to banking system dysfunction, capital controls, and the kyat's parallel-market collapse.[1]
Thilawa SEZ
● measured The Thilawa SEZ (Japan-developed, near Yangon) is the only operational special economic zone. It offered streamlined customs and one-stop services. Post-coup operations are severely disrupted.[6]
Current status: suspended
● measured All opportunities listed above are conditional on political resolution. EU sanctions target military-linked entities. EBA preferences are suspended. The banking system is dysfunctional. Any EU company considering Myanmar faces acute reputational, legal, and operational risk.[6]
3. Dangers register
7 entries across 5 categories. Each states the mechanism (how it bites an EU company), the evidence (sourced), the mitigation, and what evidence would change the assessment.
Operational collapse (banking, internet, conflict zones)
Myanmar's commercial infrastructure has collapsed since the coup. The banking system suffered runs in early 2021 and has not recovered: ATM withdrawal limits, international wire transfer disruptions, correspondent banking relationships severed by major international banks. Internet restrictions (mobile data shutdowns, VPN bans) disrupt communications. Power supply is unreliable (grid damage from conflict, fuel shortages). Transport corridors are subject to military checkpoints, conflict disruption, and banditry. Supply chains that functioned pre-coup are broken.
● measured Bank runs (Feb-Mar 2021): depositors withdrew ~30% of system deposits. ATM withdrawal limits: MMK 300,000-500,000/day. International wire transfers: multiple-week delays or failures. Telenor (Norwegian telco) sold its Myanmar operations (2022) citing human rights concerns. Mobile data shutdowns in conflict zones. Power outages averaging 8-12 hours/day in some regions. Roads in conflict zones impassable.[12,6]
Military coup and ongoing civil war
Mechanism: The Tatmadaw (Myanmar military) seized power on 1 February 2021, detaining elected leaders including Aung San Suu Kyi. The State Administration Council (SAC) governs from Naypyidaw but faces armed resistance from the National Unity Government (NUG) and its People's Defence Force (PDF), as well as from ethnic armed organisations (EAOs) including the Kachin Independence Army (KIA), Karen National Union (KNU), and Arakan Army (AA). The military controls major cities and transport corridors but large areas of the country are contested or outside military control. The conflict has no clear path to resolution.
Evidence: Over 5,000 civilians killed by military since Feb 2021 (AAPP). 2M+ internally displaced (OCHA, 2025). Military controls Yangon, Mandalay, Naypyidaw and main transport corridors. NUG/PDF and EAOs control or contest significant territory in Sagaing, Magway, Chin, Kayah, Karen, Kachin, and northern Shan states. The Arakan Army controls most of Rakhine State. Resistance forces captured several border towns in late 2023 (Operation 1027).[10]
Current status: Active civil war with no ceasefire or peace process. The military's territorial control has been shrinking since late 2023 (Operation 1027 by the Three Brotherhood Alliance captured northern Shan border towns). The SAC announced conscription (Feb 2024), indicating manpower pressure. No diplomatic resolution is in progress. ASEAN's 5-point consensus has not been implemented.
Mitigation: For EU companies: the only risk mitigation is non-exposure. Do not enter Myanmar or maintain Myanmar operations. Any presence creates sanctions compliance risk, reputational risk, and physical security risk. For companies with existing supply-chain exposure: conduct enhanced due diligence under CSDDD. Develop exit plans.
What would change the assessment: Genuine ceasefire and inclusive political dialogue. Military withdrawal from politics. Free elections. Lifting of EU sanctions. None of these are expected in the medium term.
EU sanctions and EBA trade preference suspension
Mechanism: The EU has imposed multiple rounds of sanctions on Myanmar since the Feb 2021 coup: entity sanctions on military-linked conglomerates (MEHL, MEC), arms embargo, travel bans on junta leaders and their business associates. In 2024, the EU suspended GSP/EBA (Everything But Arms) trade preferences, removing Myanmar's duty-free access to the EU market. This decision was based on serious and systematic violations of human rights (ILO forced labour findings, military atrocities documented by the UN). The EBA suspension applies to all Myanmar exports, not just military-linked ones.
Evidence: EU EBA suspension effective 2024. EU sanctions: 11 rounds since 2021. Arms embargo. Travel bans on ~100+ individuals. Entity sanctions on MEHL (Myanmar Economic Holdings Limited), MEC (Myanmar Economic Corporation), and subsidiaries. EU garment imports from Myanmar dropped from ~EUR 2.5bn (2019) to <EUR 1bn (2025, estimated). H&M, Primark, and other major buyers exited or reduced sourcing.[3]
Current status: Active and intensifying. The EBA suspension is the most economically impactful measure. EU sanctions are regularly expanded. For EU companies, any trade with Myanmar requires sanctions screening. Engaging with military-linked entities is prohibited. The EBA suspension makes Myanmar uncompetitive for EU-destined exports (garment tariffs jump to ~12% MFN).
Mitigation: For EU companies: conduct full sanctions screening before any Myanmar-related transaction. Verify that no military-linked entity (MEHL, MEC, or subsidiaries) is in the supply chain. Consider that EBA suspension applies to ALL Myanmar exports. CSDDD mandatory due diligence applies to Myanmar supply chains.
What would change the assessment: Restoration of civilian government. Demonstrated improvement in human rights conditions. ILO monitoring confirming end of forced labour. Formal EU review and reinstatement of EBA. These conditions are not met and are not expected in the medium term.
Operational collapse (banking, internet, conflict zones)
Mechanism: Myanmar's commercial infrastructure has collapsed since the coup. The banking system suffered runs in early 2021 and has not recovered: ATM withdrawal limits, international wire transfer disruptions, correspondent banking relationships severed by major international banks. Internet restrictions (mobile data shutdowns, VPN bans) disrupt communications. Power supply is unreliable (grid damage from conflict, fuel shortages). Transport corridors are subject to military checkpoints, conflict disruption, and banditry. Supply chains that functioned pre-coup are broken.
Evidence: Bank runs (Feb-Mar 2021): depositors withdrew ~30% of system deposits. ATM withdrawal limits: MMK 300,000-500,000/day. International wire transfers: multiple-week delays or failures. Telenor (Norwegian telco) sold its Myanmar operations (2022) citing human rights concerns. Mobile data shutdowns in conflict zones. Power outages averaging 8-12 hours/day in some regions. Roads in conflict zones impassable.[12,6]
Current status: Ongoing deterioration. The banking system has stabilised at a low level of functionality (basic domestic transfers work in Yangon). International payments remain extremely difficult. Internet restrictions continue. Infrastructure is degrading (no maintenance, conflict damage). Thilawa SEZ functions better than the rest of the country but is not immune to national disruptions.
Mitigation: For the small number of companies still operating: maintain cash reserves in hard currency outside Myanmar. Use Singapore or Thailand banking channels. Maintain redundant communications (satellite phones). Have evacuation plans for international staff. Accept that normal business operations are not possible.
What would change the assessment: Ceasefire allowing infrastructure repair. Banking system recapitalisation. Restoration of international correspondent banking. Internet freedom. These require political resolution of the conflict.
MMK parallel exchange rate and capital controls
Mechanism: The Central Bank of Myanmar (CBM) sets an official exchange rate of ~2,100 MMK/USD, but the market (parallel) rate is ~4,500-5,000 MMK/USD (mid-2026). The gap creates a de facto dual exchange rate. The CBM requires mandatory conversion of export proceeds at the official rate, creating a ~50-60% implicit tax on exporters. Capital controls are severe: repatriation of profits requires CBM approval (often denied or indefinitely delayed). The MMK has lost ~80% of its value against the USD since the coup (official rate: ~1,350 in Jan 2021 to ~2,100 in 2026; parallel rate: ~1,350 to ~5,000).
Evidence: Official rate: ~2,100 MMK/USD. Parallel rate: ~4,500-5,000 MMK/USD. Gap: ~50-60%. CBM directive (Apr 2022): mandatory conversion of foreign currency inflows at official rate. Inflation: ~20-25% officially, likely higher in reality. MMK pre-coup: ~1,350/USD (Jan 2021).[11]
Current status: Active and worsening. The dual rate creates impossible economics for legitimate businesses. Companies that earn revenue in MMK at official-rate-denominated prices cannot cover USD-denominated costs. Exporters lose value at mandatory conversion. The parallel rate reflects the true economic value of the kyat.
Mitigation: For any remaining Myanmar operations: price in USD. Minimise kyat holdings. Accept that profit repatriation may be impossible. Factor the parallel rate (not the official rate) into all economic calculations. Consider that trapped capital may not be recoverable.
What would change the assessment: CBM allowing market-determined exchange rate. Lifting of mandatory conversion. Restoration of capital account convertibility. These require regime change or fundamental policy reversal.
Forced labour (ILO documented, CSDDD/EUDR red flag)
Mechanism: The ILO has documented widespread forced labour in Myanmar, perpetrated primarily by the military: forced portering (civilians compelled to carry military supplies), forced construction (roads, military infrastructure), land confiscation, and forced recruitment. In February 2024, the SAC enacted a military conscription law allowing conscription of all citizens aged 18-35 for up to 2 years of military service. This creates a systemic forced labour risk across the entire economy, not just in military-linked sectors. For EU companies, Myanmar is a red flag under CSDDD (Corporate Sustainability Due Diligence Directive) and EUDR (EU Deforestation Regulation) forced labour provisions.
Evidence: ILO Forced Labour reports (2022, 2023, 2024): documented forced portering in Sagaing, Magway, Chin, Kayah, Karen. Military conscription law (Feb 2024): applies to all citizens 18-35. CTUM (trade union confederation) leaders arrested or in exile. Independent labour monitoring is impossible in most of the country. US Customs & Border Protection has issued Withhold Release Orders (WROs) on Myanmar products.[8]
Current status: Active and worsening. The conscription law represents a qualitative escalation. Forced labour is not limited to a few sectors; it is systemic. Independent monitoring is impossible. For EU companies, any Myanmar supply-chain link creates mandatory due diligence obligations and potential liability under CSDDD.
Mitigation: For EU companies: the most effective mitigation is complete supply-chain exit from Myanmar. If exposure remains, conduct enhanced due diligence with on-the-ground verification (extremely difficult to achieve given access constraints). Document all due diligence efforts for CSDDD compliance. Monitor US WROs for detained shipments.
What would change the assessment: Repeal of conscription law. End of military forced labour practices. Restoration of independent trade unions and labour monitoring. ILO confirming significant improvement. None expected in current political environment.
Reputational risk for EU companies with Myanmar operations
Mechanism: Any EU company maintaining operations, sourcing, or supply-chain links in Myanmar faces reputational risk from association with a military junta that has committed documented atrocities (killing of protesters, aerial bombardment of civilian areas, forced displacement). NGOs (Amnesty International, Human Rights Watch, Burma Campaign UK) actively monitor and publicise corporate engagement with Myanmar. The EBA suspension by the EU itself signals that normal commercial engagement is not acceptable. Media exposure of Myanmar supply-chain links has led to consumer boycotts and investor pressure on several European brands.
Evidence: Total withdrew Jan 2022 (citing human rights). Telenor sold Myanmar operations 2022. H&M, Primark reduced/exited sourcing. Kirin (Japan) terminated JV with MEHL (military conglomerate) after public pressure. APM-Maersk restricted services. Multiple European garment brands issued exit statements. NGO campaigns targeted companies maintaining Myanmar links.[3,10]
Current status: Active. Corporate exits continue. The remaining companies with Myanmar exposure face ongoing reputational scrutiny. ESG investors screen for Myanmar exposure. CSDDD creates legal liability for inadequate due diligence.
Mitigation: Exit Myanmar operations and supply chains. If immediate exit is not possible, develop a public, time-bound exit plan. Document human rights due diligence. Do not enter new commercial relationships in Myanmar.
What would change the assessment: Restoration of civilian government and credible human rights improvement. Lifting of EU sanctions. Reinstatement of EBA. International community consensus that commercial engagement is appropriate. None of these conditions are met.
Humanitarian crisis (2M+ displaced, food insecurity)
Mechanism: The civil war has created a humanitarian catastrophe. Over 2 million people are internally displaced (OCHA, 2025). Food insecurity affects ~15.2 million people. Cyclone Mocha (May 2023) affected 7.9 million in Rakhine and Sagaing, compounding conflict-driven displacement. Humanitarian access is severely constrained by the military, which blocks aid deliveries to resistance-controlled areas. The healthcare system has largely collapsed outside major cities (many health workers joined the Civil Disobedience Movement). Education is disrupted (schools closed in conflict zones, parallel education systems established).
Evidence: 2M+ IDPs (OCHA, 2025). 15.2M food insecure (WFP). Cyclone Mocha (May 2023): 7.9M affected, >150 deaths. Healthcare worker exodus (Civil Disobedience Movement). UNHCR: 1.3M Rohingya refugees in Bangladesh (from 2017 crisis, unresolved). Humanitarian aid: UN appealed for USD 887M (2024), received <50%.[13]
Current status: Worsening. Displacement is increasing as conflict expands. Food insecurity is structural (agricultural disruption, logistics breakdown, inflation). The humanitarian crisis creates workforce disruption, social instability, and operational risk for any commercial activity in affected areas.
Mitigation: Not a commercially manageable risk. The humanitarian crisis is a symptom of the civil war. It affects labour availability, consumer demand, logistics, and social stability. For companies still in Myanmar: ensure operations do not contribute to the crisis (no forced evictions, no complicity in aid blockages).
What would change the assessment: Ceasefire. Humanitarian access. Political resolution. International humanitarian funding at scale. Rohingya return and resettlement. These are political, not commercial, solutions.
13 primary sources spanning EU/Myanmar government publications, WTO tariff data, Eurostat trade data, and specialist legal/tax summaries.
- [1] PwC / ICLG, Myanmar Corporate Tax Laws (2026): 25% standard CIT, Thilawa SEZ exempt 5yr then 50% reduction 5yr, commercial tax 5%
- [2] Myanmar Companies Law 2017: allows 100% foreign ownership in most sectors; DICA (Directorate of Investment and Company Administration) administers; Myanmar Investment Commission (MIC) approval for MIC-permitted activities
- [3] EU Council: GSP/EBA trade preferences for Myanmar suspended effective 2024 due to serious and systematic violations of human rights following the Feb 2021 military coup; entity sanctions on military-linked conglomerates (MEHL, MEC)
- [4] WTO, World Tariff Profiles 2025: Myanmar
- [5] Eurostat COMEXT (ds-059331): EU27 and Finland trade with Myanmar by SITC section, monthly
- [6] US Department of State, 2025-2026 Investment Climate: Myanmar (Burma)
- [7] Thilawa SEZ (Japan-developed, JICA-backed): Myanmar's only operational SEZ; CIT exempt 5 years then 50% reduction 5 years; 25 km south of Yangon; ~115 enterprises pre-coup
- [8] ILO, Forced Labour in Myanmar (2023-2025): documented forced labour by military, including military conscription law (Feb 2024), forced portering, land confiscation
- [9] Transparency International, CPI 2025: Myanmar score ~20/100, rank ~162/182 (near-bottom governance; worst in ASEAN)
- [10] Military coup (1 Feb 2021): State Administration Council (SAC) seized power from elected NLD government; civil war ongoing; NUG (National Unity Government) and PDF (People's Defence Force) resist; ethnic armed organisations control large territories
- [11] MMK/USD: official ~2,100, parallel ~4,500-5,000 (mid-2026); CBM imposed foreign exchange controls; mandatory conversion of export proceeds; de facto dual exchange rate
- [12] Myanmar banking system: bank runs (2021), ATM withdrawal limits, international correspondent relationships severed, CBM foreign exchange rationing; World Bank and ADB suspended new lending
- [13] OCHA/UNHCR: 2M+ internally displaced (2025); humanitarian access severely constrained; Cyclone Mocha (May 2023) affected 7.9M; food insecurity affecting ~15.2M people
As of July 2026. Statutory facts verified against primary sources; practice claims cite the basis.