Contribution to the Public Consultation on the Draft ERGP Medium-Term Strategy 2026–2028

PostEurop, the association of European public postal operators, welcomes the opportunity to contribute to the ERGP’s Medium-Term Strategy 2026–2028. Building on our previous inputs to the ERGP Work Programmes for 2024 and 2025 and to the ERGP Report Regarding the Future Regulatory Postal Framework, we underline the following challenges and priorities.

Key challenges and emerging trends to prioritise (and possible overlooked issues)

• Universal Service at the core: The USO remains essential for social and economic cohesion. Its value endures if aligned with user needs, cost realities and market evolution. The USO should thus remain central to the revision of the revised regulatory framework under a new EU Delivery Act.
• Flexibility for Member States: Member States need discretion to adapt delivery frequency, quality standards, access points and place of delivery in line with declining volumes, user preferences, and geographic/social conditions. A rigid “one-size-fits-all” EU approach would risk undermining the sustainable provision of USO.
• Financial sustainability of the USO: Affordable universal services require a reliable compensation framework and recognition of rising operational costs. This aspect is often underplayed in ERGP reports.
• Competition and unfair practices: Risks from vertically integrated e-commerce platforms with strong market power must be acknowledged. However, extending postal regulation to widen its scope or introducing ex-ante SMP regimes is not justified; existing EU competition law, DMA and DSA provide the right instruments to address potential issues. As regards the suggestion for strengthened network access obligations, it could have adverse effects and ultimately, further increase the net cost for universal service providers. Concerning infrastructure sharing, contractual freedom to reach such agreements should be kept, provided they comply with competition law.
• Cross-border monitoring: Current CBPR data collection is disproportionate and of limited user benefit. Additional NRA tools are unnecessary as cross-border parcel markets are already competitive.