Contribution to the European Commission’s Call for Evidence on the “New EU Delivery Act – Reform of EU Postal Rules” Initiative

INTRODUCTION

PostEurop welcomes the opportunity to provide input to the European Commission’s call for evidence on the “EU Delivery Act”1. The review of the postal regulatory framework is of utmost importance for PostEurop and its members, the universal service providers (USPs).
In this contribution, we outline our key recommendations and concerns regarding the problems and objectives stated in the call for evidence, as well as our position on the suggested policy options.

PostEurop remains committed to engaging with the Commission and other stakeholders to ensure that the future regulatory framework effectively addresses the needs of USPs and supports the development of the postal sector.

Problem 1: The financing of the universal service obligation (USO) is becoming gradually unsustainable, potentially affecting accessibility

Objective 1: Safeguard universal access to postal delivery2 services for all citizens and businesses at all points on EU territory, in financially sustainable conditions

PostEurop members agree with the Commission’s stated problem that the financial sustainability of the USO is increasingly becoming a challenge due to market evolutions, namely declining letter volumes.

PostEurop recommends that the Commission prioritises the following areas in the review of the postal regulatory framework:

• A sustainable and flexible USO framework: The USO should remain at the core of the regulatory framework, ensuring that postal operators can fulfil the USO in an economically sustainable manner, while safeguarding users’ access to basic postal services.
• Universal access and cohesion: The USO must preserve its “universal” nature, guaranteeing that basic postal services remain available for all users across the EU, particularly in rural and remote areas, thereby contributing to territorial, social and economic cohesion.
• Flexibility and subsidiarity: The regulatory framework should preserve Member States’ ability to define the scope and modalities of the USO — including delivery frequency, domestic quality standards, access points and place of delivery — in accordance with national volumes, user preferences, and geographic or social conditions. Upholding the principles of flexibility and subsidiarity is essential to ensure that the USO remains proportionate, effective and financially sustainable, while continuing to meet users’ needs across diverse national contexts. Such an approach would not lead to fragmentation of the Single Market but rather guarantee that the universal service can be maintained efficiently and affordably for all citizens throughout the Union.
• Effective and reliable compensation mechanism: The new framework should guarantee that, where a net cost arises from the provision of the USO, Member States are obliged to fully and promptly compensate USPs. A simplified and balanced State Aid framework would facilitate timely compensation, while ex-post controls by national regulatory authorities (NRAs) could replace burdensome ex-ante notification procedures.
• Focus on reliability and predictability: The emphasis of the USO should shift from speed toward reliable and predictable basic postal delivery services as this approach better reflects current market realities and user needs.
• Proportioned protection for vulnerable users: The definition of vulnerable users should be determined at the national level, enabling Member States to tailor measures to specific needs and ensure that the concept remains future-proof. Maintaining the universal nature of the USO ensures inclusiveness, while targeted provision can complement national policies where needed.