CDS position statement on the European Commission’s call for evidence for an impact assessment on the EU Delivery Act

On 6 October 2025, the European Commission published a Call for Evidence for an Impact Assessment related to a forthcoming EU Delivery Act, aimed at modernising the current EU postal and delivery regulatory framework.

The Centre for a Digital Society (CDS) at the European University Institute (EUI) welcomes the opportunity to contribute to this consultation. In this submission, we focus on five problems identified in the Call for Evidence:

1) The sustainability and financing of the universal service obligation (USO) (Problem 1);

2) The adequacy of the scope and the effectiveness of complaints handling systems for ecommerce (Problem 2);

3) The question of the applicability of the relevant legislation to the relevant operators (Problem 3);

4) The obstacles to cross-border e-commerce (Problem 4), and

5) The question of the proportionality of the administrative burden on regulators and operators (Problem 5).

While all five issues are interrelated, our analysis primarily addresses Problems 1, 3, and 5. Also, we consider Problem 2 to be largely a symptom of Problems 3 and 4, reflecting deeper asymmetries in the regulatory scope and diversity of delivery markets across the EU Member States.

Our contribution aims to inform and support the policy debate on how to ensure an efficient, equitable, and future-proof framework for postal and delivery services in the EU single market.

In the conclusions, the CDS recommends that the forthcoming EU Delivery Act:

1. Reconceptualise the Universal Service Obligation around as a flexible, outcome-oriented guarantee.

2. Redefine the scope of postal and delivery regulation based on functional equivalence.

3. Ensure technological and business-model neutrality.

4. Promote interoperability and cross-border data exchange standards.

5. Ensure proportionality of the new regulatory framework.