Balancing universality, innovation, and competition in delivery markets: the case of out-of-home
Postal services connect citizens, businesses and public institutions across the EU. The Postal Services Directive (PSD) guarantees every user a minimum level of postal service at an affordable price, wherever they live. The European Commission is now preparing a new EU Delivery Act to replace this Directive.
Two structural shifts are pulling the current model in opposite directions. Declining letter volumes are eroding the economies of scale that make daily home delivery affordable. At the same time, the rise of e-commerce and out-of-home delivery, such as parcel lockers and pick-up points, means fewer consumers rely on home delivery as an essential service. The key question is whether the current universal service obligation specification remains proportionate to its original objective, or whether it now goes beyond addressing genuine market failures in a postal sector that has undergone profound structural change since the Directive was adopted.
Against this backdrop, the Polish National Employers' Association of Private Postal Operators (OZPNOP) asked us to assess how the future postal universal service obligation could support effective competition in letter and parcel delivery while preserving efficiency and innovation, with a particular focus on out-of-home delivery.
The main conclusions of our study
The five-day home delivery obligation is financially unsustainable at current and projected letter volumes, and several Member States have already relaxed it in practice.
The EU Delivery Act should enable universal service obligations to align with current and future user needs and financially sustainable delivery models, while preserving a minimum common standard for affordability, territorial reach, and user access.
Out-of-home delivery can lower costs, match changing consumer preferences and reduce barriers to entry, but its benefits vary across services, user groups and Member States.
The EU Delivery Act should recognise out-of-home delivery as a valid universal service channel, adopt a technology-neutral approach to place of delivery, and keep targeted safeguards for users who need home delivery.
The evidence does not show a general market failure in the parcel locker market that would justify broad ex-ante access regulation. Multiple operators are investing and competing across Member States.
Access regulation should only apply where a specific market failure is clearly diagnosed, with a stronger case where infrastructure has received significant public support.
This study was commissioned by OZPNOP.
In brief
European consumer preference for home delivery fell from 73 per cent in 2022 to 61 per cent in 2025, and out-of-home delivery now costs a fraction of delivering to the door, so the five-day home delivery obligation no longer matches what users need or what Member States can afford.
61-73%Fall in the share of European e-shoppers preferring home delivery between 2022 and 2025, with parcel lockers and pick-up points making up the difference. In Northern and Eastern Europe, out-of-home delivery is now the primary mode for e-commerce.
EUR 0.7-7.7Estimated Norwegian delivery cost per parcel, falling from EUR 7.7 for home delivery to EUR 2.5 for parcel lockers and EUR 0.7 for pick-up points. Across settings, out-of-home delivery generates cost savings of 10 to 55 per cent against home delivery.
Around 65% Share of total universal service net costs in the Czech Republic accounted for by delivery frequency and postal network density together, the two main cost drivers.
87% against 44%Share of urban Polish residents living within 500 metres of an automated parcel machine or pick-up point, against post offices. In rural areas the comparison is 87 per cent within 3 km, against 70 per cent for post offices.
73% against 20%Share of consumers preferring out-of-home delivery for parcels in Poland, against Austria, showing how far preferences diverge between Member States.
Commissioned by the Polish National Employers’ Association of Private Postal Operators (OZPNOP). Published 27 August 2026. Contact: Mindaugas Cerpickis, Partner. European Union, with country evidence from Poland, Norway, the Czech Republic, Lithuania, Finland, Denmark, and others.
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About this analysis
Copenhagen Economics assessed how a future postal universal service obligation could make use of effective competition in letter and parcel delivery while preserving efficiency and innovation, as input to the European Commission’s development of an EU Delivery Act to replace the Postal Services Directive. The study addresses two policy questions: whether current universal service requirements still reflect what consumers consider essential, and whether growth in out-of-home delivery infrastructure would justify mandated access regulation. It draws on desk research, case law, academic literature, EU and national regulatory decisions, state aid assessments, consumer surveys, and geospatial data on out-of-home networks. Out-of-home delivery as a universal service channel is assessed through a four-step framework covering the legal baseline, user needs and policy objectives, what the market delivers, and proportionate remedies; access regulation is assessed by testing whether the preconditions for intervention, namely a clearly identified market failure, are met.
The report states that the benefits of out-of-home delivery are not uniform across services, user groups, or Member States, and recommends that the framework allow out-of-home delivery as part of universal service only where national evidence justifies it, with targeted safeguards for users for whom it is less suitable. On access regulation it finds that the available evidence does not indicate a generalised market failure, while noting a potentially stronger case where infrastructure has been deployed with significant public support. Copenhagen Economics states that the client chooses the research question, that CE analyses it, and that the findings and conclusions are CE’s own.