Key challenges in tackling undeclared work in the Courier, Express, and Parcel Delivery sector

The Courier, Express, and Parcel (CEP) sector faces significant challenges related to undeclared work, complex subcontracting structures, and enforcement difficulties. Undeclared work in the CEP sector is driven by both supply- and demand-side factors. On the demand side, the cost factor of labour is key in encouraging non-compliant employment practices. Large logistics companies often outsource their parcel delivery operations to businesses commonly referred to as ‘service partners to reduce costs, shifting responsibility for working conditions onto these subcontractors. Findings from inspections and reporting by social partner organisations indicate that service partners often engage in non-compliant business practices, such as misclassifying workers (bogus self-employment) or underreporting employment to evade taxes and social security contributions. Additionally, cross-border operations complicate compliance when couriers drive vehicles registered in different countries, potentially violating cabotage and posted worker regulations. On the supply side, although there is little evidence based on studies, labour inspectorates and trade unions assume that a high proportion of CEP workers are EU mobile workers or third countries nationals, with limited access to the local labour market. This structural vulnerability makes them more susceptible to labour abuse, particularly in subcontracting chains where compliance monitoring is difficult. The mobile nature of courier work further complicates enforcement, as workers are constantly on the move. Paradoxically, while logistics companies use digital handheld devices to track parcel deliveries, these same devices are rarely used to monitor working hours, creating a regulatory blind spot. The most common forms of undeclared work in the CEP sector include underreporting workers to social security institutions , remuneration below the minimum wage due to underreporting of working hours, and unregistered businesses. While bogus self-employment remains an issue in some countries, such as France, it appears to be decreasing in others, including Germany and Spain. Violations of posting regulations, however, exist to a small extent, as cross-border parcel delivery does not account for the majority of shipments. The study highlights that undeclared work in the CEP sector remains a pressing issue but increasing awareness and targeted measures, including inspections and legislative reforms, are gradually addressing the problem. The complexity of subcontracting chains hinders accountability, underscoring the need for stronger enforcement mechanisms and clearer regulatory frameworks.