Regulatory developments

Introduction

PostNL operates in a highly regulated environment. This is, among other reasons, due to the fact that PostNL is designated as the provider of the universal service obligation (USO) and the only postal transport company with a nationwide network in the Netherlands. PostNL is also a transport company and a labour-intensive company, with sustainability high on its agenda, areas in which there are many rules and regulations at local, national, EU and international level. Politicians, public authorities and other relevant stakeholders have a major impact on rules and regulations that affect our sector and our business.

Consequently, PostNL maintains contacts with policymakers and stakeholders on developments in the sector, social developments, as well as changes to and the implementation of rules and regulations. We strongly believe that advocacy by stakeholders is crucial to the development of high-quality and meaningful new rules and regulations that will benefit all stakeholders in society. PostNL is always available to share its sector-specific knowledge and market experiences.

As many regulatory issues affect not only PostNL but also other companies in our sector or region, we work with different industries and trade associations. These associations address various issues of relevance to our sector from different perspectives (a list of associations and contributions can be found in the Content index later in this chapter). Within these associations, we not only develop common positions on future regulation, but also exchange knowledge and best practices and create voluntary sectoral initiatives. PostNL holds various board positions and actively participates in working groups and events organised by these associations. We do not make any financial contributions to political parties or politicians’ election campaigns. We are registered in the EU Transparency Register and apply its code of conduct. This chapter elaborates on the most impactful regulatory developments.

Postal developments

Revision of Dutch postal legislation

Dutch postal legislation, including the Postal Act and secondary legislation, sets standards for the USO. Due to the structural decline in mail volumes, evolving customer needs and rising autonomous costs, the current postal network through which USO and non-USO mail is delivered is no longer financially viable. As a result, further significant adjustments to the postal network are necessary. However, within the current legal framework, PostNL can no longer sufficiently adapt its postal operations. The legal framework for the USO therefore determines the current network set-up, even though the USO represents less than 15% of total postal volumes. Without adjustments to the legal requirements, PostNL is unable to take the necessary steps to transition towards a financially sustainable and future-proof postal service.

In 2025, PostNL therefore continued its efforts to constructively contribute to ongoing policy discussions regarding Dutch postal legislation and urged the Dutch government to amend the Postal Act to help secure a suitable postal service for everyone in the Netherlands – one that is aligned with market dynamics and maintains financial sustainability.

On 30 June, supported by a study by the Authority for Consumers and Markets (ACM) showing that the current situation is unsustainable and that change is urgently needed, the government proposed amendments to the Postal Act. These changes mainly relate to access to the network and the continuity of the Universal Postal Service. PostNL considered the proposed changes to be insufficient, due to a combination of high remaining standards and the absence of financial compensation. As a result, the postal service would remain loss-making until at least 2029, jeopardising the continuity of postal services in the Netherlands. Parliament was not ready to debate the proposed revision of the Postal Act in 2025. A further amendment by the Minister to the proposed revision of the Postal is expected in 2026.

Secondary legislation proposes changes to transit time and quality standard

On 3 October 2025, the Minister proposed an amendment to the Postal Decree to adjust the transit time to delivery within two days (D+2) from July 2026 with a 90% quality standard, and to delivery within three days (D+3) from July 2027 with a 92% quality standard. The Minister is able to make these changes under the current legislation. The Council of Ministers approved the proposed amendment. PostNL considers this amendment to be an important first step towards a future-proof USO that meets the needs of postal users, in line with adjustments already made in other European countries. However, it does not yet result in a future-proof USO. Even with the proposed adjustments, the remaining USO requirements continue to result in high net costs and a disproportionate financial burden for PostNL. The proposed amendment was subject to a preliminary parliamentary review procedure (voorhangprocedure) in the Dutch Parliament. Parliament concluded the procedure in February 2026 by adopting a motion explicitly supporting the amendment. This marked an important step towards implementation as of July 2026. The Postal Decree will subsequently be submitted to the Council of State for advice. PostNL has already initiated internal preparations to ensure timely implementation of the D+2 model.

Request for financial compensation for the USO

Despite ongoing efforts to modernise Dutch postal legislation, political decision-making on the future of the postal market takes time, while the costs of the USO continue to rise. Therefore, in February 2025, PostNL requested that the government reimburse the costs of the USO, as these impose an unreasonable financial burden on the company. The request for financial compensation amounts to €30 million in 2025 and €38 million in 2026 and concerns only the net costs of the USO. These net costs, and thus the requested compensation, have been determined as follows.

The USO regulation contains requirements intended to ensure that postal operators maintain a minimum level of service to the public. While these requirements provide societal benefits, they may also impose costs on postal operators. Some services may be economically unviable and would not be provided in the absence of government regulation. Net costs of the USO represent the costs incurred by a postal operator that could be avoided without legal requirements, minus the benefits of the USO. For example, for non-USO mail, PostNL already delivers under a D+2 model (mail delivered within two working days). The USO regulation prevents PostNL from aligning USO mail with this frequency, creating costs that could otherwise be avoided. Furthermore, PostNL provides services such as collecting and delivering mail from the country’s orange postboxes five days a week, maintaining a specific distribution of postboxes, and delivering specialised services including braille letters, bereavement mail and medical mail.

Under European legislation, the provider responsible for the USO is entitled to receive compensation for the net cost of the service if this constitutes a disproportionate financial burden. PostNL incurs significant net costs that result in such a burden. The structural decline in mail volumes, changing customer needs and rising costs have turned the USO into a loss-making activity in its current form. In several other European countries, including Italy, Spain and France, compensation has also been provided to the designated USO provider. In June 2025, the Minister rejected PostNL’s request for financial compensation. PostNL objected to this decision. In December, the Minister rejected the objection, and PostNL filed an appeal with the court.

Rejection of advance payment for financial compensation of the USO

After the rejection of financial compensation by the Minister in June 2025, PostNL submitted a request to the Administrative High Court for Trade and Industry (CBb) for an advance payment of €15 million per year for 2025 and 2026. The CBb rejected this request on 5 September, but explicitly noted that PostNL has substantiated, with concrete documentation, the increasing need to take measures with regard to the USO and that there was an element of urgency. In this context, the CBb stated that it is the responsibility of the Minister and the legislator to shape and implement the necessary structural measures with due care and diligence.

Withdrawal of USO designation

On 5 September, PostNL formally requested the Minister of Economic Affairs to withdraw its designation as USO provider. Submitting this request was a necessary step, but not an easy decision for PostNL. It followed the absence of a short-term solution for the high net costs of the USO, after the subsidy request was rejected by the Minister and the CBb rejected the requested advance payment. Furthermore, despite the important step taken by the Minister to amend the Postal Decree, there remains no prospect of a regulatory framework that sufficiently reflects market developments. This creates an unsustainable situation for PostNL and puts the continuity of postal service provision in the Netherlands at risk. This is irresponsible for people who rely on postal services and for the thousands of people working in the postal sector. It is also unreasonable to expect a commercial company to absorb such losses while carrying out a mandatory public service. On 19 December, the Minister rejected PostNL’s request for withdrawal of the USO designation. PostNL filed an objection to this decision.

Adherence to USO requirements

In 2025, PostNL met the required coverage requirements for the number of postboxes and continued to make adjustments to the nationwide postbox network. For example, in February 2025, PostNL introduced staggered collection from postboxes throughout the day. This approach is more efficient, reduces kilometres driven, is more sustainable and lowers costs, helping to maintain affordable postal services in the Netherlands. This ensures that services remain accessible while contributing to necessary cost savings. In 2025, PostNL also met the legal standards regarding the accessibility of postal locations in the Netherlands.

However, meeting the quality-of-service standard requiring 95% next-day delivery of consumer mail has become infeasible. In 2025, PostNL achieved a next-day delivery performance of 86%, with 95% of mail delivered within two working days. Delivery performance for funeral announcements and medical mail reached 94% in 2025, close to the target of 95%. Taking into account the confidence interval, the quality-of-service performance of funeral announcements and medical mail met the 95% target.

Quality-of-service performance continued to be impacted by the tight labour market, resulting in performance pressure in both delivery operations and sorting centres. Labour shortages remain particularly severe in certain regions due to economic factors, making the recruitment and retention of postal workers difficult and further exacerbating delivery challenges in those areas. Regional information is provided in the table below, where D+1 refers to USO mail delivered within one working day and D+2 refers to USO mail delivered within two working days.

In addition to the tight labour market, quality-of-service performance was also negatively affected by relatively high sick leave rates. The stringent USO requirement to deliver mail next day throughout the Netherlands leaves no operational flexibility to make the delivery model less labour-intensive. These challenges underline the need to transition to a delivery model based on delivery within two days, followed by delivery within three days, which would support more reliable delivery performance.

In 2019, 2020, 2021, 2022, 2023 and 2024, next-day delivery was below the 95% target due to circumstances beyond PostNL’s control, such as the Covid pandemic and a tight labour market. For 2019, PostNL paid a fine imposed by the ACM for not meeting the quality-of-service target. PostNL appealed this decision at the CBb. In December 2025, the CBb ruled that PostNL had not committed a violation. Certain sample letters should have been excluded from the measurement study because it could not be determined whether PostNL was responsible for the delayed delivery. The cause could also have been the sender or recipient. This resulted in an adjusted confidence interval, under which PostNL did meet the 95% standard. The imposed fine was cancelled and repaid in December 2025. The CBb ruling is also relevant for subsequent years. For 2021, 2022, 2023 and 2024, the (re)assessment of facts and circumstances and any decision on the imposition of fines remain with the ACM.

Revision of the EU Postal Service Directive

The European Commission plans to introduce the EU Delivery Act in the fourth quarter of 2026. This legislation is expected to replace the existing Postal Services Directive and the Cross-Border Parcel Regulation. In November 2025, the Commission launched a Call for Evidence to assess whether the market recognises several key challenges, including the sustainability of the USO, recipients’ rights, a level playing field and cross-border parcel delivery. The Call for Evidence outlines policy options ranging from maintaining the status quo to extending regulation to the entire delivery market.

A more detailed public consultation on the future of the EU postal and delivery services framework was launched by the European Commission on 11 December 2025. PostNL is closely monitoring these developments, engaging in stakeholder dialogue and actively preparing for potential implications for postal regulation and possible future legislation on (cross-border) parcel delivery.

CBb's ruling on the Sandd takeover

On 2 December, the CBb ruled that PostNL’s appeal against the ACM’s decision not to grant a permit for the takeover of Sandd was unfounded. The ACM’s decision therefore remains in force. The ruling clarifies the ACM's application of the assessment framework to the situation as it existed six years ago. The merger has been effective since 2019. At that time, PostNL had permission from the Ministry of Economic Affairs to merge. Although that decision was later annulled, there was no unlawful situation at the time of the merger, as the ACM also stated immediately after the ruling in a press release. On 13 February 2026, the ACM announced that it will launch an investigation into PostNL in relation to the Sandd acquisition, following the aforementioned CBb ruling. We do not believe a new investigation contributes to the necessary progress and clarity in a sector that requires stability and forward-looking decision-making for customers and employees.

Other postal developments

PostNL aims to keep mail delivery accessible, reliable and future-proof for everyone. In a shrinking postal market, a level playing field is essential. PostNL considers that Spotta’s delivery of personalised flyer packages qualifies as a postal service and that Spotta should therefore comply with the relevant obligations under postal legislation. The ACM concluded that Spotta is not a postal transport company, as the postal items are not offered by a third party but compiled by Spotta itself, and because Spotta also collects the addresses. PostNL appealed this decision at the CBb after the court followed the ACM’s reasoning.

PostNL also filed an appeal with the Supreme Court regarding the Rotterdam Waste Regulation. This regulation requires customers to include a name, in addition to the address, on Direct Mail sent to addresses in Rotterdam, leading customers to avoid Rotterdam for Direct Mail campaigns. Proceedings before the Supreme Court will continue in 2026.

Reducing physical labour risks

In 2024 and 2025, the Netherlands Labour Inspectorate conducted investigations into physical workload in parcel sorting centres. Following these investigations, the Inspectorate initiated enforcement actions against several major market players including, PostNL.

PostNL has made significant progress in recent years and has accelerated the implementation of measures to reduce physical strain. In the coming years, PostNL will continue to invest in and further develop automation and mechanisation in parcel sorting centres in the Netherlands and Belgium. For more information, refer to the Physical Workload programme paragraph on page in the sustainability statements. The pace of implementation largely depends on developments in automation and mechanisation, which PostNL will support to the full extent possible. The comprehensive action plan combines risk assessment, alignment with health and safety objectives and continuous monitoring to deliver both immediate and long-term improvements. PostNL regularly informed the Inspectorate of progress.

Sustainability

PostNL is committed to reducing the environmental impact of its activities. As government policies at all levels can either support or hinder progress towards sustainability objectives, we maintain regular contact with different public authorities regarding the impact and effectiveness of measures aimed at supporting the green transition. PostNL monitors regulatory developments related to, for example, green fleets, deforestation and packaging, to ensure compliance and implementation.

Cybersecurity

For more information on cybersecurity, refer to the Cybersecurity paragraph on page in the Corporate governance chapter.

Customs and e-commerce measures

In response to increasing volumes of parcels from China, the European Commission plans to introduce an e-commerce handling fee to compensate for rising customs costs. The introduction of a €3 fee per parcel is planned for July 2026. Further details remain subject to clarification. PostNL recognises the importance of ensuring a level playing field, strengthening product safety and modernising customs operations, but effective and workable implementation is essential. Key concerns for PostNL include the collection of fees, the associated operational risks for PostNL as USO provider, the administrative burden for postal operators and the availability of sufficient implementation time.

Prior to the EU-wide announcement, several Member States considered introducing such fees at a national level as early as January 2026, including the Netherlands and Belgium. Both countries have since decided to postpone national implementation. Several other Member States are still considering introduction or have recently implemented a handling fee. For PostNL, it is essential that a level playing field between Member States is maintained through harmonised European-level implementation.

Content index

PostNL is actively involved in key industry associations across the Benelux and Europe to represent our interests and contribute to the development of the sector.

The Netherlands

PostNL is a member VNO-NCW and of Transport en Logistiek Nederland (TLN), enabling us to engage on topics such as mobility, sustainability and labour market developments. PostNL is also a member of DDMA, the Dutch data-driven marketing and sales association, as well as Thuiswinkel.org, the Dutch e-commerce representative organisation. At a local level, PostNL actively participates in The Hague Connected, the network of large employers in The Hague.

Belgium

PostNL is affiliated with Febetra, TLV, UPTR and the Werkgeversorganisatie, four organisations representing the transport and logistics sector, supporting fair competition and innovation. Furthermore, PostNL is board member of the Belgian Courier association (BCA) and a member of the Flanders Chamber of Commerce and Industry (VOKA), the Central Economic Council (CRB), the Belgian e-commerce representative Becom and the Belgian Cycle Logistics Federation (BCLF).

Europe

PostNL participates in PostEurop, the association of European postal operators, where PostNL collaborates on regulatory developments, sustainability initiatives and cross-border delivery solutions. PostNL is also a member of Ecommerce Europe.