Exploring the Unforeseen Challenges Arising from the Surge in Final Mile Delivery Services
The European Trade Union Institute (ETUI) has highlighted subcontracting as a predominant business model in the logistics sector, with concerns about its impact on working conditions and workplace safety. According to a recent ETUI report, subcontracting worsens working conditions and increases workplace accidents [1]. This is due to the fragmentation of the workforce, job instability, and the volatility of subcontractors, which make it difficult for trade unions to reach and represent logistics workers [2].
High staff turnover, caused by poor working conditions, further complicates the efforts of trade unions to protect logistics workers. Subcontractors often offer lower wages, apply inferior or no collective agreements, and demand longer work shifts [2]. Additionally, the corporate veil prevents clients from being held liable for violations of workers' rights or other breaches committed by main contractors or subcontractors [3].
Several European and national trade unions, including the European Transport Workers' Federation (ETF), the European Federation of Food, Agriculture and Tourism Trade Unions (EFFAT), the European Federation of Building and Woodworkers (EFBWW), and the European Trade Union Confederation (ETUC), have called for stricter limits on both what can be subcontracted and the length of subcontracting chains [2].
In response to these concerns, the European Union has taken steps to address subcontracting in the logistics and e-commerce sectors. The EU Digital Operational Resilience Act (DORA) and its associated Regulatory Technical Standards (RTS) adopted in 2025 primarily target financial entities and ICT service providers, but their approach to subcontracting includes critical new rules that set a precedent for managing subcontracting risks and monitoring subcontracting chains in digital and critical service contexts [4].
As of July 2025, the RTS under DORA (Delegated Regulation (EU) 2025/532) establishes detailed requirements for financial entities when subcontracting ICT services supporting critical or important functions [1][2][4]. These include mandatory risk assessments during the precontractual phase, due diligence processes, and ongoing monitoring of subcontractors to ensure transparency and operational resilience throughout the subcontracting chain.
While these regulations are specific to the financial and ICT sectors, the principles of transparency, risk assessment, and contractual clarity they promote are increasingly viewed as best practices to combat worker exploitation and improve working conditions in broader sectors such as logistics and e-commerce, which often involve complex subcontracting chains.
Currently, there are no direct EU regulations published explicitly targeting worker exploitation through subcontracting in logistics and e-commerce sectors. However, the general trend in EU policy, reflected in the scrutiny and formalization of subcontracting arrangements under DORA, signals an intent to extend rigorous regulatory frameworks to ensure subcontracted workers do not face exploitation and enjoy improved conditions.
In the logistics sector, issues such as the use of algorithmic management systems, the existence of letterbox companies, and the lack of tachographs in last-mile delivery vehicles, compound the challenges of unionising a workforce already weakened by precarious employment and the extensive use of migrant labor. Despite these obstacles, the EU reforms serve as a potential model and regulatory foundation for future expansions to cover logistics and e-commerce sectors for worker protection.
References: [1] ETUI (2022). Subcontracting in the logistics sector: A review of four-country case studies. [2] European Trade Union Confederation (2022). Joint statement on subcontracting in the logistics sector. [3] European Commission (2021). Corporate Veil: A Challenge to Workers' Rights and Social Protection. [4] European Parliament and Council (2025). Regulation (EU) 2025/532 on the delegated acts supplementing Regulation (EU) 2025/531 on the digital operational resilience of the financial sector.
The European Trade Union Confederation (ETUC) and other trade unions, such as the European Transport Workers' Federation (ETF), the European Federation of Food, Agriculture and Tourism Trade Unions (EFFAT), the European Federation of Building and Woodworkers (EFBWW), and the European Trade Union Confederation (ETUC), have called for stricter regulations to address worker exploitation and improve conditions in the logistics sector, where subcontracting often leads to poor conditions [2].
The European Union's Digital Operational Resilience Act (DORA) and its associated Regulatory Technical Standards (RTS) have introduced regulations to manage subcontracting risks and promote transparency in the financial and ICT sectors. These principles, though specific to certain industries, are seen as best practices to combat worker exploitation and enhance working conditions in broader sectors like logistics and e-commerce [4].
