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Delivery Hero SE

Delivery Hero SE aims to engage with European policy-makers and other stakeholders in debates surrounding the regulation of the digital services sector, the future of work, sustainable last-mile transport and logistics, the future of delivery, and the creation of European Tech champions, among other topics.

Lobbying Activity

Meeting with Egelyn Braun (Cabinet of Commissioner Michael McGrath)

28 Jan 2026 · Exchange of views on the forthcoming Digital Fairness Act

Meeting with Henna Virkkunen (Executive Vice-President) and

12 Jan 2026 · Discussion on Delivery Hero’s activities and challenges, as well as their position on the EU’s digital and competitiveness agenda

Meeting with Wojciech Saryusz-Wolski (Head of Unit (Ad interim) Communications Networks, Content and Technology) and Uber and

2 Oct 2025 · Exchange of views on the upcoming Digital Omnibus Package, with an emphasis on simplification and harmonisation of digital legislation.

Meeting with Sergey Lagodinsky (Member of the European Parliament)

23 May 2025 · Exchange of view

Meeting with Chiara Riondino (Head of Unit Employment, Social Affairs and Inclusion) and Bolt and

20 Feb 2025 · Information exchange on the Platform Work Directive

Meeting with Sergey Lagodinsky (Member of the European Parliament) and Transparency International Liaison Office to the European Union

2 Oct 2024 · Exchange of views Start of the new mandate

Meeting with Christian Ehler (Member of the European Parliament)

1 Oct 2024 · Industriepolitik allgemein

Meeting with Svenja Hahn (Member of the European Parliament)

15 May 2024 · Exchange on Tech-Scale ups in Europe

Meeting with Didier Reynders (Commissioner) and

6 Mar 2024 · GDPR, consumers

Meeting with Thierry Breton (Commissioner) and

6 Mar 2024 · Platform regulation

Meeting with Malte Gallée (Member of the European Parliament) and HelloFresh SE

29 Mar 2023 · Green Claims

Response to VAT in the Digital Age

4 May 2022

Delivery Hero welcomes the opportunity to contribute to this European Commission consultation on the “VAT in the digital age” legislative package aiming to bring the EU VAT legislation up-to-date, while fostering a more uniform application of rules across the Member States and preventing fraud. We also welcome the fact that the European Commission is taking action to address the specific challenges faced by the platform economy when it comes to the application of VAT rules. However, we underscore the need for a tailored approach that takes into account the characteristics of different digital platforms and business models for a new EU VAT framework that is truly fit for purpose. As one of the world’s leading local delivery companies present in around 50 countries across four continents, Delivery Hero works with a large ecosystem of couriers (“riders”), restaurants, local shops and partners, with the aim to deliver anything a customer orders from our applications. Riders are at the heart of our business, and the majority of the riders we work with are self-employed individuals, who operate under service agreements with local delivery platforms and issue their own invoices for the delivery services performed, just as any other supplier or service provider. It is crucial to ensure that mandatory e-invoicing requirements introduced at the European level do not pose a disproportionate burden on these self-employed individuals, who, as one person companies, are responsible for performing all administrative duties resulting from the contract, in addition to providing the necessary services. As such, complex e-invoicing requirements could hamper individual entrepreneurs’ ability to carry out their work, result in additional costs, and deter them from venturing into new areas of business. One way to address this and make compliance easy without additional administrative burden could be setting simplified e-invoicing requirements for the self-employed (freelancers) and other Small- and Medium-Sized Enterprises (SMEs). Beyond this fundamental aspect, we expect only limited impact on our operations resulting from this initiative as it primarily aims to achieve a more uniform approach in the application and control of VAT rules in relation to cross-border sales of goods and services; whereas the vast majority of the transactions on our platforms inherently do not have a cross-border dimension and are confined within the national borders of the countries that our brands operate in. Nevertheless, we would like to highlight potential inadvertent consequences of the national implementation of anti-fraud measures designed to prevent fraud in connection with cross-border digital platform businesses. While we strongly support such measures, it must be ensured that platforms with a limited/domestic scope -and thus, substantially limited fraud potential- are not subjected to undue burden at the national level through additional Digital Reporting Requirements intended to target cross-border supplies. This could be achieved through a targeted compliance system with tailored reporting requirements, as opposed to all-encompassing filing requirements that fail to take heed of industry specificities. Delivery Hero looks forward to an updated framework that simplifies compliance and brings the EU VAT rules into the 21st century, while safeguarding the rights of self-employed individuals who play an indispensable role in today’s digital economy.
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Meeting with Elisabetta Gualmini (Member of the European Parliament, Rapporteur) and BUSINESSEUROPE and

29 Mar 2022 · Roundtable on platform work directive

Meeting with Filomena Chirico (Cabinet of Commissioner Thierry Breton)

14 Dec 2021 · Platforms regulation and platforms workers’ proposal

Meeting with Nicolas Schmit (Commissioner) and

20 Sept 2021 · Consultation hearing with digital labour platforms on the Initiative on improving working conditions in platform work. (to be completed)

Meeting with Ana Carla Pereira (Cabinet of Commissioner Nicolas Schmit) and Bolt and

17 Mar 2021 · Regulation of digital platforms and platform work in the EU

Response to Collective bargaining agreements for self-employed – scope of application EU competition rules

3 Feb 2021

Delivery Hero SE is a European local-delivery company headquartered in Berlin (Germany) operating food delivery services in around 50 countries across Asia, Europe, Latin America, the Middle East and North Africa. Our group employs more than 27,000 employees globally with the European Union being our home. We operate in 10 EU countries, under 8 different brands. Across the EU Member States, our subsidiaries operate the logistics of the food delivery through a sizable fleet of passionate and mostly self-employed couriers. We welcome the opportunity to provide feedback on the European Commission´s (“EC”) initiative that address collective bargaining rights for ‘solo self-employed providing their own labour through digital labour platforms’. With the attached document, we aim to provide Delivery Hero´s views regarding CBA for self-employed workers. - The EC needs to provide further clarity on the repercussions this initiative may have on EU and national competition laws From a competition law perspective this initiative raises a lot of critical questions which we urge the EC to address since they are at the heart of the subject and more than a legal technicality. The EC will also have to clarify to what extent this initiative will have a binding effect (or not) for the EU Member States. - Self-employed platform workers benefit from a highly competitive market Food delivery platforms are not “digital labour platforms”. They are marketplaces which connect restaurants and retail partners with consumers to facilitate the transaction of prepared meals and other daily goods. Self-employed riders neither offer nor provide their labour through our platforms. Rather, self-employed riders provide their services to our subsidiaries directly, and our subsidiaries use these services to operate the delivery logistics for restaurants and retailers. This distinction is fundamental to understand. Unlike “solo-self employed” in the “traditional economy” and in other types of online or on-location platform work, self-employed riders do not compete against one another for an opportunity to work with us and, thus, their earnings and working conditions are not exposed to the lowering effect of market competition or the abuse of controlling high-profit agencies. Quite the opposite, food delivery is a highly competitive industry with very low profit margins. The competition among food delivery companies to attract self-employed riders already results in self-regulation and constant improvement of work conditions of self-employed riders. Multi-homing is a common phenomenon in the food delivery industry. - Marketplace versus Own-delivery When thinking about collective bargaining for self-employed in the food delivery sector, the existence of two very different operational models needs to be taken into account: 1.) The Marketplace model refers to platforms that solely connect consumers with partners such as restaurants and retailers. In this case, the partners take care of the logistics, usually by building up their own “microfleet” of self-empoyed couriers. 2.) The Own-delivery model (also Generation Two model) is operated by platforms which run logistics themselves by building up sizeable delivery fleets of couriers to enable restaurants and retailers to focus on their core business and thereby offering a seamless experience for customers, restaurants and couriers alike. The EC should note that mere marketplace operators source out logistics to restaurants. This group of self-employed couriers, who are in service agreements with individual restaurants instead of platforms must be part of the scope of a potential regulation in order to ensure a level-playing-field among competing platforms in the food delivery industry. Marketplace platforms should not be rewarded with a competitive advantage for sourcing out logistics operations and hence, for avoiding responsibility for the wellbeing of self-employed couriers.
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Meeting with Werner Stengg (Cabinet of Executive Vice-President Margrethe Vestager) and Bolt and

18 Jan 2021 · Statement of Principles of EU technology platforms, DSA