The German coalition government, comprised of the Christian Democratic Union (CDU) and the Social Democratic Party (SPD), is poised to significantly broaden its legislative efforts to combat black market labor, drawing increasing scrutiny onto the burgeoning food delivery sector. A revised draft law, slated for parliamentary approval this Thursday, expands the list of industries considered particularly vulnerable to undeclared work to include platform-based delivery services and associated subcontractors.
Previously targeting barbershops and cosmetic studios, the amended legislation now explicitly aims to regulate companies organizing deliveries, including those specializing in prepared foods like pizza. This broadening of scope directly impacts the rapidly expanding market dominated by digital platforms, a sector often criticized for its ambiguous employment practices and potential exploitation of workers.
The inclusion of these delivery services triggers a cascade of new obligations. Employees will be required to carry and present identification, while platform operators and their subcontractors face stringent “immediate notification” requirements for new hires. Failure to comply carries the threat of substantial fines, a measure proponents claim will deter illegal labor practices and levelling an uneven playing field.
Anja Karliczek, CDU’s rapporteur on the finance committee, defended the move to the “Rheinische Post” arguing it represents a “effective contribution” to eradicating black market employment and safeguarding small and medium-sized enterprises from unfair competition resulting from “illegal dumping.
However, the legislation faces potential political and ethical challenges. Critics contend the expanded regulations place an undue burden on both delivery workers and platform companies, particularly smaller, independent establishments. Concerns are also being raised about the practicality and potential for overreach in enforcing the immediate notification requirements and potential for worker identification to be exploited. The focus on platform-based services raises fundamental questions about the future of worker classification and the responsibilities of digital intermediaries in ensuring labor law compliance. The effectiveness of the measures and whether they truly address the root causes of black market labor, remain open to debate.



