In March 2023, France's highest administrative court was asked what a Paris shop becomes when the shutters stay down, the customers stay out, and the couriers wait on the sidewalk. Its answer: a warehouse. The Conseil d'État ruled that dark stores are "warehouses under the meaning of the French Town Planning Code and the local town planning scheme of Paris," which meant turning a shop into one needed the city's permission.
That ruling settled one question: where a dark store is allowed to sit. A second question, who delivers the orders and on what terms, gets its own deadline on December 2, 2026, when EU member states must have the Platform Work Directive in national law. Between them, zoning rulings and labor law now make up most of dark store regulation in Europe, and grocers running rapid delivery plan around both.
This article is general information, not legal advice. It reflects the status of the rules as of October 2026.
What counts as a dark store in law?
A dark store is a site laid out like a shop but closed to the public, used only to pick and dispatch online orders. Most European law doesn't use the term. It decides which existing category the site falls into, and that category decides where it can open.
France made the category explicit. A decree and an order published in March 2023 rewrote the planning code's definition of a warehouse. As summarized by Gossement Avocats, it now covers buildings used for logistics or storage "without a sales area," including "permanent delivery points" for retail orders placed online. In plain terms: if customers can't walk in and the site exists to fulfill online orders, the law treats it as a warehouse.
What did France change, and when?
Two things happened within days of each other. The Conseil d'État decision of March 23, 2023, confirmed that converting a shop into a dark store is a change of use, so the city can refuse it. The decree that followed wrote that reading into national rules, with the new definitions taking effect on July 1, 2023.
The practical effect for operators is about location. A warehouse can usually open in a logistics or industrial zone without much argument. In a dense residential neighborhood, where most quick-commerce sites wanted to be, it needs the city's approval, and Paris made clear it would use that power.
How does Amsterdam regulate dark stores?
Amsterdam took the zoning route. Under the city's zoning plan, rapid-delivery dark stores may operate only on business estates and no longer in residential areas, with an exception for zones that mix housing and commerce. The Netherlands' highest administrative court, the Raad van State, upheld the plan, as Binnenlands Bestuur reported in June 2025.
The pattern in Paris and Amsterdam is the same. Cities decide where online grocery fulfillment can happen, and they push it toward sites zoned for logistics.
What does the EU Platform Work Directive require, and by when?
Directive (EU) 2024/2831 on improving working conditions in platform work sets out three main changes.
A presumption of employment. Where a digital labor platform controls or directs the work, the person doing it is presumed to be an employee. The platform carries the burden of proving otherwise.
Rules on algorithmic management. Platforms have to tell workers how automated systems monitor them and make decisions about them, and significant decisions, such as suspending an account, need human review.
Limits on data. Platforms can't process certain personal data, such as private conversations or data collected while the person is off duty.
The Council of the EU adopted the directive on October 14, 2024, saying it would improve conditions for "more than 28 million people" working through digital labor platforms. Member states must transpose it by December 2, 2026.
Where do national laws stand?
Unevenly, and the detail will differ from country to country. A few examples as of October 2026:
The Netherlands published a draft Platform Work Act on June 29, 2026, with a public consultation that ran until August 24, 2026. According to Global Workplace Insider, the draft presumes employment where a platform "exercises a certain degree of control or direction over the work," and requires human oversight for decisions such as account suspension.
Germany's government has confirmed it is drafting the transposing law, according to DLA Piper.
Greece is preparing legislation built around the reversed burden of proof, so the platform must show a worker is genuinely independent, Remote Work Europe reports.
The obligations that bind operators will sit in the national versions. The directive sets the floor, and each country decides what facts trigger the presumption and how it is enforced.
What about the UK?
The UK is outside the directive and moving on its own timetable. The Employment Rights Act 2025 received Royal Assent on December 18, 2025. It strengthens a range of rights, including protections for people on zero-hours and other "one-sided flexibility" arrangements, phased in through 2027.
It does not create a single worker status or reclassify platform couriers. The government has said it will consult on employment status separately, and MPs were still debating a single status of worker in April 2026. For now, courier status in the UK still rests on existing law and the courts.
What should grocers plan for in 2027?
The rules point in one direction, so the planning questions are fairly concrete.
Where your fulfillment nodes sit. A site zoned for logistics is easier to open, keep, and expand than a converted shop on a residential street. That favors fulfillment centers and micro-fulfillment sites planned into logistics or mixed-use zones from the start.
How your couriers are engaged. If delivery runs through a platform model, the presumption of employment changes the cost and the risk in every EU country that transposes it. Grocers that use their own drivers, or partners that employ theirs, have less to restructure.
How your dispatch software makes decisions. The directive's rules on algorithmic management apply to digital labor platforms, and national laws will define who counts. Either way, a dispatch system that can explain how it assigns work, and lets a person override it, is easier to defend.
When to check again. National laws will arrive at different times in late 2026 and 2027. Anyone running delivery in several EU countries should track each one rather than plan from the directive text alone.
Questions grocers ask about dark store regulation
Are dark stores banned in Europe?
No. There is no EU-wide ban. Some cities restrict where they can open, for example Paris through its warehouse classification and Amsterdam through zoning.
Does the Platform Work Directive apply to grocery delivery couriers?
It applies to people working through digital labor platforms. Whether a particular delivery model counts depends on each country's transposing law, so check the national version.
What happens on December 2, 2026?
It is the deadline for EU member states to transpose the directive. National laws then apply, and several are still in draft as of October 2026.
Does the UK Employment Rights Act make gig couriers employees?
No. It strengthens several worker rights, but reform of employment status is still at the consultation stage.
Fulfillment where the rules expect it
Read together, the zoning decisions and the platform rules describe the same kind of operation: fulfillment in sites zoned for logistics, delivery run by people whose terms are clear, and dispatch software a person can understand and override.
Veloq's platform is built for that kind of operation. It runs Rohlik Group's dedicated fulfillment centers and the last-mile software that plans every route, with dispatch rules operators can see and adjust. France settled what a dark store is in a single ruling. Grocers planning their 2027 networks can settle where theirs go before a city does it for them. See how Veloq plans fulfillment and delivery.
Sources
- Conseil d'État, "The conversions of shops into dark stores must be authorised by the City of Paris" (March 23, 2023)
- Gossement Avocats, summary of Decree No. 2023-195 and the order of March 22, 2023 (in French)
- Binnenlands Bestuur, "Amsterdam mag darkstores weren in groot deel van de stad" (June 25, 2025, in Dutch)
- EUR-Lex, Directive (EU) 2024/2831 on improving working conditions in platform work
- Council of the EU, "Platform workers: Council adopts new rules to improve their working conditions" (October 14, 2024)
- Global Workplace Insider, "The Platform Work Act: Implementing the EU Platform Work Directive in the Netherlands" (September 2026)
- DLA Piper, "Germany moves forward on transposing the EU Platform Work Directive" (2026)
- Remote Work Europe, "Greece moves to transpose the EU platform work directive" (2026)
- UK Parliament, Employment Rights Act 2025
- Hansard, "Single Status of Worker" (April 15, 2026)
