Return of Registered Mail with Delivery Confirmation? DHL Changes Delivery Procedure

For decades, registered mail with delivery confirmation was considered a reliable way to deliver important documents such as termination notices and invitations to company integration management (BEM) meetings, while simultaneously creating robust evidence of receipt. This remained the case until DHL Group changed its delivery process in 2025, fully digitalizing proof of delivery.

This change had significant consequences: on May 7, 2026, the German Federal Labour Court (BAG) ruled in case 2 AZR 184/25 that registered mail with delivery confirmation no longer provides sufficient evidentiary value regarding proof of delivery.

DHL Introduces a New Delivery Procedure for Registered Mail with Delivery Confirmation

In response to the courts’ concerns about the lack of documentary reliability associated with the current procedure, DHL Group revised its process on July 15, 2026.

An additional documentation step has been added to the delivery process. After scanning the item and depositing it in the recipient’s mailbox, the delivery agent must now confirm digitally—using both a checkbox and a signature on the handheld scanner—that the item has actually been placed in the recipient’s mailbox. Under the original procedure, the postal employee removed the so-called “peel-off label” from the item immediately before depositing it, attached it to the delivery receipt, and confirmed delivery with a signature and date.

Where this procedure was properly followed, the courts generally accepted registered mail with delivery confirmation as establishing a prima facie presumption of receipt.

As digitalization progressed, the delivery process evolved. Since around 2025, documentation has been carried out exclusively in digital form. Delivery personnel scan the item and sign electronically. The time and location of delivery are automatically recorded and stored in the system. This development was intended to improve traceability and strengthen the evidentiary position. However, the letter itself is only deposited into the mailbox after these digital steps have been completed. As a result, several courts questioned whether purely digital documentation is sufficient to establish legally reliable proof of delivery.

BAG Judgment: Why the Presumption of Receipt No Longer Applies

In its May 2026 decision, the BAG found that mere electronic documentation prior to actual delivery does not completely eliminate doubts regarding whether the item was truly deposited in the mailbox. Unlike the former peel-off-label procedure, scanning the barcode can occur while the postal employee is still carrying several items, increasing the risk of delivery errors. Furthermore, delivery is confirmed by the employee before the letter is actually deposited. In addition, the delivery record does not distinguish between a letter being deposited in a mailbox and being handed personally to the recipient.

For these reasons, the BAG refused to grant the new “scanning procedure” the same prima facie evidentiary effect that had previously been recognized for the peel-off-label procedure. The Court particularly criticized the timing of the documentation, since the place and time of delivery are recorded electronically before delivery actually occurs. According to the Court, this may reduce the delivery agent’s attention to the crucial act of depositing the item itself. After completing the scanning procedure, the delivery agent could still be distracted or interrupted. As a result, the key evidentiary element required for a presumption of receipt—the actual act of depositing the item—is missing. Consequently, registered mail with delivery confirmation no longer differs significantly from an ordinary letter in terms of evidentiary value. 

In response to the BAG’s decision, DHL Group has modified its product. After scanning the item, the delivery agent must now provide an additional digital confirmation that the letter has actually been deposited. This confirmation is documented through a signature and an explicit acknowledgment of deposit in the scanner. The additional confirmation step is intended to increase the delivery agent’s attention to the proper completion of the delivery process and improve the traceability of the documented delivery. Whether this will be sufficient remains to be decided by the courts. It is also unclear whether the revised procedure now distinguishes between delivery into a mailbox and personal handover to the recipient. Moreover, scanning the wrong letter may still be more likely than removing the wrong peel-off label under the previous system.

Criticism has already been voiced by legal practitioners and HR professionals. They note that no visible changes appear to have been made to the delivery receipt itself, and that in test deliveries the names of the delivery personnel were reportedly not identifiable. It is currently unknown whether any modifications have been made to the delivery records.

Practical Recommendation for Employers: Continue to Deliver Termination Notices Personally or via Messenger

Even after DHL’s modification of its digital procedure, it remains uncertain whether registered mail with delivery confirmation can once again provide legally reliable proof of service. Termination notices in particular should continue to be delivered personally at the workplace or through a messenger who documents the deposit into the mailbox with a written record and photographic evidence. It is important that the messenger knows the contents of the letter, meaning that the messenger should be present when the document is placed into the envelope. Although this approach involves greater effort, it currently provides the most reliable basis for proving effective service of legally significant documents.