Platform Work: Who Is a Platform and What Obligations and Rights the New Rules Bring

The Platform Work Act is the Czech transposition of Directive (EU) 2024/2831 on improving working conditions in platform work. It applies to apps and websites that use algorithms to organise people's paid work – typically food delivery, ride-hailing or small online tasks. The government bill (Chamber of Deputies print no. 301) introduces a presumption of an employment relationship, bans on processing sensitive data, mandatory human oversight of algorithms and workers' right to an explanation and review of decisions. The proposed effective date is 1 January 2027.

• Legal basis: Directive (EU) 2024/2831 of 23 October 2024, in force since 1 December 2024; transposition deadline 2 December 2026.
• Czech legislation: government bill on platform work, Chamber of Deputies print no. 301, submitted to the Chamber on 8 September 2026; proposed effective date 1 January 2027.
• Who it covers: platforms such as Uber, Bolt, Wolt or Glovo and everyone working through them – employees and the self-employed alike.
• Who it does not cover: services for sharing assets or selling goods between individuals, such as Airbnb, Vinted, eBay or BlaBlaCar.
• Key changes: a rebuttable presumption of an employment relationship, bans on processing sensitive data, a mandatory data protection impact assessment (DPIA), human oversight of algorithms, the right to an explanation and review of decisions within 15 days, and registration of platforms.
• Enforcement: the Office for Personal Data Protection and the labour inspectorate; fines of up to CZK 3 million, and for personal data up to EUR 20 million or 4% of turnover.

The EU is regulating platform work because many people working through apps are formally self-employed but in practice are managed much like employees – except that an algorithm takes the place of the manager. According to the Council of the EU, more than 28 million people worked through digital labour platforms in 2022, and around 500 such platforms operate in the Union. Article 1 of the Directive therefore sets three objectives:

• to facilitate the correct determination of employment status – distinguishing the genuinely self-employed from people who in fact perform dependent work,
• to ensure transparency, fairness and human oversight in the algorithmic management of work,
• to make platform work transparent for public authorities, including in cross-border situations.

The recitals of the Directive point out that algorithms are taking over the role of managers – they allocate tasks, set prices, evaluate work and impose sanctions – while workers often do not know on what basis the system decides about them.

Status in the Czech Republic: The government submitted the Platform Work Bill to the Chamber of Deputies on 8 September 2026 as print no. 301, with a proposed effective date of 1 January 2027. The overview below is based on this government bill and its explanatory memorandum; it is a draft act whose wording may still change in Parliament. The change to the definition of dependent work in the Labour Code, to which the bill refers, is contained in a separate amending act.

A digital labour platform is a service that organises people's paid work through a website or app and uses automated systems to do so. Under Section 2(1) of the draft act (in line with Article 2 of the Directive), all four criteria must be met at the same time:

1. the service is provided, at least in part, at a distance by electronic means, such as a website or a mobile application,
2. it is provided at the request of the recipient of the service,
3. it involves, as a necessary and essential component, the organisation of work performed by individuals in return for payment, whether online or in a certain location,
4. it involves the use of automated monitoring or decision-making systems.

The act is to apply to platforms organising work performed in the Czech Republic regardless of where they are established or which law governs the contract (Section 1(2)).

Examples of platforms: The explanatory memorandum names Uber, Bolt, Wolt and Glovo. The Council of the EU lists typical activities such as delivery services, taxi services, translation, data entry, childcare and elderly care. The recitals of the Directive also expressly mention crowdwork – platforms that give businesses access to a large pool of people for small online tasks, such as data labelling.

The act does not cover services that merely connect people without organising their work. Under Section 2(2) of the draft, a platform does not include a service whose primary purpose is to exploit or share assets, or the sale of goods by individuals outside their business activities. The explanatory memorandum illustrates these peer-to-peer services with the examples of Airbnb, Vinted, eBay and BlaBlaCar.

The recitals of the Directive further indicate that the following are not platforms:

• portals that merely advertise offers or display available service providers in an area without any further involvement,
• services organising the activities of volunteers,
• services for which the organisation of work is only a minor and purely ancillary component,
• traditional arrangements such as taxi dispatch without automated systems – according to the explanatory memorandum, transport companies will not meet the definition either.

• A platform worker (Section 4) is any individual performing platform work – including the self-employed.
• A platform employee (Section 5) is a platform worker in an employment relationship or on an agreement to perform work with the platform or an intermediary.
• An intermediary (Section 6) is a person who has a contract with both the platform and the worker, or who sits in the contractual chain between them (typically so-called fleets of couriers or drivers). Obligations towards such a worker are borne by both the platform and the intermediary (Section 7).

The distinction matters, but the rules on algorithms and personal data protection apply to all platform workers, not only to employees.

Presumption of an employment relationship (Sections 9 to 11)

A platform worker is presumed to be in a basic employment relationship if the facts indicate (it does not yet have to be proven) that the hallmarks of dependent work under Section 2(1) of the Labour Code are met. The platform or intermediary can rebut the presumption by proving that at least one hallmark is not met – the burden of proof therefore lies with the platform. The presumption applies in administrative, tax and court proceedings and during inspections, but not in criminal proceedings or social security matters. A worker may file a complaint with the labour inspectorate, which will ask the platform for a statement and, if the platform does not credibly explain that there is no employment relationship, will carry out an inspection.

Platforms will mainly have to limit the collection of sensitive data, assess the risks of their systems in advance, explain how their algorithms work and ensure genuine human control over them. Specifically:

• Ban on processing certain data (Section 12): a platform may not use automated systems to process data on a worker's emotional or psychological state or data from their communications with colleagues, collect data while the worker is neither offering nor performing work, predict the exercise of fundamental rights, infer sensitive characteristics (e.g. ethnic origin, health, political opinions, trade union membership) or use “one-to-many” biometric identification. The ban applies from the recruitment stage.
• Data protection impact assessment – DPIA (Section 13), mandatory before automated systems are deployed, with input from workers and employee representatives – see the detailed section below.
• Information on systems (Sections 15 to 18): what the systems monitor, what decisions they take, on the basis of which main parameters, and for what reasons they may restrict or terminate an account. Concise information no later than the first working day and before any substantial change; detailed information on request within 30 days.
• Information and consultation of employee representatives on the introduction of, or substantial changes to, the systems (Section 19).
• Human oversight (Section 20): a designated person with the authority to overturn the system's decisions, an impact assessment at least every two years, and corrective action where a risk of discrimination is identified. One key rule applies – any decision to restrict or terminate the cooperation or to suspend an account (or a decision of similar gravity) must be taken by a human!
• Registration and information for the state (Sections 22 and 23): registration in the employer register within the single monthly employer report, and disclosure of the number of workers, the general terms and conditions and the list of intermediaries, updated at least every six months. Platforms already operating must do so by 31 January 2027.
• Communication channel (Section 24) through which workers can contact each other and employee representatives; the platform must not have access to it.
• Contact person in the Czech Republic (Section 30) for platforms without a registered office or branch in the country.

Mandatory data protection impact assessment (DPIA)

A platform that processes workers' personal data through automated systems must always carry out a data protection impact assessment (DPIA). Article 8 of the Directive expressly states that such processing is likely to result in a high risk to the rights and freedoms of natural persons within the meaning of Article 35(1) GDPR – so a platform cannot conclude that it does not need a DPIA. Under Section 13 of the draft act:

• The DPIA is carried out in advance – before personal data processing through automated systems begins; the obligation lies with the controller.
• Consultation with workers: where the platform is the controller, it must seek the views of platform workers and employee representatives (a trade union, works council or health and safety representative), if any.
• Sharing the result: the platform must provide the completed assessment to employee representatives.
• Content: the assessment should also cover whether the systems comply with the processing bans under Section 12 (Articles 7 and 8 of the Directive).
• Sanctions: failure to carry out a DPIA, to seek the required views or to provide the assessment to employee representatives is an offence for which the Office for Personal Data Protection may impose a fine of up to EUR 20 million or 4% of total worldwide annual turnover (Section 33).

Compared with the general GDPR rules, a DPIA is therefore mandatory for platforms without any further risk assessment, and it also requires the involvement of the workers themselves and their representatives.

Compliance is to be supervised by the Office for Personal Data Protection (data) and the labour inspectorate (other obligations). Fines for individual offences reach up to CZK 3 million; for breaches of the personal data rules, the GDPR framework applies – up to EUR 20 million or 4% of worldwide turnover.

Above all, platform workers will gain the right to know why an algorithm decided about them and to obtain a human review. Specifically:

• Right to an explanation of any decision taken or supported by an automated system, within 15 days at the latest (Section 21(1)), and the possibility to discuss it with a designated contact person.
• Written reasons for key decisions – restriction or termination of an account, refusal to pay for work performed, decisions on contractual status – no later than the day on which the decision takes effect.
• Right to a review of the decision, with the outcome within 15 days; if the decision infringed the worker's rights, the platform must rectify it or compensate for the damage and adjust the system (Section 21(6) and (7)).
• Data portability, including ratings and reviews, for example to another platform (Section 14).
• Option to report unlawful conduct, including harassment, through the platform's internal whistleblowing system (Section 25).
• Protection against retaliation for exercising their rights; a worker whose cooperation has been terminated may request written reasons (Section 26).
• Complaint to the labour inspectorate to assess whether the work is in fact dependent work (Section 11).

Under the draft, the rights to an explanation and review do not apply to workers who are also business users of online intermediation services within the meaning of Regulation (EU) 2019/1150 – that Regulation applies to them instead.