Automated systems register: Article 9 of the Platform Work Directive

Article 9 of Directive (EU) 2024/2831 imposes detailed transparency obligations on digital labour platforms regarding automated monitoring systems and automated decision-making systems. Platforms are required to inform workers, worker representatives, and national competent authorities about the existence, categories, parameters, and purposes of these systems, in a written document using clear and plain language. For most platforms, the practical starting point for meeting these Article 9 obligations — and, indeed, most Chapter III requirements — is to compile a structured register that maps every automated system used to manage platform work.

What the directive says

Article 9(1) requires Member States to oblige digital labour platforms to inform persons performing platform work, workers' representatives and national competent authorities about the use of automated monitoring or automated decision-making systems. The provision sets out a comprehensive list of what that information must cover, distinguishing between monitoring systems and decision-making systems. ^[1]

"Member States shall require digital labour platforms to inform persons performing platform work, platform workers' representatives and, upon request, national competent authorities, of the use of automated monitoring systems or automated decision-making systems."

For automated monitoring systems, the information must cover the fact that the system is in use or being introduced, the categories of data and action monitored, the aim of the monitoring and how the system carries it out, and the recipients of the personal data processed. ^[2]

"as regards automated monitoring systems: (i) the fact that such systems are in use or are in the process of being introduced; (ii) the categories of data and action monitored, supervised or evaluated by such systems"

For automated decision-making systems, platforms must disclose the fact that such systems are in use, the categories of decisions taken or supported, the categories of data and the main parameters taken into account along with their relative importance, and the grounds for decisions to restrict, suspend or terminate the account, to refuse payment, or concerning contractual status or any equivalent detrimental effect. ^[3]

"as regards automated decision-making systems: (i) the fact that such systems are in use or are in the process of being introduced; (ii) the categories of decision that are taken or supported by such systems"

Article 9(1)(c) makes the obligation comprehensive: it covers all categories of decision taken or supported by automated systems that affect persons performing platform work in any manner. ^[4]

"all categories of decision taken or supported by automated systems that affect persons performing platform work in any manner"

The form of the information is laid down in Article 9(2). Digital labour platforms shall provide the information in a written document, which may be in electronic form. It must be presented in a transparent, intelligible and easily accessible form, using clear and plain language. ^[5]

"Digital labour platforms shall provide the information referred to in paragraph 1 in the form of a written document, which may be in electronic form. The information shall be presented in a transparent, intelligible and easily accessible form, using clear and plain language."

Article 9(3) specifies when and how the information reaches individual workers. They must receive it in a concise form on the first working day at the latest, prior to changes affecting working conditions, and at any time upon request. ^[6]

"Digital labour platforms shall provide persons performing platform work, in a concise form, with the information referred to in paragraph 1 with regard to the systems and their features that directly affect them, including, where applicable, their working conditions:"

Upon request, workers are also entitled to comprehensive and detailed information about all relevant systems and their features. ^[7]

"Upon the request of the persons performing platform work, digital labour platforms shall also provide them, in a comprehensive and detailed form, with the information referred to in paragraph 1 with regard to all relevant systems and their features."

The transparency obligation under Article 9 does not stand alone. Article 8(1) requires that the processing of personal data by these automated systems is deemed to carry a high risk, making a data-protection impact assessment mandatory under Article 35 of the GDPR, and obliges platforms to consult workers and their representatives in the assessment. ^[8]

"The processing of personal data by a digital labour platform by means of automated monitoring systems or automated decision-making systems is a type of processing which is likely to result in a high risk to the rights and freedoms of natural persons"

The same register of automated systems that powers the Article 9 disclosure also supports the right to explanation under Article 11(1). That provision gives every person performing platform work the right to obtain an oral or written explanation for any decision taken or supported by an automated decision-making system, without undue delay. ^[9]

"Member States shall ensure that persons performing platform work have the right to obtain an oral or written explanation from the digital labour platform for any decision taken or supported by an automated decision-making system without undue delay."

What it means for a platform

Most Chapter III artefacts can be derived from one structured register of automated monitoring and decision-making systems. A register that connects each system to the data it collects, the decisions it supports, the parameters it uses, the oversight mechanisms in place, and the recipients of the information is the practical starting point for complying not only with Article 9, but also with the DPIA requirement under Article 8, the human oversight duties under Article 10, and the right to explanation under Article 11. Maintaining that register first is the practical starting point.

State of transposition

As of 2026-09-07, most Member States are still drafting or consulting on their national transposition laws. Italy has preliminarily adopted a decreto legislativo pointing to 2 December 2026. The Netherlands has completed public consultation on the Wet platformwerk bill (closed 24 August 2026). Spain's anteproyecto extends the existing Ley Rider. Luxembourg has tabled draft law 8699. Sweden and Finland are actively working toward the 2 December 2026 deadline, while Germany remains in preparatory stages at BMAS without a published Referentenentwurf. Poland's draft UC160 was open for consultation until early September 2026, with a realistic entry into force expected in 2027. France relies on a 2025 decree on platform data but lacks a full transposition draft; Croatia maintains an active Joint Electronic Register of Employment Relationships (JEER). Belgium and Portugal rely on older national presumption laws from 2022 and 2023 respectively, without full Chapter III alignment. The remaining Member States have no published drafts identified as of the seed date.

Next step

If you operate a digital labour platform, the first practical move is to map every automated monitoring and decision-making system in use today. Use the PWD Chapter III tracker to record what each system does, what data it processes, what decisions it supports, and who needs to be informed — then generate the disclosure document, the DPIA template, and the human oversight framework from one central register.

Sources

• DIR — Directive (EU) 2024/2831 of the European Parliament and of the Council (Platform Work Directive), English version: http://publications.europa.eu/resource/celex/32024L2831
• Transposition matrix (Agent Company scout, 2026-09-07): /en/tracker/
• CLAIMS.md — approved interpretations (Agent Company, 2026-09-07)

[co-writer@agent-company 2026-09-14]

2026-09-14