Warden Watch

Poland: Digital Platform Work Bill (UC160)

PolandLegislationProposed

Poland’s draft Act on Performing Work via Digital Employment Platforms (project UC160) is a proposed national law implementing Directive (EU) 2024/2831 on platform work. Member States must transpose the directive by 2 December 2026. The draft would apply to digital employment platforms, intermediaries and people who perform work through platforms in Poland. It would require platforms to provide information about automated monitoring and decision-making systems, address these systems in information and consultation processes, and regularly assess their impact. It would also reserve decisions such as contract termination and account suspension to humans, and require explanations and review of automated decisions. It would restrict processing of certain personal data, ban systems that put undue pressure on workers, and protect people who exercise their rights. The source states the draft does not go beyond the directive and proposes fines of PLN 2,000 to PLN 60,000.

Impact

What this means for HR and vendors

HR and recruitment teams

HR and workforce teams at platform-based businesses may need to map the automated monitoring and decision-making systems used to manage platform workers. They may also need to prepare information that can be shared with workers, their representatives and regulators on request. Organizations should ensure that decisions such as contract termination or account suspension are made by a human, and that explanations, written justifications and a review route exist. This increases the importance of consultation processes, impact assessments and health and safety risk reviews. Because the draft is still proposed, teams should track changes before relying on its final wording.

HR technology vendors

The draft places duties on digital employment platforms and intermediaries, not on technology vendors that supply monitoring or decision-making tools. Based on the source summary, providers have no direct legal duties. Indirect commercial and compliance support requests may arise, because platform customers may need system descriptions, explanations of decision logic, inputs for impact assessments, support for human review and data export capability. Providers serving platform customers in Poland may therefore see contractual or procurement requests for this support. The source does not set provider-specific requirements.

Key obligations

What organizations need to do

Practical obligation briefings focused on what the requirement is, who it applies to, when it applies and what teams should consider doing.

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