A courier opens the app before a shift and discovers that the account has been deactivated. The notice does not say whether the trigger was a customer complaint, a low rating, a cancellation, a location anomaly or an automated fraud flag. When access to the platform is the person's main source of income, “account suspended” is not a routine technical message. In practice, it may stop work immediately or end the contractual relationship.

Directive (EU) 2024/2831 creates a dedicated framework for transparency, human oversight and review in platform work. The timing matters in Greece. On 31 August 2026, the official sources checked did not identify a published Greek transposition law, while the transposition deadline is 2 December 2026. This article therefore explains what national law must deliver under the Directive and which existing legal routes may already be relevant. It does not claim that the Directive already imposes a direct, general ban on algorithmic dismissal by every private platform in Greece.

1. Why deactivation is more than a technical incident

Digital labour platforms may use systems to allocate orders, calculate pay, record acceptance and cancellation rates, assess routes, detect anomalies and rank performance. A final measure may be fully automated or may follow a recommendation that a person approves. For the affected worker, that design distinction offers little comfort when access to work and income disappears without a usable explanation.

The first question is not whether the platform markets the system as artificial intelligence. The relevant issue is whether an automated monitoring or decision-making system influenced task allocation, payment, ranking, account status or another essential term. A rules engine, risk score or fraud filter can be legally significant even if no one calls it AI.

2. The legal position in Greece on 31 August 2026

The Directive has entered into force at EU level, but it requires Member States to transpose its rules. The deadline is 2 December 2026. The EUR-Lex register of national transposition measures reviewed on 31 August 2026 did not show a published Greek measure. It would therefore be inaccurate to tell a Greek courier that the Directive itself already and directly prohibits a private platform from using an algorithm in a termination decision.

That caution does not mean there are no present rights. Depending on the facts, Greek labour and contract law, non-discrimination rules, the GDPR, or specific EU regimes for business users and online intermediaries may apply. These routes have different tests and remedies. A sound assessment starts with the actual working relationship, the data processing involved and the nature of the measure, rather than selecting a convenient label.

3. Employee, contractor or nominally self-employed platform worker?

The Directive distinguishes a “platform worker”, whose employment relationship is recognised under applicable law, from the broader category of a “person performing platform work”. The latter may be described in a contract as self-employed. Correct status is determined primarily by the facts of how the work is performed: who sets essential conditions, how control is exercised, whether entrepreneurial autonomy is genuine and how algorithmic management organises the service.

The algorithmic-management chapter is deliberately broader than ordinary employee protection. Core safeguards on personal data, transparency and human review extend to persons performing platform work even where no employment relationship has yet been recognised. This does not give every contractor every employment right. Health and safety, information and consultation duties that are specific to workers have their own scope.

4. What a person should be told about the systems assessing them

Article 9 requires information about automated monitoring and automated decision-making systems. It covers the categories of data or actions monitored, the purpose of monitoring, the categories of decisions taken or supported, the main parameters considered and the grounds used for decisions that restrict, suspend or terminate an account, refuse payment, or affect contractual status.

This does not mean unrestricted disclosure of source code or trade secrets. It does require information that is transparent, intelligible and useful. “Policy violation” without an event, date, rule or factual basis is unlikely to let the affected person understand or challenge the result. A meaningful explanation should identify the decision path without exposing unrelated personal data or protected technical detail.

5. Restriction, suspension or termination requires a human decision

Article 10(5) states the rule Member States must ensure: any decision to restrict, suspend or terminate the contractual relationship or account of a person performing platform work, and any decision of equivalent detriment, must be taken by a human being. This is a human decision, not a ceremonial click that leaves an algorithmic recommendation untouched.

Human oversight must be effective. The people assigned to it need competence, training and authority to override an automated result. Platforms must allocate sufficient human resources and regularly assess the impact of individual decisions. If oversight reveals a high risk of discrimination or an infringement of rights, the platform must take corrective steps, potentially modifying or discontinuing the system.

6. Written reasons and access to a qualified human contact

Article 11 provides a right to an oral or written explanation, without undue delay, for decisions taken or supported by an automated decision-making system. The platform must provide access to a designated contact person who can discuss and clarify the facts, circumstances and reasons that led to the decision. That person must be able to do more than repeat a standard script.

For a decision restricting, suspending or terminating an account, refusing payment, changing contractual status or affecting another essential aspect of the relationship, written reasons must be provided no later than the date the decision takes effect. Useful reasons identify the alleged conduct, relevant data, applicable rule and available review route. They need not reveal every technical security signal, but must allow a real response.

7. Review and a reasoned reply within two weeks

If the explanation is unsatisfactory or the person believes that rights were infringed, the significant decision may be submitted for review. Under the framework the Directive requires, the platform must provide a sufficiently precise and adequately substantiated written reply without undue delay and in any event within two weeks of receiving the request.

If the decision infringed the person's rights, it must be rectified without delay and, under Article 11, no later than two weeks after the decision was adopted. If correction is impossible, the platform must offer adequate compensation for the damage and take steps to prevent recurrence. The Directive does not replace national disciplinary or dismissal procedures and does not predetermine compensation in an individual case.

8. Evidence to preserve before access disappears

The practical priority is lawful preservation. Keep the complete suspension notice with date and time, emails, in-app notifications, the terms that applied, shift and order history, payment records, ratings, cancellations, support tickets and replies. A chronological file is usually more useful than one cropped screenshot. Record which device and account produced each export.

Preserve originals where possible. Do not alter dates, content or metadata, and do not create “cleaned” screenshots that conceal context. Keep a separate log describing when each item was obtained. Do not access another person's account or secretly record calls without first checking whether the recording is lawful. Evidence obtained unlawfully can create a second dispute instead of solving the first.

9. What a practical request to the platform should contain

A useful request is short, specific and traceable. It states the account identifier, date of the measure and exact consequence. It asks for the concrete reasons, the term or policy applied, the key facts considered inaccurate, confirmation of whether automated monitoring or decision support was used, access to a qualified human contact and review of the measure. Use a channel that produces a ticket number or delivery record.

Threats, repeated bulk submissions or public posts exposing customer data usually weaken the record. If income loss is urgent, a limitation period may be running, discrimination is alleged or employment status is disputed, obtain timely individual advice. An internal appeal does not necessarily suspend a court, administrative or contractual deadline.

10. Where the GDPR may help now

The GDPR already applies when the platform processes personal data. Transparency and access rights can clarify data categories, purposes, recipients, retention periods and, where applicable, meaningful information about the logic of automated decision-making. Article 22 specifically addresses a decision based solely on automated processing that produces legal or similarly significant effects, subject to exceptions and safeguards.

The presence of an algorithm somewhere in the workflow is not enough to trigger Article 22. The assessment must consider whether human involvement was meaningful, what effect followed and which legal basis is relied on. Nor does an access request create an unlimited right to source code, other people's data or security secrets. Data access and the contractual challenge should be coordinated but remain distinct procedures.

11. Labour law, P2B and the DSA: overlaps without shortcuts

If the facts point to employment, termination must also be assessed under applicable labour law regardless of a “partner” label. Organisation, control and actual dependency matter more than contractual vocabulary. In Greece, a person alleging a breach of labour legislation may also consider the Labour Inspectorate route, while recognising that status and remedy may require a fuller legal determination.

A genuinely self-employed person who qualifies as a “business user” may, under the conditions of Regulation (EU) 2019/1150, have P2B safeguards concerning restriction or suspension. Article 11 of the Directive does not apply to such business users because the specialised P2B provisions prevail. The Digital Services Act may matter where the action is a statement-of-reasons or account/content-moderation decision within its scope. It does not turn every delivery-work deactivation into a DSA content-moderation case.

12. What platforms should build before national transposition

A responsible platform should inventory every system that monitors or affects work, map data to decisions, remove prohibited or excessive inputs, staff genuine human oversight and create a review route capable of reversing an error. A reviewer must not be penalised for overriding the system. Human review that always confirms the automated output is not effective oversight.

Reasons, human contact, audit logs, deadlines and remedies form one accountability process. Without a record of the system version, relevant input, rule triggered and human action, neither the affected person nor the platform can reconstruct what happened. Preparation also requires representative involvement where applicable, data-protection impact assessment and testing for discriminatory or unsafe outcomes.

13. Official sources and limits of this guide

Legal information: Official sources were reviewed on 31 August 2026. The transposition deadline is 2 December 2026 and no published Greek transposition measure was identified at that time. Labour law, GDPR, P2B and DSA routes depend on the facts. This guide is not individual legal advice.