Algorithmic Management in the Labour Code: Key Changes for Lithuanian Employers

On 13 October 2026, the Seimas approved at first reading draft amendment package No. XVP-1914 to the Labour Code, alongside related bills No. XVP-1915 and No. XVP-1916. These legislative drafts transpose European Parliament and Council Directive (EU) 2024/2831 on improving working conditions in platform work into Lithuanian law. The bill passed the initial vote with 85 votes in favor, none against, and 8 abstentions. The Committee on Social Affairs and Labour has been designated as the lead committee, with plenary deliberations scheduled for November 2026. The provisions must enter into force by 2 December 2026.

While the directive is widely associated with gig platforms such as delivery and ride-hailing services, the Lithuanian legislative draft extends its core transparency obligations much further. Under the proposed Article 27(4) of the Labour Code, rules governing algorithmic management (Articles 110-4 through 110-8) will apply mutatis mutandis to all traditional employers that rely on automated monitoring or decision-making systems to allocate tasks, record working hours, or assess employee output.

Consequently, logistics centers, manufacturing facilities, customer support operations, and other enterprises utilizing performance-tracking software will need to audit their algorithmic systems and carry out a Data Protection Impact Assessment (DPIA). The draft legislation explicitly prohibits automated systems from collecting data on an employee's emotional or psychological state, private conversations, off-duty activities, or predicting the exercise of fundamental rights, such as trade union membership.

Employers will also be required to provide transparent notifications regarding the logic, parameters, and criteria behind automated tools no later than the first working day or prior to implementing system updates. Employees receive the statutory right to request written explanations of automated decisions affecting their working conditions and have those decisions reviewed by a designated human manager within a set timeframe.

The amendments codify the primacy of facts principle (Articles 32(2) and 110-3 of the Labour Code). Rather than relying on the formal title of a civil or contractor agreement, competent bodies will assess actual subordination, behavioral direction, and economic dependence to determine whether an employment relationship exists. Self-employed platform workers will be granted direct standing to submit claims to the Labour Disputes Commission.

A one-year transitional grace period is established during which fines for undeclared work will not be levied, provided businesses rectify non-compliant arrangements. Specific technical procedures and reporting formats for data submissions to the State Labour Inspectorate (VDI) will be enacted through subordinate regulations by 2 December 2026.