Contract with a self-employed person by 1 October 2026

From 1 October 2026 the rules of platform work get stricter: if a self-employed person works with one platform for longer than six months and more than 160 hours a month, the platform blocks the “customer — contractor” pair for two months. A direct civil-law contract with an NPD payer does not automatically fall under that block — but the risk of reclassification as employment has not gone away. Before the deadline it makes sense to rewrite the wording: a result, not a schedule; certificates; a check of NPD status; no job titles and no salaries.

This is a guide, not legal advice. The text of 289-FZ and official explanations may be refined — check the current text of the law and keep the contract version as of the date it was made.

If you have an old civil-law template and a new version “for NPD” — first record the differences, then agree them with the contractor:

Compare two versions Check for risks

What the logic of 289-FZ changes for the customer

The platform-economy law is aimed at intermediaries: aggregators and order platforms. The threshold “6 months + 160 hours a month” starts a cooling-off period: the platform does not let the same parties continue the link for two months. Long full engagement through a platform is a reclassification-risk zone.

The platform itself does not “block” a direct contract with a self-employed person. But the tax authority and the courts look at the same signs: continuity, a schedule, subordination, the customer’s tools, and the absence of a result as the subject. If your civil-law contract looks like employment, the 1 October deadline only highlights the problem. It does not create it from scratch.

What to rewrite in the contract before 1 October

1. The subject is a result, not a process

Describe a measurable result (a report, a batch of content, a closed development stage)
Remove shifts, “a working day from 9 to 18”, a timesheet, and a duty to “be on call at all times”
Deadlines are delivery dates, not an attendance regime

2. Certificates and acceptance

Each stage is closed by a certificate or an electronic confirmation of the result
Payment is tied to acceptance, not to a “monthly salary”
The NPD receipt is a required annex to the payout

3. NPD status and bans on “staff-like” terms

A check of self-employed status before the contract and before each large payout
No job title, staffing table, leave, or sick leave “as for an employee”
The contractor chooses the methods and means, unless something else is needed for the result

A practical step

Search the template for: “salary”, “job title”, “schedule”, “workplace”, “employment”. Each hit is a candidate for deletion or for rewriting around a result. Then compare the old and new versions of the contract.

A direct civil-law contract and a platform: two different tracks

If you hire through a platform, watch the 160-hour threshold and the length of cooperation: once the rule triggers, the pair will be frozen for two months, and you will not be able to “simply re-register the same person on the same platform”. If you work directly, the platform block does not apply to you, but you need a clean civil-law frame and discipline on receipts.

Do not mix the schemes in one document: “as on the platform, but we pay to a card with no receipt” is a fast path to claims. Either a platform contract under the intermediary’s rules, or a direct civil-law contract with NPD and certificates.

A template “for a self-employed person” is easy to assemble from a brief and immediately run for signs of employment:

Draft a contract Check for risks

Checklist before 1 October 2026

The subject of the contract is a result and stages, not a job title and a schedule
There is a certificate procedure, and payment is tied to acceptance
An NPD status check and a receipt requirement are fixed
Salary, leave, “workplace”, and staff-style subordination are removed
It is clear whether you go through a platform (the 160-hour cap) or directly
The old and new contract versions are saved and compared

Short conclusion

By 1 October 2026 platforms will cut long full links more strictly under the 160-hour rule. A direct contract with an NPD payer does not automatically insure you against the block — it needs to be brought to the form “result + certificates + receipt”, without employment markers. The deadline is useful as a date to revise templates, not as the day “when everything breaks by itself”.

Assemble or check an NPD contract in DocumentCHEK

Upload the current civil-law contract, or assemble a draft for a self-employed person — get a review of reclassification risk and one-sided terms.

Draft a contract Check the contract

Need to compare the old and new template? Compare two versions.

Contract with a self-employed person by 1 October 2026: what to rewrite before the deadline