Self-employed people and platforms after 1 October 2026: what to check in the contract now
The law is already in force — caps, cooling-off, and a direct civil-law contract: what to check in the text, rather than racing a deadline
From 1 October 2026 the platform-economy rules already apply. The question is no longer “will we rewrite the template in time”, but how to work from here: who is the party in a dispute, whether a platform block of the pair will trigger, and whether your direct contract with a self-employed person looks like employment. Below is a practical review for the customer and the contractor.
This is a guide, not legal advice. Subordinate acts and platform practice are still being refined — keep the offer and the contract version as of the date of the work.
You have an old civil-law contract and a new exchange offer — first record the differences, then run the text for signs of reclassification:
What actually changed after 1 October
For operators of digital platforms, limits on a self-employed person’s long “full engagement” with one customer through the platform are now on. The public benchmark: cooperation longer than six months in a row and a load above 160 hours a month for that customer — after that the platform must technically restrict the interaction (a cooling-off period, usually about two months).
A direct contract outside the platform is not automatically cut off by this block. But the criteria of 6 months + 160 hours have become a market indicator of risk: if you have the same pattern on paper and in fact, the Federal Tax Service and a court will look at signs of employment just as strictly as before.
Two tracks: the platform offer and your civil-law contract
1. You work through an exchange or an aggregator
- Who is the party to payment, and who issues the NPD receipt
- How the platform counts hours and the length of cooperation
- What happens when the pair is blocked: access to orders, payouts, disputes
- Whether you also have a parallel direct contract — and whether it contradicts the offer
More on where the offer meets a direct agreement: a self-employed person through a platform.
2. A direct contract with an NPD payer
- The subject is a measurable result or volume of services, not “performance of duties”
- No work schedule, job title, salary, or subordination to internal rules
- Certificates and NPD receipts on actual acceptance
- A check of self-employed status on the payment date
Risky wording is covered here: civil-law wording with a reclassification risk. Preparation “for the deadline” is in the article for 1 October; this piece is about the regime after the rules took effect.
What the customer should do this week
- A list of NPD contractors: who is through a platform, who is direct, and how many months in a row
- For platform work — check the offer and the cooling-off rules; leave a margin on the load
- For direct contracts — strip out “employment” words and fix the result in certificates
- Do not move one person from the platform onto a direct contract with the same schedule — that does not disguise the relationship
A 10-minute checklist
- It is clear whether you work through a platform or under a direct civil-law contract
- The current platform offer or contract version is saved
- The text has no schedule, job title, salary, or “labour discipline”
- The subject and the certificates are tied to a result
- There is a procedure for checking NPD status and the receipt
- It is clear who is responsible in a dispute over quality and deadlines
Related reading
- Civil-law contract and employment: what is different
- How to check a civil-law contract
- How to draft a contract with a self-employed person
Short conclusion
After 1 October the market is guided by platform caps and the same reclassification criteria as before. A working approach: split the flows “platform / direct contract”, remove employment wording, and check the text before the next payment — not after a claim.
Check a contract with a self-employed person in DocumentCHEK
Upload the civil-law contract or the offer — get a review of one-sided terms and risk signs. If you need a new frame, assemble a draft from a brief.