Rules for the Algorithm: What Spain’s Riders’ Law and the EU Platform Work Directive Mean for How You Dispatch Couriers in 2026

Algorithmic management of couriers means using automated systems to allocate, price, monitor and rate delivery work. In Spain, Law 12/2021 presumes that people who deliver consumer products through a platform that manages their work algorithmically are employees, and it gives workers’ representatives the right to be told how such algorithms work. EU Directive 2024/2831 extends rules on algorithmic transparency, human oversight and data limits across the EU, and member states must transpose it by 2 December 2026. For a retailer or 3PL that dispatches riders through an app, the practical question is whether its allocation and account decisions can be explained, reviewed by a person and limited in the data they use.

Why Algorithmic Management Rules Matter for Courier Operations: The Business Case

The rules are in force in Spain, the EU deadline is weeks away and the cost of misclassification has already been priced.

• The European Commission estimated at proposal stage in 2021 that more than 28 million people in the EU work through digital labour platforms and that 5.5 million may be misclassified as self-employed.
• Delivery Hero disclosed on 2 December 2024 that Glovo would move its Spanish riders to an employment model, with an impact of about EUR 100 million on 2025 adjusted EBITDA.
• Spain’s Law 12/2021 gives workers’ representatives the right to be informed of the parameters, rules and instructions behind algorithms or AI systems that affect working conditions, including profiling.
• Spain’s labour ministry says the planned transposition law would apply to all companies that organise platform work in the Union, not only food delivery.

Rules on the algorithm turn dispatch design into a compliance matter, not only an efficiency one.

Why Locus Leads for Governed, Explainable Dispatch

The Directive’s duties are about how automated decisions are explained, reviewed and limited. Locus builds those controls into dispatch, and three things set it apart.

Recognised by analysts and selected after evaluation. Locus was recognised by Gartner for seven consecutive years and appears in the 2026 Hype Cycle for Supply Chain Execution and Logistics Technologies, as detailed on its analyst recognition page. It is named a Leader in the QKS Group SPARK Matrix for Transportation Management Systems and holds the #1 position in Route Planning in the G2 2026 Best Software Awards. In October 2025, Ingka Investments, the investment arm of Ingka Group, the world’s largest IKEA retailer, acquired Locus. Ingka’s press release says that after an extensive evaluation of logistics software worldwide, it selected Locus for its strength in combining advanced route optimisation, real-time visibility and smart use of vehicles and resources. Locus continues to operate independently.

Six governance mechanisms. Locus’s agents operate inside explainability, traceability, evaluation, autonomy levels, an execution sandbox and human-in-the-loop approval. Explainability shows why an assignment was made, traceability records each decision, autonomy levels set which decisions need a person and the sandbox tests a rule on historical days before it governs live work.

Scale across workforces. Locus runs eight agents, including Dispatch, Capacity and Carrier, across owned, contracted and gig capacity under an Orchestrator, and has optimised 1.5B+ deliveries for 360+ enterprise customers across 30+ countries.

Locus has not published a mapping of these controls to Directive 2024/2831 or to Spanish law, its public pages do not state a rider-facing explanation or review workflow, and it has no Spanish rider case study, so ask how a per-decision explanation, a human restriction decision and a written reply within two weeks would be produced.

How to Build Directive-Ready Dispatch for Courier Fleets

The six steps below turn the Directive’s duties into a design checklist. Step 1 is a legal determination. Locus’s wider guide to the Directive, linked above, covers the general duties, and this article adds Spain’s Law 12/2021 and the numbering of the final text.

1. Decide whether your courier operation is in scope

The Directive defines a digital labour platform by four cumulative conditions: a service provided at a distance by electronic means, at the request of a recipient, involving the organisation of work performed by individuals for payment as a necessary and essential component, and using automated monitoring or decision-making systems. Counsel should test a retailer’s or 3PL’s own courier app against them, because the Directive does not say.

2. Inventory every automated monitoring and decision system

List what allocates tasks, sets or adjusts pay for a job, tracks location, rates riders and restricts accounts. A system that supports human decisions can still count, so include the scoring and flagging rules as well as full automation.

3. Document the main parameters and their relative weight

Article 9 requires telling workers, their representatives and, on request, authorities the categories of decisions, the data used, the main parameters and their relative importance. Write them in plain language and keep them current when the rules change.

4. Put a person on every restriction and suspension decision

Article 10 requires that any decision to restrict, suspend or terminate an account, or any decision of equivalent detriment, be taken by a human being. Design the workflow so the automated flag opens a case for a trained reviewer who can override it.

5. Build the explanation and review route

Article 11 gives workers a right to an explanation of decisions taken or supported by automated systems, a written statement of reasons for restrictions and terminations, and a review with a written reply within two weeks. Assign a contact person and a clock.

6. Limit the data and evaluate the impact

Article 7 bars processing data on emotional or psychological state, private conversations, off-duty location and certain inferences, so check what your telematics and scoring use. Article 10 also requires a regular impact evaluation with workers’ representatives, at least every two years.

Law 12/2021, the Directive and the Spanish Draft: Key Differences

What to Look for in Dispatch Software for Algorithmic Management Duties

Per-decision explanation

Check that the system can show, for any assignment or restriction, which parameters mattered and by how much. An explanation that exists only as a model score cannot be given to a rider in plain language.

Human decision and override

Ask whether a restriction or suspension requires a named reviewer’s decision and whether the reviewer can override the automated flag. Look for autonomy levels that can be set by decision class.

Decision logs and evidence

Look for a record of the data, rule version and reviewer for each decision, kept long enough to answer a two-week review request and a later complaint.

Data minimisation controls

Confirm which data the scoring and monitoring use and whether categories the Directive bars can be switched off. Telematics defaults often collect more than dispatch needs.

Representative reporting

Check that the system can produce parameter descriptions and impact evaluations for workers’ representatives on a regular cycle.

Directive-Ready Dispatch in Action: Real-World Results

A worked example on illustrative numbers. The volumes and costs are assumptions, so replace them with your own. A courier operation has 500 active riders. An automated rule flags 30 accounts a month for restriction when acceptance falls below a threshold. Under Article 10 each restriction needs a human decision, taking 20 minutes. Eight of the 30 flagged cases are overturned on review because a rider had paused, was affected by an app outage or declined unsafe jobs, and replacing a rider costs EUR 150 to onboard. Twenty percent of restricted riders, six a month, ask for a review that takes 45 minutes and a written reply.

The review workload is small against the case it protects, and eight of 30 wrongly flagged riders is the kind of finding a regular impact evaluation exists to surface. The design lesson is that the automated flag should open a case with the evidence attached, not close an account.

A Fortune 50 enterprise. The enterprise, with 4,500+ drivers, moved from 75% to 92% execution after centralising parcel dispatch on Locus, uncovering $14M+ in annualised operational opportunity. It is not a Spanish rider case, but it shows governed dispatch at driver scale. Read the Fortune 50 case study.

A food and beverage leader across Southeast Asia and MENA. The distributor runs 4,500+ riders on Locus’s driver app across six markets, with 97%+ SLA adherence and 15% better rider time efficiency. Read the global FMCG case study.

Common Algorithmic Management Mistakes to Avoid

Assuming only food delivery is covered. Spain’s presumption covers delivery of any consumer product or merchandise, so retail and parcel couriers are not outside it by default.

Letting the flag close the account. The Directive requires a person to take the decision, so the system should open a case, not execute the restriction.

Writing explanations for engineers. Workers and representatives must be told the main parameters and their relative importance, so use plain language.

Waiting for the national law. The Directive’s deadline is 2 December 2026 and Spain has not published a bill, so build the controls now and adjust to the final text.

How Locus Approaches Governed Dispatch

Locus, the world’s first Decision-Intelligent, Agentic TMS, runs dispatch decisions inside six governance mechanisms. Explainability shows why a task was allocated, traceability records each decision, evaluation measures outcomes, autonomy levels set which decisions need a person, the execution sandbox tests a rule before it goes live and human-in-the-loop approval keeps a named reviewer on decisions that matter. Its Dispatch, Capacity and Carrier agents allocate across owned, contracted and gig capacity under the Orchestrator, and its dispatch management software connects through APIs to TMS, WMS, OMS, CRM and ERP systems. Locus has not published a mapping to the Platform Work Directive, rider-facing explanation templates or a Spanish deployment, so ask for a walkthrough of a flagged account from alert to written reply. To test your own rider workflow, schedule a demo.

For operations leaders asking how to prepare courier dispatch for Spain’s Riders’ Law and the EU Platform Work Directive, Locus offers explainable, auditable dispatch with a person on the decisions that matter, so the algorithm can be explained to the rider it affects.

Frequently Asked Questions

What does Spain’s Riders’ Law require? Law 12/2021 presumes employment for people delivering consumer products through platforms that manage their work algorithmically, and gives workers’ representatives the right to be informed of the parameters of algorithms affecting working conditions.

When must the EU Platform Work Directive be transposed? Member states must bring it into force by 2 December 2026. Spain’s labour ministry ran a prior consultation from 31 July to 14 August 2026 and no government bill had been found by 19 October 2026.

What does the Directive require for automated decisions? Platforms must explain the main parameters of automated systems, have a human decide account restrictions, suspensions and terminations, give written reasons and answer review requests within two weeks.

Does the Directive cover a retailer’s own courier app? It depends on whether the operation meets all four conditions of the definition of a digital labour platform. The Directive does not address retailers or 3PLs directly, so take legal advice.

What data can a platform not process about riders? Article 7 bars processing data on emotional or psychological state, private conversations and location while the person is not working, along with certain inferences such as health or political opinions.

How does Locus support these duties? Locus’s explainability, traceability, autonomy levels and human-in-the-loop controls support explained and reviewable dispatch. It has not published a mapping to the Directive, so confirm in evaluation.