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CDS position statement on the European Commission’s call for evidence for an evaluation and impact assessment on the EU Chips Act 2

This contribution builds upon the CDS’ engagement with regulation, innovation competition, and industrial policies, and digital markets.   On 5th September 2025, the European Commission published a Call for Evidence for an Evaluation and...

Algorithmic management in the workplace raises significant questions for the regulation of employment relationships. As automated systems increasingly monitor and govern workplace activities, concerns arise regarding transparency, accountability, the protection of workers’ rights, health and safety, their autonomy and well-being. Employers face challenges in adopting and deploying algorithmic systems, such as workforce resistance, high costs and legal questions.

This working paper examines the regulatory and policy implications, with a focus on the interplay between employment law, data protection, and AI regulation. The paper begins by charting the current state of play of workplace technology and the concept of algorithmic management, highlighting its applications and effects for workers and employers. It then analyses the EU’s regulatory framework, including the General Data Protection Regulation (GDPR) and the Artificial Intelligence Act (AI Act), discussing their provisions and effectiveness in addressing the challenges posed by algorithmic management. Focus is put on specific rules for automated monitoring and decision-making, data access and portability rights and the role of software developers and vendors.

Finally, the paper assesses the limitations of the current regulatory framework and critiques its adequacy in providing appropriate safeguards, legal certainty and clear guidance to businesses and workers in the EU. By analysing the current regulatory framework and its applications, this paper aims to contribute to the ongoing debate on the regulation of algorithmic management, providing insights for policymakers and stakeholders seeking to promote fair and accountable algorithmic management practices while fostering innovation and efficiency in modern workplaces

 

Disclaimer

The content of the report only reflects the views of the author and does not represent the official position of the European Commission.

This report was prepared in the context of the 2024/25 EU fellowship programme. From 1 September 2024 to 31 July 2025, the author conducted research at the Robert Schuman Centre for Advanced Studies, at the European University Institute (EUI) in Florence (Italy). In the framework of his fellowship, he co-organised a workshop on AI and algorithms at the workplace with the EUI’s Centre for a Digital Society which took place on 6 May 2025.

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