Platform workers and social protection: International developments

Platform workers and social protection: International developments

The growth of the gig and platform economy in recent years has created new markets for businesses and income-generating opportunities for workers, but it has also brought to the forefront issues related to social protection for platform workers. The platform economy is a diverse and complex reality, with different business models, economic sectors, forms of service provision, and types of work and worker profiles. Therefore, platform work cannot be looked at from any single viewpoint.

There are two broad types of platform work: online web-based and location-based, or in-situ. Online web-based platforms enable workers to undertake work from any location, at any time. It makes remote work possible across borders, supplying services such as software development, text translation, graphic design, data entry, and image review for social networks. On the other hand, in-situ platforms require workers to be located in a specific area to provide services such as deliveries, transport, and personal care. In-situ platforms are traceable, while the workers supplying their services online are scattered worldwide and often invisible (ILO, 2021a; LaSalle and Cartoceti, 2019).

Estimates indicate that the gig and platform economy has around 22 per cent of the working-age population in the United States offering some kind of a good or service using a digital platform (ILO, 2021a). These figures reflect the significant increase in the use of digital labour platforms by workers who rely on them as their primary source of income. According to the ILO, the number of online web-based and location-based platforms rose from 142 in 2010 to over 777 in 2020. Many small and medium enterprises have initiated location-based platforms and increasingly rely on digital labour platforms to supply workers, particularly in restaurants and retail businesses.

However, studies show that platform workers, both in-situ and online, do not enjoy adequate social protection. Only about 40 per cent of online platform workers have health insurance, less than 15 per cent have protection in case of work accidents and unemployment, and about 20 per cent have protection for old age. For in-situ platform workers, only slightly more than one in two have health insurance, less than one-third have protection in case of work injury, and less than one-fifth have old-age pensions coverage (ILO, 2021a).

Table 1. Proportion of platform workers covered by social protection benefits, by development status, worker's sex and type of platform
  Health insurance Employment injury Unemployment insurance Disability insurance Pension
Online platforms
Total 41 15 12 12 20
Developed countries 61 17 17 15 35
Developing and emerging countries 43 18 9 7 23
Male 42 18 13 12 21
Female 39 11 10 10 14
Has other job 45 17 14 13 26
No other job 37 12 10 10 14
In situ platforms
Taxi 51 27 5 4 18
Delivery 53 31 5 6 17
Source: ILO, 2021a.

The evidence highlights the dire need to protect platform workers sustainably and justly. The current lack of protection is often due to the classification of platform workers as self-employed, which often leads to minimal or no access to social security systems and reduced benefit packages. These hindrances result in exclusion from contingencies such as unemployment or employment injury.

Social security is essential for ensuring decent work in today's and tomorrow's world of work. Therefore, platform workers, both employees and self-employed, should be eligible for at least a basic level of social protection. This requirement is also in the interest of fair competition between enterprises and safeguarding and promoting labour markets' efficiency.

Studies show that adequate labour and social protection for platform workers depend on adequate policies, regulations, process implementation, transparency, awareness and information. Furthermore, ensuring proper coverage of platform workers – independently from the employment status – poses numerous challenges, such as ease of access, data transfer, awareness, and portability, similar to other difficult-to-cover groups (ISSA, 2022a). Box 1 summarizes the key aspects of protecting platform workers.

Box 1: Key aspects of the protection of platform workers

  • Labour protection
    • Correct classification of employment status
    • Ensuring adequate working conditions / decent work for platform and gig workers
      • Adequate pay
      • Working time regulation
      • Occupational safety and health
      • Employment protection
    • Ensuring the transparency of data and rules implemented by algorithms to protect workers' rights
  • Social security coverage
    • Adapting national social protection policy and legal frameworks
    • Facilitating registration and contributions payment
    • Data sharing between platforms, workers and authorities
    • Awareness and information
    • Portability and transferability among schemes and employers
    • Cross-border protection

Building on previous studies, this article further develops the aspects introduced in Box 1 and reviews recent developments in providing social protection to workers on digital labour platforms (La Salle and Cartoceti, 2019), (Behrendt, Nguyen and Rani, 2019; Freudenberg, 2019; ISSR, 2021; Deraeve, Rogiers and Segaert, 2022). It also reflects discussions by the G20 Employment Working Group in which the International Social Security Association (ISSA) prepared a joint technical paper with the International Labour Organization (ILO) and the Organisation for Economic Co-operation and Development (OECD). (ILO, ISSA and OECD, 2023)

Regulating labour protection for platform workers

Regulating platform and gig work is necessary to ensure adequate social protection for workers in these new forms of employment, and it is particularly crucial to prevent worker misclassification and disguised employment. Adequate classification of employment status, employment protection and ensuring the transparency of rules implemented by algorithms and data to protect workers' rights are all critical elements in ensuring workers' rights (ILO, 2021a).

Preventing misclassification of workers and curbing disguised employment

Determining the proper employment status of platform workers is essential to establish their social security and labour rights, considering that the nature of labour and social protection is intrinsically linked to the dependent or independent nature of employment.

At present, the absence of clear legal frameworks governing work on digital platforms has led to many labour-related disputes and case-law, which has contributed to delays in legal certainty and predictability. Even when a judicial decision has been reached, it may not apply to all digital platforms operating in a given country.

In response to these challenges, several countries – such as Belgium, Italy, and Spain have introduced legislative measures to clarify the criteria used for determining the existence of an employment relationship on digital platforms (Deraeve, Rogiers and Segaert, 2022;  Italian Law No. 128;  Spanish Law 12/2021). Many have established a rebuttable presumption of an employment relationship whenever certain criteria are met. This approach is also proposed as part of a project for a European Union (EU) directive (European Commission, 2021) (see Box 2). In turn, China and other countries have introduced a third, intermediate category of workers entitled to basic labour and social protection rights (Deraeve, Rogiers and Segaert, 2022).

Box 2: European Commission proposals on improving working conditions in platform work

The European Commission proposed in December 2021 a directive on improving working conditions in platform work. The directive would create a legal presumption of an employment relationship between a digital platform and a worker if two out of five criteria for control of work performance are fulfilled. These relate to: the setting of remuneration, whether there are binding rules concerning conduct, the supervision of work, the freedom of work organization and working time and restrictions regarding the choice of clients. The presumption can be rebutted if the platform proves that there is no employment relationship.

In addition, the directive would introduce certain rights for platform workers, including the right to transparency regarding the use and functioning of automated monitoring and decision-making systems, the impact of such automated systems on working conditions and channels to request reviews of such decisions. These measures concerning transparency would apply to both employees and genuine self-employed. Finally, the proposal aims to enhance transparency and traceability of platform work to support competent authorities in enforcing existing rights and obligations concerning working conditions and social protection.

Source: European Commission, 2021

Despite these legislative responses, some workers still fall into a "grey zone" between employment and self-employment. These workers may not have access to the same social protection as dependent employees and, as a result, may be vulnerable. Some countries have attempted to address this by extending social protection to financially dependent self-employed workers or specific occupational groups. Others have introduced an intermediate category of workers with some basic labour and social protection rights.

Ensuring decent work rights for platform and gig workers

Platform and gig workers must enjoy labour protection mechanisms related to adequate pay, working time regulations, occupational safety and health and employment protection.

Furthermore, platform workers should have the right to know the rules and criteria used by algorithms for task assignment, work evaluation and access to the data related to their work. Lack of transparency in these aspects bears the risk of infringing upon workers' rights. The EU and some European countries are already addressing this issue. The role of algorithms in managing platform workers' tasks has been a topic of significant concern for some time. Many workers have voiced their concerns about the lack of transparency in the algorithmic management practices that the data platforms use, which could potentially infringe upon their rights.

Social protection for platform workers

Whether employees or self-employed, platform workers should be eligible for at least a basic level of social protection. This would enable them to access health care and income security in case of maternity, employment injury, sickness, old age, disability or loss of the income provider. Additionally, non-contributory schemes play an important role in ensuring a basic level of social protection for all.

Similarly to other difficult-to-cover groups, it is also essential to establish effective mechanisms for registration, contribution collection, and benefits delivery to ensure all workers receive adequate social protection (ISSA, 2022a).

Some countries are developing labour and social security legislation for platform workers, with some providing full social security coverage. Argentina is developing a new statute for the on-demand digital platform worker (Estatuto del Trabajador de Plataformas Digitales Bajo Demanda), which provides full social security coverage. Belgium developed a labour and social framework inspired by the EU's draft directive, including work injury insurance for the self-employed. And India's Code of Social Security (CoSS) (2020) extends protection to gig and platform workers, including a financing mechanism (Majumdar, 2021;  Deraeve, Rogiers and Segaert, 2022).

In turn, providing adequate social security to the self-employed has been highlighted as an objective by G20 countries, among others, especially considering the lessons learned from the COVID-19 pandemic (ILO and OECD, 2020; ILO, 2021b; ISSA, 2021). Self-employed workers in several countries have been granted access to social protection, which extends to those with low income and in vulnerable situations. Argentina, Brazil, Canada, France, the Republic of Korea, Turkey, and Uruguay are among the countries that provide a level of social protection comparable to that of employees. Other countries such as Austria, Colombia, and Sweden have ensured mandatory work injury insurance for these workers (Deraeve, Rogiers and Segaert, 2022).

Facilitating the enrolment of platform and gig workers

As with other difficult-to-cover groups, achieving effective social security coverage for platform and gig workers involves implementing effective and easy-to-use registration, contribution collection and benefits delivery mechanisms (ISSA, 2022a).

Easily accessible registration and contribution payments for platform workers are mainly based on two complementary features: (i) Simplified procedures and tools provided by the social security and contribution collection agencies, and (ii) Interconnection between the platform and the contribution collection agencies aiming at automatic contributions payment at source. Both require investment in the digital and technological capacities of implementing agencies, and the latter the development of approaches towards national initiatives for data sharing.

Some countries have developed simplified registration and contribution payment mechanisms to improve the social security coverage of self-employed and small entrepreneurs, notably in Argentina, Brazil, Estonia (see Box 3), and France (Central Agency of Social Security Bodies, 2022; Deraeve, Rogiers and Segaert, 2022).

In turn, developments in Indonesia (Nguyen and Cunha, 2019), Malaysia (La Salle and Cartoceti, 2019; Bin Othman Mohd, 2022) and Singapore have focused on the coverage of work injury and death benefits for ride-hailing workers (Freudenberg, 2019).

Box 3. Estonia – Entrepreneur account

Estonia established the Entrepreneur Account in 2019 to simplify the formalization and payment of taxes for private persons engaged in entrepreneurship without large expenses, including digital platform work. Taxes, pensions and health insurance contributions are remitted directly and in a simplified way from the account to the social security administration. Although it has a broader scope, the entrepreneur account enables formalizing platform workers and other new forms of work.

The holder of an entrepreneur account is entitled to various social benefits, such as a pension, parental benefits and health insurance, which are covered by the social contribution. In addition to simplifying payments, the account allows for income from several platforms and work to be received and considered as a whole, reflecting the realities of many digital workers registered on several platforms.

Source: Estonia, Entrepreneur account

Automated contribution payment through the interconnection between platforms and agencies has been developed in Estonia (Box 3), Indonesia, Malaysia, Singapore and Uruguay (for transport platform workers) (Social Insurance Bank, 2017). In France, workers can authourize the platform to transfer contribution payments on their behalf to the contribution collections agency (Ogembo and Lehdonvirta, 2020). Other countries, like Argentina, Brazil and Mexico have introduced electronic invoicing systems for self-employed workers to improve tax collection and compliance (Barreix and Zambrano, 2018).

In this context, effective and systematic data sharing between platforms, workers and authorities is a key enabler for enrolment, and promotes voluntary compliance by automating processes. It also facilitates detecting and addressing under-declaration and fraud, it also protects workers' rights related to their classification and transparency of rules and criteria used by algorithms and data, outlined above. The portability of data between platforms also promotes labour market mobility and can be used to increase compliance with social insurance contributions. For instance, in France, platforms must share detailed information on workers' income with social security agencies and tax authorities.

Data-sharing mechanisms must comply with data protection regulations. In this way, the General Data Protection Regulation in the EU recognizes individuals' rights to data portability, including social protection entitlements and work and rating histories, as do the Standards for Personal Data Protection for Ibero-American States (Article 30).

Awareness and information

As well as for other difficult-to-cover groups, experiences show that awareness and information campaigns are crucial to encourage platform workers' formalization and social security coverage (ISSA, 2022a; ISSA, 2022b).

In France and Malaysia, platforms inform workers about the applicable social contribution and tax obligations and provide a link to the websites of the respective administrative authorities (Freudenberg, 2019) (GrabBenefits – Grab). The Argentinean Tax Authority (Administración Federal de Ingresos Públicos – AFIP) provides information and Q&A about the Monotax scheme and its variants (Argentina. Monotributo-AFIP). The Indonesian National Social Security Administering Body for Employment (BPJS Ketenagakerjaan) and the digital transport platform coordinate awareness measures (see Box 4).

Box 4. Indonesia – BPJS Ketenagakerjaan

In Indonesia, BPJS Ketenagakerjaan informs platform drivers and generates awareness about formalization through its YouTube channel. Furthermore, the national Social Security administering body for employment works in partnership with the financial sector to facilitate the registration and contribution payments to extend the coverage of work injury and death benefits to platform drivers. These measures encourage them to register online with the agency, while their social security contributions are drawn directly from their driver accounts.

Source: Nguyen and Cunha, 2019

Portability and transferability among schemes and employers

Platform workers may alternate between being employed and self-employed or working through a platform while employed. Therefore, it is crucial to have the ability to transfer entitlements and working records to ensure platform workers are adequately protected in such transitions. The absence of such portability and transferability can result in incomplete social protection coverage, particularly regarding long-term benefits such as pensions. Such issues can create social protection gaps during work and life transitions. These challenges become even more pronounced when the worker and platform are situated in different jurisdictions or countries.

Instituting rights and protections across borders

Protecting platform workers developing cross-border activities (i.e. involving different countries) involves additional challenges as they work through platforms operating across several jurisdictions. Unlike the in-situ scenarios, cross-border online platform workers might not be in the same jurisdiction as the platforms or final customers.

There is thus a need for international coordination mechanisms to address these issues, notably for determining the legislation applicable to this type of online platform. Online platform workers may be classified as self-employed or employees, impacting their social security and tax obligations. If considered self-employed, they would be subject to social security regulations in their country of residence. However, if they are classified as employees, the question arises regarding which country is responsible for registering and collecting social security contributions (see Table 2). For instance, the coverage for medical care would allow access in the employer's country, which is of little value for the employee residing potentially on the other side of the world.

Table 2. Considerations concerning social security rights and protection across borders
Type of worker Social security protection and barriers
Self-employed A self-employed worker who provides services abroad must contribute in their place of residence and is not treated differently from the self-employed providing online services to domestic clients. International situations may increase difficulties concerning enforcing compliance.
Employee Depending on the social security system covering the worker and to which contributions should be paid:
  • Social security system in the country where work is performed, i.e. the country of residence of the worker: It is important to know if the platform is registered and if it can legally pay contributions in this country.
  • Social security system in the country where the platform is registered: It is important to know if foreign employees can be registered in the social security system and to which social security benefits they have access. Also, whether portability is assured.

Coordinating categorization criteria is essential for ensuring workers are classified correctly and receive the appropriate benefits. This is particularly challenging given the global nature of online platform work, and international cooperation is necessary to develop and enforce these criteria.

Finally, ensuring the portability of rights and benefits is crucial for protecting the rights of online platform workers. With workers often located across different countries, ensuring they have access to social security benefits, regardless of where they are located, is essential.


The growth of the gig and platform economy in recent years has created new business and income-generating opportunities for workers, but it has also brought social protection gaps among platform workers to the fore.

Social security coverage is key to ensuring that platform and gig workers have access to health care and income security, especially for unemployment, maternity, employment injury, sickness, old age, disability, loss of income provider, and child care. Regardless of their employment status (i.e. employed, self-employed or other), providing adequate and sustainable social protection for gig and platform economy workers is essential to ensure decent work. Furthermore, the formalization of platform work is crucial to promote efficient labour markets and fair competition between firms, as well as to support the sustainability of social security systems by encouraging contribution and tax payments.

Nevertheless, it is clear that providing adequate social and labour protection for workers on digital platforms is a complex issue, notably due to the wide diversity of platform work scenarios. Policymakers will need to continue to adapt and refine frameworks in order to ensure that workers are protected without stifling innovation and flexibility.

A broad set of policy and administrative mechanisms is needed to build the capabilities of all workers to engage in today's and tomorrow's world of work. Through systematic interconnections and taking advantage of the digital nature of the platforms, social security administrations and business platforms can provide effective mechanisms for registration, collection of contributions and delivery of benefits to ensure adequate access for workers.

As shown in this article, a growing number of countries are developing policies, legal frameworks and innovative mechanisms to promote the formalization and protection of platform workers by simplifying and automating administrative procedures and carrying out information and awareness campaigns. It is important to highlight that experiences in formalizing other difficult-to-cover groups, such as domestic and missing-middle workers, have provided valuable insights and institutional capacities to address the challenges of improving the social security coverage of platform workers.

Finally, regulating cross-border platform work and protecting workers poses complex challenges. As no central authority oversees these activities, ensuring workers are treated fairly and paid according to the law can be challenging. Furthermore, the absence of collective agreements for online platform workers leaves them vulnerable.

In this complex journey, the ISSA will continue to support member institutions in developing administrative processes, innovating mechanisms and building the required institutional capacities to address the emerging challenges related to the formalization and protection of platform workers.


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