Introduction
The growing demand for flexible app-based work, together with wider internet access and more affordable smartphones, has expanded India’s platform economy. Food-delivery, ride-hailing and home-service platforms have created livelihoods outside the traditional employer–employee relationship. Depending on incentives and the availability of work, gig workers often engage with several aggregators at once, and multi-platform engagement has therefore become an important feature of India’s gig workforce.
“Gig worker” and “platform worker” are statutory categories under the Code on Social Security, 2020, which requires aggregators to contribute to the Social Security Fund and provides registration mechanisms intended to give workers access to portable benefits. The Social Security (Central) Rules, 2026, notified on 8 May 2026, further operationalised eligibility by prescribing engagement of at least 90 days with a single aggregator, or 120 days cumulatively across multiple aggregators, in the preceding financial year. Importantly, where a worker is engaged with several aggregators on the same calendar day, each engagement counts towards the threshold.
However, this recognition remains limited. While the Rules clarify how multi-platform engagement counts for eligibility, neither the Code nor the Rules establishes how contribution liability should be apportioned among multiple aggregators, or which platform is accountable when a claim or dispute involves more than one platform. The framework thus addresses eligibility fragmentation but leaves contribution allocation, inter-platform accountability and dispute resolution unresolved. This study examines this regulatory gap and its implications for effective and portable social security protection.
A. Need for the study
The growth of multi-platform gig work poses challenges to India’s social security framework. While the Social Security (Central) Rules, 2026 clarify cumulative eligibility for multi-platform workers, they do not specify how contributions should be apportioned among aggregators or who is accountable where a dispute involves multiple platforms. This creates uncertainty in contribution allocation, accountability and benefit enforcement. This study examines these gaps and assesses whether the framework adequately protects multi-platform gig workers.
B. Review of literature
Dr. Gajanan Jagadish Salunkhe, in “The Code on Social Security, 2020 and Gig Workers in India: A Critical Analysis of Legal Recognition and Implementation Challenges”, examines gig and platform workers under the Code on Social Security, 2020, focusing on classification, registration, aggregator contributions and protection gaps.1
Ashwath Chitranshi and Aryan Sharma, in “Social Security for Gig and Platform Workers under the Code on Social Security, 2020: Gaps, Challenges, and the Road Ahead”, point out the lack of clarity and enforcement in how workers are categorised, how the rules are put into practice and what responsibilities aggregators bear under the Code on Social Security, 2020.2
Dr. Vinayaka K., in “Social Security Code, 2020 and Its Impact on Gig and Platform Workers: A Critical Assessment”, examines gig and platform workers under the Code on Social Security, 2020, focusing on classification, registration, aggregator contributions and protection gaps.3
Dr. Sofia Ahmed Sait, in “Bridging the Protection Gap: A Systematic Analysis of Social Security Deficits in the Gig Economy and Organisational–Governmental Pathways Toward Inclusive Platform Work”, examines the gaps in social security for gig workers, with a focus on legal classification, income instability, the algorithmic management of work and the lack of consistent regulation. The study also discusses portable benefits and ways of funding them.4
Dr. S. Emlin Jobitha and Dr. V.R. Dinkar, in “Ensuring Social Protection for Gig Workers: Guidelines and Recommendations Across Jurisdictions in Digital Age”, compare social protection measures for gig workers in India, the United States and the European Union, highlighting gaps in current systems. The study underscores the need for cooperation among governments, platform companies and workers.5
Viha Jain and Sudarsana Sarkar, in “Socio-Economic Challenges for Gig Workers in India’s Emerging Labour Landscape”, examine the socio-economic challenges faced by Indian gig workers, particularly social security deficits, wage instability and the lack of employment protection. They also consider domestic and international approaches and propose measures such as a Gig Worker Provident Fund, but do not specifically examine multi-platform accountability or the portability of social security.6
C. Research gap
Existing literature examines social security deficits, implementation challenges, aggregator contributions and the legal recognition of gig and platform workers under the Code on Social Security, 2020, alongside comparative social protection mechanisms. However, it largely predates the 2026 Rules and does not address their eligibility-aggregation mechanism or the unresolved issues of contribution allocation and accountability among multiple aggregators. This study addresses that gap by examining these issues in the post-2026 regulatory framework.
D. Research problem
Many gig workers now work for multiple platforms, for example driving for one and delivering for another. The Social Security (Central) Rules, 2026 allow engagement across platforms, including on the same day, to count cumulatively towards social security eligibility. However, they do not clarify how contributions should be divided among platforms or which aggregator is responsible when contributions are unpaid or disputes arise. This creates uncertainty about whether protection is fully funded and accountable.
E. Research questions
How do the Code on Social Security, 2020 and the 2026 Rules determine social security eligibility for multi-platform gig workers?
How are social security contributions and accountability divided among multiple aggregators, and do the 2026 Rules address contribution apportionment?
To what extent does the framework ensure enforceable social security protection beyond eligibility, and what legal gaps remain?
F. Hypotheses
H1: The 2026 Rules adequately address eligibility but not contribution liability and accountability among multiple aggregators.
H2: A cross-platform contribution mechanism would ensure more effective and accountable social security protection for multi-platform gig workers.
G. Objectives of the study
To examine the social security framework for gig and platform workers under the Code on Social Security, 2020 and the 2026 Rules.
To analyse the eligibility mechanism of the 2026 Rules for multi-platform workers, including same-day cumulative counting.
To assess contribution liability and accountability among multiple aggregators.
To identify legal gaps and suggest measures to strengthen social security protection for multi-platform gig workers.
H. Research methodology
This study adopts a doctrinal legal research methodology, analysing the Code on Social Security, 2020, the 2026 Rules, government notifications, policies, judicial decisions and other relevant legal materials. Secondary empirical data from government reports, surveys and industry studies are used to understand multi-platform work. A comparative approach examines social security portability and platform accountability in selected jurisdictions. The study identifies the legal gaps concerning contribution allocation and accountability that remain after the 2026 Rules.
I. Limitations of the study
The study is limited to India’s legal framework, particularly the Code on Social Security, 2020 and the 2026 Rules, and focuses specifically on multi-platform gig workers. It relies mainly on secondary sources and does not include primary surveys or interviews. As the 2026 Rules are recent, little evidence yet exists on the practical operation of Form XX and Form XXI, particularly for multi-platform workers. Selected foreign jurisdictions are considered for comparison, and the findings may evolve with future implementation and regulatory developments.
Legal framework governing gig and platform workers
A. Statutory recognition and definitions
The Code on Social Security, 2020 expressly recognises gig workers and platform workers. Section 2(35) defines a gig worker,7 while Sections 2(60) and 2(61) define platform work, performed through an online platform in exchange for payment, and the platform worker who undertakes it.8 Section 2(2) defines an aggregator as a digital intermediary or marketplace connecting the buyers or users of a service with its sellers or providers.9 This recognition extends social security protection beyond traditional employees, though uncertainty remains about the precise scope of protection for non-traditional workers.10
B. Social Security Fund and aggregator contributions
The Code establishes a Social Security Fund under Section 141, with a separate account for the funding of schemes for gig and platform workers.11 Section 114 provides for schemes covering life and disability cover, accident insurance, health and maternity benefits, old-age protection and crèches, which may be funded by the Central and State Governments, by aggregators or from other sources. Aggregators are to contribute at a rate, notified by the Central Government, of not less than one and not more than two per cent of their annual turnover, subject to a cap of five per cent of the amount paid or payable to gig and platform workers, from such date as the Central Government notifies. Effective protection therefore depends on proper notification, contribution collection and implementation, revealing a gap between legal provisions and practical enforcement.12
C. Registration, e-Shram and portability of benefits
Section 113 provides for the registration of unorganised, gig and platform workers so that they can access social security schemes.13 The e-Shram portal and the Universal Account Number (UAN) support worker registration and portability: the Government has stated that the Aadhaar-linked UAN will allow benefits to continue when workers move between platforms, employers or States, and the 2026 Rules require aggregators to share the details of their gig and platform workers on a Central portal for the generation of such a number. However, Aadhaar-based identification and digital registration raise concerns about privacy, accessibility and the possible exclusion of workers facing digital barriers.14
D. The 2026 Rules and the multi-platform threshold
The Social Security (Central) Rules, 2026, notified on 8 May 2026, introduced a 90-day threshold for workers engaged with a single aggregator and a 120-day cumulative threshold for those engaged with multiple aggregators.15 Engagement with several aggregators on the same day counts separately for each aggregator towards the threshold.16 This formally recognises concurrent multi-platform work for eligibility, but it addresses only the counting of eligibility. Contribution allocation under Section 114(4) remains aggregator-specific and unreconciled.17
Multi-platform engagement: contribution, allocation and accountability
A. The persisting single-aggregator assumption in the funding formula
The Social Security (Central) Rules, 2026 allow workdays across aggregators to count towards eligibility, but the funding structure remains aggregator-specific. Section 114(4) requires each aggregator to contribute on the basis of its own turnover.18 Under the 2026 Rules, each aggregator separately assesses and pays its contribution in Form XX and files its own final return in Form XXI.19 Thus, while eligibility is aggregated across platforms, contributions remain fragmented. A worker who completes 70 days on Platform A and 50 on Platform B may qualify, yet the two platforms keep separate contribution records, revealing a gap between aggregated eligibility and fragmented funding.20
B. Aggregator-specific liability under Section 114(4)
Section 114(4) makes each aggregator responsible only for its own contribution, based on its own turnover, and does not provide for joint or proportionate liability where multiple platforms engage the same worker.21 The 2026 Rules do not alter this position. The model follows the establishment-based design of older social security laws such as the Employees’ Provident Funds and Miscellaneous Provisions Act, 1952 and the Employees’ State Insurance Act, 1948, under which each employer contributes for its own employees. This creates a mismatch, because gig workers may work for several platforms at once, leaving a gap in contribution allocation and accountability.22
C. Comparative doctrine: Uber BV v. Aslam and the limits of worker reclassification
In Uber BV v. Aslam, the UK Supreme Court held that Uber drivers were “workers”, relying on Uber’s control over fares, contractual terms, the acceptance of trips, the monitoring of drivers’ performance and communication with passengers.23 Indian scholarship has considered whether a similar control-based approach should apply to gig workers.24 However, reclassification alone would not solve the contribution-apportionment problem where workers engage with multiple platforms. The gap therefore concerns funding architecture and platform accountability, not merely worker classification.
D. Gap identification: no forum for multi-aggregator disputes
Neither the Code nor the 2026 Rules designates a forum empowered to apportion liability or adjudicate a claim where more than one aggregator is implicated. The National Social Security Board and the State Unorganised Workers’ Boards under Section 6, the former also serving as the Board for gig and platform workers under Section 114(6), are recommendatory and advisory bodies without an adjudicatory mandate extending to inter-aggregator disputes.25
The multi-platform problem in practice
A. Empirical scale of multi-platform engagement
India’s gig workforce grew from about 77 lakh in 2020–21 to an estimated 1.2 crore in 2024–25, and is projected to reach 2.35 crore by 2029–30.26 Platform disclosures reported in the press suggest that the average delivery partner works fewer than forty days a year, and the same report describes most gig workers as seasonal, part-time or multi-platform workers.27 The funding and accountability gaps identified above therefore affect a substantial workforce rather than a hypothetical minority.
B. Applying the 120-day rule: a hypothetical worker’s contribution trail
Consider a worker engaged with Platform A for 70 days and with Platform B for 60 days. Under the 2026 Rules, this cumulative engagement of 130 days satisfies the 120-day threshold.28 However, each aggregator independently assesses and pays its contribution through Form XX and Form XXI on the basis of its own turnover and records.29 In the absence of cross-platform reconciliation, eligibility is unified while contribution records remain fragmented.
C. From exclusion risk to reconciliation risk
A day threshold counted separately for each platform would exclude multi-platform workers who fall short on every individual platform even though their total engagement is substantial.30 Cumulative counting under the 2026 Rules reduces this problem but creates a reconciliation risk: workers may qualify legally while their contribution records remain fragmented. Entitlement may therefore exist without an effective mechanism for combining contributions. Scholarship on portability similarly identifies gaps between formal entitlement and administrative reconciliation.31
D. Consequences for benefit continuity and enforceability
The reconciliation gap threatens benefit continuity, because no institution is made responsible for combining contributions across platforms, which may lead to under-payment despite eligibility. It also weakens enforceability, because workers lack a clear statutory mechanism to compel reconciliation between aggregators.32 The 2026 Rules thus address eligibility fragmentation but leave significant funding and enforcement gaps unresolved.
Emerging regulatory responses
A. State-level gig-worker legislation
Rajasthan enacted India’s first State gig-worker statute, the Rajasthan Platform Based Gig Workers (Registration and Welfare) Act, 2023, which establishes a welfare board and a fund financed by a welfare fee charged on the value of each transaction.33 Karnataka, Bihar, Jharkhand and Telangana have since enacted comparable legislation, each broadly following Rajasthan’s model of a welfare board funded by a welfare fee levied on aggregators.34 This proliferation reflects growing legislative recognition that Central protection alone is insufficient, though it raises questions of overlap, since aggregators may now face welfare obligations at both the Central and the State level.
B. Assessment: do State laws address multi-platform accountability better?
None of the State enactments examined here introduces an eligibility-aggregation mechanism comparable to that of the Central 2026 Rules, and none apportions contribution liability among multiple aggregators.35 Each of these statutes levies its welfare fee on each aggregator’s own transactions or payouts, without reference to a worker’s engagement on competing platforms. State legislation therefore addresses coverage, bringing gig workers within a welfare net, without addressing the accountability question this study identifies, and multi-platform apportionment remains as unresolved at State level as it is at the Centre.
C. The draft Shram Shakti Niti, 2025
The draft Shram Shakti Niti, 2025 proposes a Universal Social Security Account consolidating EPFO, ESIC, e-Shram and Ayushman Bharat (PM-JAY) records into a single portable identity, alongside a national “Labour and Employment Stack”.36 Such an account would be the natural institutional home for the cross-aggregator reconciliation that this study argues is missing. However, the policy remains in draft form, with no published rules specifying how aggregator contributions would be pooled, audited or apportioned across platforms.
D. Central–State coordination gaps
The simultaneous operation of Central aggregator contributions under Section 114 and State welfare fees creates a coordination problem beyond the multi-aggregator gap already identified. An aggregator may be liable to two levies on the same engagement, and a worker registered under both a Central scheme and a State welfare board has no assurance that the two streams of contribution will translate into coordinated benefits. Karnataka and Telangana partly address this by providing that the State welfare fee counts towards the aggregator’s contribution under Section 114(4), with any difference to be reconciled as prescribed; the Rajasthan and Bihar Acts contain no comparable rule.37 Scholarship on India’s federal social security architecture has flagged Centre–State fragmentation as a recurring structural weakness extending well beyond the gig-work context.38
Comparative perspectives
A. European Union: the Platform Work Directive’s presumption and burden-of-proof model
Directive (EU) 2024/2831 creates a rebuttable presumption of an employment relationship in platform work, triggered where facts indicating control and direction are found, and places the burden of rebuttal on the platform rather than the worker.39 The presumption does not, however, apply in proceedings concerning tax, criminal or social security matters, although Member States may extend it to them under national law; the Directive therefore does not itself resolve contribution apportionment, even within the EU.40 Its significance for India lies not in the presumption itself, but in its allocation of the evidentiary burden to the party holding the relevant data.
B. Malaysia: the Gig Workers Act 2025 and Perkeso integration
Malaysia’s Gig Workers Act 2025 (Act 872) requires platform providers to integrate their systems with the Social Security Organisation (Perkeso), for which they have been given a transition period of three to six months, enabling centralised tracking of a worker’s engagement and contributions across platforms.41 This design is consistent with earlier World Bank research showing strong worker demand for social insurance flexible enough to accommodate irregular, multi-source gig income.42 Unlike India’s aggregator-by-aggregator filing system, Malaysia’s model centralises reconciliation at the regulator rather than leaving it to individual platforms.
C. Transferable design principles for India
Two principles emerge as transferable without requiring India to abandon its sui generis “gig worker” and “platform worker” categories: first, placing the evidentiary or reporting burden on the aggregator holding the data, as the EU model does; and second, centralising contribution reconciliation through a single regulator-linked account, as Malaysia’s Perkeso integration does.43 The Code’s registration architecture already contains the elements of such a centralising function: the 2026 Rules require aggregators to share their workers’ details on a Central portal for the generation of a Universal Account Number and to report new engagements and exits in real time or daily, and commentators have called for the seamless integration of State schemes with the Central registration system.44
Findings and suggestions
A. Findings
The hypotheses are partly confirmed. The 2026 Rules address eligibility aggregation through the 120-day cumulative threshold, including same-day counting across platforms.
However, contribution liability and accountability among multiple aggregators remain unresolved under the Central framework and under the State legislation examined.
Comparative analysis shows that worker-centred, cross-platform reconciliation is feasible and has precedents elsewhere, supporting the second hypothesis.
B. Suggestions
Contribution tracking: Mandate UAN-linked reporting in Forms XX and XXI, standardise digital formats and create a cross-platform contribution ledger through e-Shram.
Liability apportionment: Adopt a pro rata rule based on each aggregator’s share of a worker’s engagement, with platforms bearing the burden of proving exclusive responsibility.
Dispute resolution: Give the Social Security Boards specific powers to resolve multi-aggregator disputes through a single-window, time-bound mechanism.
Institutional coordination: Establish Centre–State reconciliation and annual audits comparing aggregator filings with UAN records, and integrate cross-platform reconciliation into the proposed Universal Social Security Account.
Worker access: Enable simple multi-platform declarations and dedicated helpline guidance for workers.
Conclusion
The Social Security (Central) Rules, 2026 mark real progress, resolving the eligibility-fragmentation problem that threatened to exclude multi-platform workers. The study finds, however, that the Code on Social Security, 2020 and the 2026 Rules are only partially adequate for multi-platform workers. The 120-day cumulative and same-day counting mechanism resolves eligibility fragmentation, but contribution liability remains platform-specific, with no reconciliation of multiple contributions, and no clear mechanism exists for resolving multi-platform disputes. Portability therefore remains incomplete: eligibility travels with the worker, but funding and accountability do not.
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Footnotes
1. Gajanan Jagadish Salunkhe, The Code on Social Security, 2020 and Gig Workers in India: A Critical Analysis of Legal Recognition and Implementation Challenges, 13(4) Int’l J. Advance & Applied Rsch. 166 (2026), https://doi.org/10.5281/zenodo.20540526.
2. Ashwath Chitranshi & Aryan Sharma, Social Security for Gig and Platform Workers under the Code on Social Security, 2020: Gaps, Challenges, and the Road Ahead, 8(2) Indian J.L. & Legal Rsch. 8593 (2026), https://www.ijllr.com/post/social-security-for-gig-and-platform-workers-under-the-code-on-social-security-2020-gaps-challeng.
3. Vinayaka K., Social Security Code, 2020 and Its Impact on Gig and Platform Workers: A Critical Assessment, 12(1) Int’l J. Innovative Rsch. Tech. 5360 (2025), https://ijirt.org/publishedpaper/IJIRT181756_PAPER.pdf.
4. Sofia Ahmed Sait, Bridging the Protection Gap: A Systematic Analysis of Social Security Deficits in the Gig Economy and Organisational–Governmental Pathways Toward Inclusive Platform Work, 1(1) Glob. J. Progressive Innovation & Rsch. 20 (2026), https://doi.org/10.68325/gjpir.v1i1.002.
5. S. Emlin Jobitha & V.R. Dinkar, Ensuring Social Protection for Gig Workers: Guidelines and Recommendations Across Jurisdictions in Digital Age, 10(12) Int’l J. Novel Rsch. & Dev. c198 (2025), https://ijnrd.org/papers/IJNRD2512224.pdf.
6. Viha Jain & Sudarsana Sarkar, Socio-Economic Challenges for Gig Workers in India’s Emerging Labour Landscape, in Unlocking the Gig Economy in India 97 (Sumanta Dutta & Ravi Kant Modi eds., MGM Publishing House 2025), https://doi.org/10.62823/MGM/9789349468719/10.
7. The Code on Social Security, 2020, No. 36, Acts of Parliament, 2020, § 2(35) (India) [hereinafter Code on Social Security]. Sections 1–14, 17–141 and 144–163 of the Code, among other provisions, came into force on Nov. 21, 2025. Ministry of Labour and Employment, Notification S.O. 5319(E) (Nov. 21, 2025), https://egazette.gov.in/WriteReadData/2025/267882.pdf.
8. Code on Social Security, supra note 7, § 2(60)–(61) (defining “platform work” and “platform worker”).
9. Id. § 2(2); see also id. sched. VII (categories of aggregators).
10. Suresh Nadagoudar & Rajashree Patil, Social Security Code 2020: An Analysis, 10(2) Christ U. L.J. 19, 23–24, 36–37 (2021), https://doi.org/10.12728/culj.19.2.
11. Code on Social Security, supra note 7, § 141(1)–(2).
12. Id. § 114(1)–(5) (contribution by aggregators at a rate, notified by the Central Government, of not less than one and not more than two per cent of annual turnover, not exceeding five per cent of the amount paid or payable to gig and platform workers, from a date to be notified by the Central Government).
13. Id. § 113(1)–(2).
14. Gig Workers Now Legally Recognised Under India’s Labour Codes, But Key Details Still Missing, MediaNama (Nov. 24, 2025), https://www.medianama.com/2025/11/223-gig-workers-legally-recognised-indias-labour-codes/ (reporting the Government’s statement that the Aadhaar-linked UAN will allow portability across States, platforms and employers); Ministry of Labour and Employment, Notification G.S.R. 344(E), Gazette of India, Extraordinary, pt. II, sec. 3(i) (May 8, 2026) (Social Security (Central) Rules, 2026), r. 48(2)(b)–(c) [hereinafter Social Security (Central) Rules]; Akanksha Dua & Divyaansh Dulles, Central Rules Notified: Key Compliances under Code on Wages (Central) Rules, 2026 and Social Security (Central) Rules, 2026, Obhan Mason (May 20, 2026), https://obhanmason.com/blog/central-rules-notified-key-compliances-under-code-on-wages-central-rules-2026-and-social-security-central-rules-2026/ (summarising r. 48(2)); Anto Robert G., Gig Economy: Prospects and Challenges under Social Security Code, 4(3) Int’l J.L. Mgmt. & Human. 3863, 3871–74 (2021), https://ijlmh.com/paper/gig-economy-prospects-challenges-under-social-security-code/.
15. Social Security (Central) Rules, supra note 14, r. 48(2)(e) proviso.
16. Social Security (Central) Rules, supra note 14, r. 48(2)(e), Explanation (ii)–(iii).
17. Code on Social Security, supra note 7, § 114(4).
18. Id.; Social Security (Central) Rules, supra note 14, r. 49(3)(a).
19. Social Security (Central) Rules, supra note 14, r. 49(3)(a)–(c).
20. Social Security (Central) Rules, supra note 14, rr. 48(2)(e), 49(3); cf. Nadagoudar & Patil, supra note 10, at 37 (noting that the driver of an app-based taxi aggregator has the option of working for a competing aggregator).
21. Code on Social Security, supra note 7, § 114(4).
22. Id.; cf. Nadagoudar & Patil, supra note 10, at 37–38 (noting that unorganised workers shift between occupations and States, and that inter-State coordination remains unresolved).
23. Uber BV v. Aslam [2021] UKSC 5, [94]–[101] (appeal taken from Eng.).
24. Anto Robert G., supra note 14, at 3872–73.
25. Code on Social Security, supra note 7, §§ 6(1), (7), (9), (15), 114(6).
26. Chitranshi & Sharma, supra note 2; NITI Aayog, India’s Booming Gig and Platform Economy: Perspectives and Recommendations on the Future of Work (2022), https://www.niti.gov.in/sites/default/files/2022-06/25th_June_Final_Report_27062022.pdf.
27. Swiggy, Zomato, Ola Must Report Gig Workers to Govt in Real Time under New Social Security Rules, MediaNama (May 12, 2026), https://www.medianama.com/2026/05/223-social-security-central-rules-2026-gig-workers-90-days-work/.
28. Social Security (Central) Rules, supra note 14, r. 48(2)(e).
29. Id. r. 49(3)(a)–(b).
30. See Social Security (Central) Rules, supra note 14, r. 48(2)(e), Explanation (ii); cf. Nadagoudar & Patil, supra note 10, at 37.
31. Ravi Srivastava, Vulnerable Internal Migrants in India and Portability of Social Security and Entitlements (Ctr. for Emp. Stud., Inst. for Hum. Dev., Working Paper No. WP 02/2020, 2020), https://www.ihdindia.org/Working%20Ppaers/2020/IHD-CES_WP_02_2020.pdf; Khushi Bhagat, Social Security Schemes and Migrant Workers: Legal Challenges and Opportunities, Indian J.L. & Legal Rsch. (2024), https://www.ijllr.com/post/social-security-schemes-and-migrant-workers-legal-challenges-and-opportunities.
32. Code on Social Security, supra note 7, § 6(7).
33. The Rajasthan Platform Based Gig Workers (Registration and Welfare) Act, 2023, No. 29, Acts of Rajasthan State Legislature, 2023, § 11 (India) [hereinafter Rajasthan Act], https://prsindia.org/files/bills_acts/acts_states/rajasthan/2023/Act29of2023Rajasthan.pdf.
34. The Karnataka Platform Based Gig Workers (Social Security and Welfare) Act, 2025, No. 72, Acts of Karnataka State Legislature, 2025 (India) (replacing the Karnataka Platform Based Gig Workers (Social Security and Welfare) Ordinance, 2025) [hereinafter Karnataka Act]; The Bihar Platform Based Gig Workers (Registration, Social Security and Welfare) Act, 2025, No. 8, Acts of Bihar State Legislature, 2025 (India) [hereinafter Bihar Act]; The Jharkhand Platform Based Gig Workers (Registration and Welfare) Act, 2025 (India); The Telangana Platform Based Gig Workers (Registration, Social Security and Welfare) Act, 2026, No. 21, Acts of Telangana State Legislature, 2026 (India) (assent first published in the Telangana Gazette on Apr. 28, 2026) [hereinafter Telangana Act].
35. See Rajasthan Act, supra note 33, § 11; Karnataka Act, supra note 34, § 20; Bihar Act, supra note 34, § 22; Telangana Act, supra note 34, § 20; see also Chitranshi & Sharma, supra note 2, at 8604 (describing the Rajasthan and Karnataka State models).
36. Gig Workers Now Legally Recognised Under India’s Labour Codes, supra note 14.
37. Karnataka Act, supra note 34, § 20(5); Telangana Act, supra note 34, § 20(6); see also Nadagoudar & Patil, supra note 10, at 37–38 (noting the dual Central and State authority over schemes for unorganised workers and the absence of any roadmap for inter-State coordination).
38. Srivastava, supra note 31.
39. Directive (EU) 2024/2831 of the European Parliament and of the Council of 23 October 2024 on Improving Working Conditions in Platform Work, art. 5(1), O.J. L, 2024/2831 (Nov. 11, 2024).
40. Id. art. 5(3); Patty Shapiro, It’s Official: The EU Platform Work Directive Is Here, Ogletree Deakins (Jan. 3, 2025), https://ogletree.com/insights-resources/blog-posts/its-official-the-eu-platform-work-directive-is-here/.
41. Gig Workers Act 2025 (Act 872) (Malay.); Gig Economy Platforms Have 3 to 6 Months to Comply with New Perkeso Law, Malay Mail (Mar. 31, 2026), https://www.malaymail.com/news/malaysia/2026/03/31/gig-economy-platforms-have-3-to-6-months-to-comply-with-new-perkeso-law/214568.
42. Yashodhan Ghorpade, Amanina Abdur Rahman & Alyssa Jasmin, Social Insurance for Gig Workers: Insights from a Discrete Choice Experiment in Malaysia (World Bank, Policy Research Working Paper No. 10629, 2023), https://hdl.handle.net/10986/40741.
43. See Directive (EU) 2024/2831, supra note 39, art. 5(1); Gig Economy Platforms Have 3 to 6 Months, supra note 41; cf. Arjun Sangwan, Decoding the Code: A Focus on the Language Employed in Chapter IX of the Code on Social Security, 2020, 4(4) Int’l J.L. Mgmt. & Human. 2877, 2884–85 (2021), https://ijlmh.com/paper/decoding-the-code-a-focus-on-the-language-employed-in-chapter-ix-of-the-code-on-social-security-2020/ (arguing that Chapter IX allocates scheme-making powers between governments rather than conferring enforceable rights, and calling for minimum country-wide benefits).
44. Social Security (Central) Rules, supra note 14, r. 48(2)(b)–(c), (g); Nadagoudar & Patil, supra note 10, at 37.