Platform
“Platform” under the New Labour Codes: Meaning, Definition, and Legislative Intent
Out of all the four new labour codes, the word “platform” appears only in the Code on Social Security, 2020. The other three Codes do not use the term at all, whether in their definitions or anywhere else in their operative provisions. This article examines what “platform” means in the context of the Code on Social Security, where that meaning comes from, and why Parliament chose to introduce these concepts.
What is a “Platform”? Meaning from Other Statutes and Sources
The Code on Social Security does not define the word “platform” as a standalone term. However, its meaning can be somewhat understood by reading three sources together: the Code itself, the Information Technology Act, 2000, and the Rajasthan Platform Based Gig Workers Act, 2023.
First, the Code on Social Security in Section 2(2) defines the term “aggregator” as follows:
An aggregator means a “digital intermediary or a market place for a buyer or user of a service to connect with the seller or the service provider.” In the architecture of the Code, the entity that runs or operates a platform is called an “aggregator.” The platform itself is the digital space; for example, an app or a website through which this connection happens. The two terms, platform and aggregator, describe the same reality from different angles: one is the technology, the other is the entity behind it.
Second, the Information Technology Act, 2000, provides the foundational statutory meaning of what such a digital structure is. Under Section 2(w) of that Act, an “intermediary” means any person who, on behalf of another person, receives, stores, or transmits electronic records, or provides any service with respect to that record. The definition specifically includes online marketplaces and internet service providers. A platform, in the statutory sense, is therefore a type of digital intermediary that facilitates transactions and connections between parties without itself being the direct provider of the underlying service or employment.
Third, the Rajasthan Platform Based Gig Workers (Registration and Welfare) Act, 2023 which is the first state law in India specifically governing platform workers defines “aggregator” as a digital intermediary for a buyer of goods or user of a service to connect with the seller or the service provider, including any entity that coordinates with one or more aggregators for providing services. This mirrors the central Code's definition and confirms that Indian law consistently understands a platform as a digital bridge between service providers and consumers.
Put simply, in the context of labour laws and social security, a “platform” is an app or a website run by a company (the aggregator) that connects workers who provide services such as delivering food, driving passengers, or doing household repairs, with customers who need those services. The worker uses the platform to find work and get paid. The platform does not employ the worker in the traditional sense; it merely facilitates the arrangement.
As of today, no Supreme Court judgment has authoritatively defined the word platform in this specific context. A petition filed by the Indian Federation of App-Based Transport Workers (IFAT) before the Supreme Court, challenging the classification of platform workers and their exclusion from employment benefits, remains pending. The Supreme Court has issued notice in this matter and observed that the rights of gig workers cannot be denied, but a final judgment defining platform has not yet been delivered.
Karnataka's Statutory Definition of "Platform"
A more recent and more detailed statutory definition of "platform" has now been provided at the state level. Section 2(g) of the Karnataka Platform Based Gig Workers (Social Security and Welfare) Act, 2025 defines "platform" as:
any arrangement providing a service through electronic means, at the request of a recipient of the service, involving the organisation of work performed by individuals at a certain location in return for payment, and involving the use of automated monitoring and decision-making systems or human decision-making that relies on data.
This is the most precise statutory definition of "platform" yet enacted in India in the context of gig work. Several features of this definition deserve attention. First, it is functional rather than technical: the focus is on what the arrangement does: organises work, facilitates payment, rather than on the technological architecture that underlies it. Second, it explicitly incorporates algorithmic management into the definition itself. The reference to "automated monitoring and decision-making systems" recognises that what distinguishes a digital labour platform from a conventional employer or marketplace is precisely its use of data-driven systems to allocate tasks, monitor performance, and manage workers. Third, it is location-aware: the phrase "at a certain location" captures delivery, ride-hailing, home services, and similar work where the service is physically rendered at a specific place, as distinct from fully remote digital labour.
The Karnataka Act also separately defines "aggregator" in Section 2(b) as a digital intermediary connecting buyers and sellers of goods and services, including any entity that coordinates with one or more aggregators, a definition that expands on the central Code's formulation and explicitly captures multi-tier platform structures.
Taken together, the Karnataka Act gives the Indian legal system its first statutory definition of "platform" as a distinct concept in the context of gig work, filling a gap left by the central Code on Social Security.
[Sources: Karnataka Platform Based Gig Workers (Social Security and Welfare) Act, 2025, Section 2(g) and Section 2(b) (Karnataka Act 72 of 2025, notified 12 September 2025); Medianama, "Understanding Karnataka's Gig Workers Welfare Bill 2025," August 20, 2025; Lexology / Argus Partners, "Karnataka Platform Based Gig Workers (Social Security and Welfare) Act, 2025: What Aggregators in Karnataka Must Know," September 23, 2025; LawRbit, "Karnataka Gig Workers Act 2025: Gig Economy Formalization," January 3, 2026; PRS Legislative Research, "The Karnataka Platform Based Gig Workers (Social Security and Welfare) Bill, 2025," prsindia.org]
The DPDP Act and the Proposed Digital India Act: What They Say, and Do Not Say About Platforms
Two further pieces of legislation are relevant to understanding how Indian law conceptualises digital platforms, though neither provides a direct definition of "platform" in the gig work sense.
The Digital Personal Data Protection Act, 2023, which was partially brought into force on 13 November 2025, does not define "platform" as a standalone term. However, it uses the term in its operational provisions and works with the concept of a "social media intermediary", defined in the Third Schedule as any intermediary under the Information Technology Act, 2000 that primarily or entirely enables online interaction between two or more users and allows them to create, upload, share, or access information using its services. The DPDP Act also introduces the concept of a "significant data fiduciary", an entity designated by the central government on account of the volume and sensitivity of personal data it processes which would cover large platform aggregators. Importantly, the DPDP Act applies to digital personal data processed by any entity, including aggregators and digital labour platforms, making it directly relevant to gig work contexts: every time an aggregator collects location data, performance data, or identity information from a worker, it does so within the regulatory framework of the DPDP Act. The Act was partially notified in November 2025 and is being implemented in phases, with full compliance requirements taking effect by May 2027.
The Digital India Act proposed by the Ministry of Electronics and Information Technology as the intended replacement for the Information Technology Act, 2000 has been under consultation since 2023 but has not, as of the time of writing, been introduced in Parliament or enacted. Its proposed framework would introduce a classification system for intermediaries based on risk and size, with different regulatory obligations for categories such as e-commerce platforms, social media intermediaries, online gaming platforms, and AI systems. The proposed Act was expected to provide clearer definitions of various types of digital platforms. However, given that the legislation has not been enacted and no public draft has been released since the 2023 consultations, any analysis of its definitional approach would be premature. What is significant for this article is that the government's own consultations on the proposed Act acknowledged that the IT Act 2000's concept of "intermediary" which currently forms part of the definitional basis for "platform" in gig work law is outdated and inadequate for the range of platform types that now exist. When and if the Digital India Act is enacted, it will require re-reading of the term "platform" in the labour law context alongside whatever new intermediary classifications it introduces.
[Sources: Digital Personal Data Protection Act, 2023 (Act No. 22 of 2023), Third Schedule; CookieYes, "India Digital Personal Data Protection Act (DPDPA): Updated Guide," January 2026; Vidhilegalpolicy.in, "Explained: The Digital India Act 2023," August 2023; Medianama, "India to Regulate AI Under DPDPA, IP Laws, No Standalone AI Law," December 2025 (confirming Digital India Act has not been introduced in Parliament as of late 2025); India Briefing, "Digital India Bill 2023: Key Provisions and Stakeholder Perspectives," August 2023]
What the Code on Social Security, 2020 Actually Defines: “Platform Work” and “Platform Worker”
The Code on Social Security, 2020 introduces two new defined terms in Section 2 that together describe this new form of work.
“Platform work” is defined under Section 2(60) as: a work arrangement outside of a traditional employer-employee relationship in which organisations or individuals use an online platform to access other organisations or individuals to solve specific problems or to provide specific services, or any such other activities as may be notified by the Central Government, in exchange for payment.
“Platform worker” is defined under Section 2(61) simply as: a person engaged in or undertaking platform work.
Reading these two definitions together, the picture is this: a platform worker is someone who earns money by providing services through a digital app or website, where the arrangement is not a formal employment contract with a fixed employer. The most familiar examples in everyday life are food delivery riders, cab drivers working through ride-hailing apps, domestic service professionals available through home services apps, and freelancers offering work through online task marketplaces.
The definition of platform work is deliberately broad in one important respect: it includes “any such other activities as may be notified by the Central Government.” This means Parliament has not frozen the definition to the types of work that existed in 2020. As new kinds of platform-based work emerge, the Central Government can bring them within the definition by issuing a notification, without needing to amend the statute.
It is also worth noting what these definitions do not say. They do not say that a platform worker is an employee. They do not create an employment relationship between the worker and the aggregator. The definition is built precisely around the idea that this kind of work sits outside the traditional employer-employee relationship. This deliberate choice has significant consequences for what benefits platform workers are entitled to, a point discussed in the next section.
Why These Definitions Were Included: Legislative Intent
The inclusion of platform worker and platform work in the Code on Social Security, 2020 was not accidental. It was a considered response to a visible and growing gap in Indian labour law.
Before the four Labour Codes, Indian labour legislation was built almost entirely around the concept of a formal employer-employee relationship. A worker had rights, which included right to minimum wages, provident fund contributions, gratuity, maternity benefit, insurance because they worked for an identifiable employer who was legally responsible for their welfare. This model worked reasonably well in factories, mines, plantations, and offices. It did not work at all for a delivery rider who earns a living through an app and can be switched on and off the platform without any notice, severance, or explanation.
The Second National Commission on Labour, which submitted its report in 2002, had already flagged the growing phenomenon of informal and non-standard work. By the time the Labour Codes were being drafted in the 2019-2020 period, it was impossible to ignore the scale of the platform economy. Millions of workers in India were earning their primary income through apps like Ola, Uber, Swiggy, Zomato, Urban Company, and Dunzo, with no access to any formal social security benefit.
Parliament's response in the Code on Social Security was twofold. First, it gave these workers a legal identity by defining them. Before 2020, the terms “platform worker” and “gig worker” had no statutory existence in Indian law. By defining them in Section 2, the Code formally acknowledged that this category of worker exists and deserves legal attention. Second, under Sections 113 and 114, the Code extended the right to social security schemes to these workers for the first time. The Central and State Governments are empowered to frame schemes covering life and disability insurance, health benefits, maternity benefits, old age protection, and similar welfare measures for gig and platform workers.
The funding mechanism for these schemes is also significant. Under Section 109, aggregators (the companies running the platforms) are required to contribute to a social security fund. The contribution rate is to be notified by the Central Government and is capped at between 1% and 2% of the aggregator's annual turnover, subject to a ceiling of 5% of the total amount paid or payable by the aggregator to its gig and platform workers. This was a landmark step: for the first time, the companies benefiting from platform labour were being made financially responsible for the welfare of those workers, even without any formal employment relationship.
The legislative intent behind these provisions can therefore be summarised in three points. The first is recognition: to formally acknowledge that platform workers exist and that they do real, economically productive work, even if it does not fit the old categories of “employment.” The second is inclusion, i.e. to bring platform workers within the umbrella of social security law, so they are not left entirely without protection simply because they have no employer in the conventional sense. The third is flexibility: to create a framework capable of growing with the platform economy, rather than one that is locked to the specific types of platform work visible in 2020.
It should be noted, however, that the definitions in the Code on Social Security are only the beginning of the story. The scheme-making powers under Sections 113 and 114 have not yet been fully exercised, and the contribution rates under Section 109 remain unnotified as of the time of writing. The legal identity that the Code gives to platform workers has, so far, outpaced the actual delivery of benefits. The framework exists; its implementation is still work in progress.
The International Perspective
How the European Union Defines Platform Work
While the four Labour Codes are domestic legislation and stand on their own terms, it may be useful to note how other jurisdictions have approached the same question. The most significant international development in this area is the European Union’s Directive (EU) 2024/2831 on improving working conditions in platform work, adopted on 23 October 2024 and published in the Official Journal of the European Union on 11 November 2024. It came into force on 1 December 2024, with EU Member States required to transpose it into their national laws by 2 December 2026.
The EU Directive defines a “digital labour platform” in Article 2 as a natural or legal person providing a service which is provided, at least in part, at a distance by electronic means such as a website or mobile application, and which involves, as a necessary and essential component, the organisation of work performed by individuals in return for payment. “Platform work” under the same provision means work organised through a digital labour platform and performed in the EU by an individual on the basis of a contractual relationship between the digital labour platform or an intermediary and that individual. These definitions are drawn directly from Article 2 of Directive (EU) 2024/2831, available on the official EUR-Lex database of the European Union.
Two features of the EU approach stand out in contrast with the Indian framework. First, the EU Directive goes a significant step further than the Code on Social Security by introducing what it calls a rebuttable legal presumption of employment. This means that when facts indicating direction and control of a worker by a platform are present, the law presumes that the worker is an employee, and it is then for the platform to prove otherwise. Under the Indian Code on Social Security, no such presumption exists. Platform workers in India are defined as a separate category that sits outside the traditional employer-employee relationship, with no mechanism to challenge that classification. The Code gives them a legal identity but stops short of giving them employee status. Second, the EU Directive specifically regulates algorithmic management, the use of automated systems by platforms to assign work, monitor performance, and make decisions about workers. It prohibits platforms from using algorithms to collect personal data when a worker is not actively working, and requires that significant decisions such as suspension or termination of a worker's account must be made by a human being, not an automated system. The Code on Social Security contains no comparable provisions on algorithmic management.
These contrasts are not merely academic. The IFAT case, discussed earlier in this article, has already drawn attention to international developments. The Directive represents the most comprehensive legislative attempt by any major jurisdiction to define platform work, regulate the power of platforms over workers, and resolve the question of employment status systematically. As India works towards implementing the social security framework for platform workers under Sections 113 and 114 of the Code on Social Security, the EU Directive offers a detailed reference point, particularly on the questions of employment classification and algorithmic accountability that Indian policymakers and courts are likely to engage with in the years ahead.
International Judicial Precedents and the ILO Process
The definitional and regulatory questions around "platform" and "platform work" discussed in this article are not limited to India and the European Union. Two further international developments are directly relevant.
Judicial precedents on platform classification
In Uber BV v Aslam [2021] UKSC 5, the United Kingdom Supreme Court unanimously held that Uber drivers were "workers" — a third category between "employee" and "independent contractor" under UK employment law — and were entitled to minimum wage and paid holiday. The court's reasoning turned on a functional analysis of the platform's role: Uber set the fare, dictated contractual terms, and exercised significant operational control, regardless of how the arrangement was labelled. What matters, the court held, was the substance of the relationship rather than the form. This approach — analysing what a platform actually does rather than what it calls itself — is the judicial counterpart to the EU Directive's presumption of employment and stands in contrast to India's Code on Social Security, which defines platform work by reference to the absence of a traditional employer-employee relationship without providing any mechanism to re-examine that classification.
In the United States, California's Assembly Bill 5 (AB5), enacted in 2019, sought to reclassify gig workers as employees by codifying a strict three-part "ABC test." Platforms like Uber, Lyft, and DoorDash responded by backing Proposition 22, a voter initiative approved in November 2020 that created a statutory exemption for app-based services, allowing them to continue classifying drivers as independent contractors. The California Supreme Court upheld Proposition 22 in July 2024 in Castellanos et al. v. State of California. The California episode illustrates a key structural question that Indian law will eventually have to confront: what happens when a platform argues that the work it organises is genuinely independent, while the workers argue that the platform's control over them makes them employees in practice?
The ILO's standard-setting process
At the international level, the International Labour Organization (ILO) is in the process of developing the first binding global Convention on decent work in the platform economy. The first discussion took place at the 113th ILC in June 2025, where member states agreed to proceed with a Convention and Recommendation. At the 2025 ILC, definitions of "digital labour platform" and "platform work" were among the agreed elements of the proposed text, — making this process directly relevant to how "platform" will be defined in international labour law. The final discussion and vote on adoption is scheduled for the 114th ILC, to be held in Geneva from 1 to 12 June 2026. If adopted, the Convention would represent the first binding international standard for platform work and would require India, as a founding ILO member since 1919, to consider its ratification position and its consistency with domestic definitions under the Code on Social Security, 2020.
[Sources: Uber BV v Aslam [2021] UKSC 5 (UK Supreme Court); California Assembly Bill 5 (AB5), 2019; Castellanos et al. v. State of California, California Supreme Court, July 25, 2024; ILO, "Decent Work in the Platform Economy," Draft Convention and Recommendation (ILC114-V(3)), August 2025, ilo.org; ILO, "Agenda of the 114th Session of the International Labour Conference (1–12 June 2026)," ilo.org; World Employment Confederation, "ILC 2025: Progress Made on Platform Work Regulation," June 20, 2025, wecglobal.org]
Summary
The word “platform” as a standalone term is not defined in any of the four Labour Codes, or indeed in any other central Indian statute. Its meaning in the Code on Social Security must be understood through the definition of “aggregator” in Section 2(2) of the Code itself, read alongside the concept of an “intermediary” in the Information Technology Act, 2000. A platform is, in short, a digital intermediary, i.e. an app or website that connects service providers with customers.
The Code on Social Security, 2020 takes this concept and builds two new defined categories upon it:
1. First is “platform work” under Section 2(60), meaning work done outside a traditional employment relationship through an online platform in exchange for payment;
2. And second is “platform worker” under Section 2(61), meaning any person who does such work. These are new additions to Indian law, with no equivalent in the three other Labour Codes.
Their inclusion reflects a deliberate legislative choice to bring a rapidly growing section of the Indian workforce within the reach of social security and employment benefits, not by treating them as employees, but by creating a separate, purpose-built framework that recognises the reality of how thousands of Indians earn their living today.