Ikigai Law advised one of India's largest e-commerce platforms as India's social security framework for gig and platform workers was being developed under the Code on Social Security, 2020 and its rules. How that framework treated platform businesses carried significant cost and structural consequences for the client and the wider sector, and the central design questions were still open while the rules were being written.
A key question was how aggregators should be required to contribute to the social security fund for gig and platform workers. We advised the client on how the framework, across the range of design options then under consideration, would affect its business once implemented, and on how it would affect different platform models differently. As part of this, we also undertook a comparative analysis of how other jurisdictions had approached quick-commerce regulation, to inform the client's position on how the rules should apply to these operations.
This analysis also fed into the client's engagement with the government, including meetings with the Ministry of Labour and Employment. Our work shaped the client's contribution to the discussions on one of the framework's central questions.
Since this engagement, the Code on Social Security, 2020 has been substantially brought into force and the Social Security (Central) Rules, 2026 notified.
The Ikigai Law team comprised Aman Taneja and Nehaa Chaudhari (Partners), Vijayant Singh (Principal Associate), Isha Mittal and Sarmad S. Ahmad (Senior Associates), and Nirmal Bhansali, Utkarsh Gupta and Vidushi Sinha (Associates). The employment law team at Ikigai Law regularly advises on employment and HR related issues, and specialises in doing so in the context of technology businesses and startups.
Frequently asked questions
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What is the Code on Social Security, 2020 (the “Code”), and how does it apply to gig and platform workers?
The Code consolidates India's central social security legislations and, for the first time, statutorily extends government social security schemes to gig and platform workers. It provides the mechanism for the central and state governments to establish a social security fund and frame welfare schemes for these workers covering areas such as life and disability cover, accident insurance, health and maternity benefits, old-age protection, etc. The Code was brought into force on 21 November 2025 and has been partially operationalised through the Social Security (Central) Rules, 2026 (the “Central Rules”), notified on 8 May 2026.
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Are gig and platform workers considered employees under the Code?
No. For the purposes of the Code gig and platform workers are recognised as distinct categories. Instead, the Code creates a separate social security framework funded partly by aggregator contributions.
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Who is an "aggregator" under the Code?
An aggregator under the Code is, broadly, a digital intermediary or marketplace that connects buyers or users of a service with the gig or platform workers who provide it. While the Code identifies specific categories of aggregators, such as ride sharing, food and grocery delivery, logistics, e-marketplace, etc., this is not an exhaustive list. Whether a particular business is an aggregator will require analysis, especially for platforms operating across multiple models.
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How much must aggregators contribute to the gig worker social security fund?
Under the Code, an aggregator must contribute between 1%-2% (as notified by the Central Government) of its annual turnover to the social security fund, subject to an upper limit of 5% of the total amount paid or payable by the aggregator to those workers. Presently, neither the contribution rate nor the commencement date have been notified by the Central Government, but as the Central Rules provide for interest on delayed contributions, aggregators should treat the contribution framework as established in principle and provisioning for such contributions.
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What are the compliance obligations under the Code for aggregators?
The Code (read with the Central Rules) require the aggregator to facilitate registration and reporting of platform and gig workers through an API integration with a designated central government portal, including reporting new engagements and exits on a real-time/daily basis. The Central Rules also provide for filing periodic returns with respect to their contributions. Because compliance is technology-driven and deadline-based, aggregators generally need to align their internal systems and worker-onboarding processes with these requirements.
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How do state gig-worker laws, such as those in Rajasthan and Karnataka, interact with the Code?
Several Indian states have enacted or proposed their own laws for gig and platform workers, with Rajasthan and Karnataka being among the first. While there is some overlap with the Code (namely w.r.t. welfare contributions), these state laws impose obligations that go beyond the central framework, such as requiring aggregators to put in place grievance redressal mechanisms for worker disputes, providing for prior written notices for termination, transparency in pay structures and algorithmic systems, etc. While there is no fundamental conflict between the State and Central legislations, their interplay is still uncertain, with the Karnataka legislation already facing judicial challenge. Platforms operating nationally should therefore assess the Central regime together with the specific legislation, rules and implementation requirements applicable in each State in which they engage gig or platform workers.
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Does Ikigai Law advise on compliance with the Code?
Yes. Ikigai Law advises platform businesses and aggregators on their obligations to gig and platform workers under the Code and Central Rules. This includes assessing how they apply to different aggregator models, analysing contribution and registration obligations, advising on compliance with the Central and State requirements, and supporting engagement with the appropriate Government stakeholders on how the rules apply to business models.
