Vulnerable workers

Protecting vulnerable workers amid shifting regulatory and political landscapes

Vietnam passes Employment Law 2025. Mexico’s social security and labor reforms for platform workers take effect. The United States changes its approach to independent contractors’ classification. EU member states have until 2 December 2026 to create national laws aligning with the Platform Work Directive (PWD).

Key takeaways

  • Governments worldwide are expanding protections for vulnerable workers through legislation and social security reforms.
  • Progress to implement the PWD across the EU remains slow, despite a December 2026 deadline.
  • Meanwhile, the United States has made it slightly easier for companies to classify workers as contractors.

The global gig economy boasted a market size of US$582.2 billion in 2025, with that number expected to grow to US$2,178.4 billion by 2034. As platform workers continue to play an active and vital role in economies across the world, governments are grappling with questions surrounding protections for these workers and how far their rights should extend in comparison with the permanent workforce.

But the conversation reaches far beyond the platform economy, as the term “vulnerable workers” can include low-paid, part-time, temporary, and/or informal workers. Around the world, policymakers are reconsidering how these workers fit within existing employment laws and social security programs.

Many of these conversations are taking place in Europe, following the European Parliament’s adoption of the EU Platform Work Directive (PWD) in 2024. The EU legislation notably requires a legal presumption that platform workers are employees if the company directs and controls their work, thus protecting workers from what the European Parliament refers to as “bogus self-employment.” The Directive also prohibits a person from being dismissed based on a decision made by an algorithm or automated decision-making system.

EU member states have until 2 December 2026 to implement national laws reflecting the principles of the PWD. However, progress is slow in Germany, France, Spain, Italy, the Netherlands, and Hungary, none of which have yet outlined a clear path to doing so.

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Vulnerable workers remain central to the global labor conversation.”

Employee or contractor? Defining platform work

In some countries, political instability is making it difficult to progress legislation. In others, governments are tackling worker misclassification primarily through tax and social security rules rather than employment law. This may have made implementing the PWD less of a political priority for some governments.

Looking outside Europe first, legislation implemented in Mexico on 1 July 2025 states that platform workers in the country are entitled to labor and social security benefits if they meet monthly minimum wage requirements. The reform ensures greater protection for this type of worker while subsequently increasing costs for platforms in the form of employer social security contributions.

In the Netherlands, a moratorium on proactive enforcement against false self-employment by the tax authorities expired at the beginning of 2025. A tax authority finding that an employment relationship is one of false self-employment can have tax and employment law implications for the employer and the employee. Fines will be levied for ongoing breaches in 2026 and retrospective assessments for unpaid contributions may be carried out for periods after 1 January 2025, although not before that date in most cases. A proposal to clarify the legal status of workers and to reduce false self-employment by introducing a presumption of employment for workers earning less than €36 (US$42) per hour is being considered, but it remains unclear whether it will be adopted.

As reported last year, Germany is another country continuing to tackle the issue through the prism of social security contributions. There has been an ongoing focus on misclassification across many sectors during 2025, resulting in administrative and criminal penalties. Germany is working on an initial draft for implementing the PWD, though no legislative text is currently available.

Meanwhile, a Supreme Court decision in France has bucked a trend of classifying gig economy workers as employees. In July 2025, it found that drivers using a rideshare app were contractors and not employees, despite elements of the arrangement which suggested a subordinate relationship between the platform and the drivers. The court’s decision highlighted driver autonomy in choosing their own hours, deciding whether to accept rides, and setting their preferred routes as factors supporting their classification as gig workers. However, this could be challenged once France implements legislation aligning with the PWD, which presumes employment if platform control is evident.

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Social protection, contracts, and job security are driving policy changes.”

Extending protections to vulnerable workers

Many governments are extending social protections for vulnerable workers outside the scope of the PWD.

Over the last several years, Spain has seen significant increases in minimum wage pay as a way of supporting low-paid workers. This trend, which continued in 2025, has not had a major adverse impact on employment rates.

Elsewhere in the region, the United Kingdom has increased its minimum wage levels significantly over recent years, and the government is using the Employment Rights Act to extend protection for vulnerable workers dramatically. One reform will effectively ban zero-hours contracts by requiring employers to offer guaranteed-hours contracts to qualifying workers. Although the rule is not expected to take effect until 2027 and its precise scope remains unclear, it aims to give vulnerable workers more stable working arrangements if they want them. It should also make it easier for them to establish that they are employees, with the full range of employment rights. The government has promised to consult on how to simplify the tests for employment status and improve protections for the genuinely self-employed.

Developments in many jurisdictions in Asia also reflect the global trend toward protecting vulnerable workers. In Hong Kong, changes to the meaning of a continuous contract mean that some vulnerable workers (including part-time staff and those on flexible contracts) will be able to acquire statutory rights. More specifically, if a person has been continuously employed by the same employer for four weeks or more, and works for at least 17 hours each week, or at least 68 hours over a four-week period, they will be regarded as working on a “continuous contract” without having to work a minimum number of hours each week. The change is due to take effect on 18 January 2026.

Employment Law 2025, which was passed by the Vietnamese government on 16 June 2025 and took effect on 1 January 2026, gives vulnerable workers the right to unemployment insurance. Of particular note is that this protection is provided by the government – not employers – although employers will bear additional costs through unemployment system contributions.

In 2025, multiple Chinese authorities jointly launched the Notice of Expanding the Pilot Program of Occupational Injury Insurance for Workers in New Forms of Employment, which expands the pilot program to better protect the occupational injury rights of workers in new forms of employment (such as delivery workers and ride-hailing drivers) and promotes the healthy development of the platform economy. By 2026, the program will be expanded to all provincial-level regions across the country and generally all platform companies in the ride-hailing, rapid delivery, and intra-city freight sectors. By 2027, the initiative could include platform companies in other industries.

Launched in July 2022, the trial program has seen over 12.3 million workers in relatively new forms of employment covered by occupational injury insurance, providing them with critical protections should they experience a severe workplace accident. In addition to governmental initiatives, judicial practice also reflects a trend of protecting vulnerable workers. In practice, Chinese courts have increasingly recognized the imbalance in labor relations in new forms of employment and prioritized vulnerable workers’ rights in disputes.

While Singapore did not introduce new legislation protecting vulnerable workers in 2025, it did see cases testing the boundaries of the recent Platform Workers Act, which was passed in 2024 and came into effect on 1 January 2025. The law grants gig workers benefits including collective representation on issues such as health and safety, grievances, and work injury compensation. Those who are Singapore citizens or permanent residents also benefit from the Central Provident Fund (CPF), a social security savings scheme designed to pay for retirement, health care, and housing. The legislation requires platforms to deduct a portion of their gig workers’ earnings and contribute that money – along with their own contributions – to the workers’ CPF accounts, and to insure workers in case of incapacity from a work injury.

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While Europe tightens protections, the United States is loosening them.”

Shifting labor policies in the United States

While much of the world is extending vulnerable worker protections, the United States appears to be moving slightly in the opposite direction. The Department of Labor has revised its approach to worker classification, making it easier for individuals to be deemed independent contractors after pausing enforcement of a 2024 Biden-era rule that imposed stricter criteria. Some state jurisdictions, including California, are maintaining the stricter standard for classifying a worker as a contractor, and employers should be aware that if they are deemed to have misclassified a worker as a contractor instead of an employee, penalties and back taxes can be severe.

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