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Platform-based work has experienced remarkable growth and is becoming a significant part of the global labour market. Digital platforms — from delivery services to online freelancing marketplaces — provide rapid access to work for hundreds of millions of people worldwide, yet often fail to offer traditional employment protections. According to a World Bank report, the number of workers active on online gig platforms worldwide is estimated to be between 154 and 435 million people. This estimate includes both those for whom platform work is their main source of income and those who use it to supplement their earnings. Platform work thus accounts for 4.4–12.5 percent of the global workforce.
According to the International Labour Organization, 95 percent of investment in platforms goes to those providing ride-hailing and delivery services in G20 countries. Platforms are transforming the organization of work: algorithmic task allocation, rating systems, and performance-based pay are creating a new model of flexible employment that both expands access to income and increases workers’ vulnerability, while existing regulatory frameworks have yet to adapt.
In Kyrgyzstan, digital platforms have long ceased to be a niche phenomenon. Drivers, couriers, online order fulfilment workers, and freelancers all use them to earn a living. The COVID-19 pandemic significantly accelerated these trends. For some, platform work provides a source of extra income, while for others, it is their primary source of earnings. Thanks to very low barriers to entry, relatively flexible working hours, and the ability to combine the work with other jobs or studies, platform work has become an attractive option, including for socially vulnerable groups such as young people who lack work experience, women with children, foreign migrants, and those who find it difficult to integrate into the formal labour market. However, as these services expand, an increasingly pressing question arises: who protects these workers if their labour has already become an integral part of the economy, yet their rights remain ill-defined?
Kyrgyzstan is a small country in Central Asia where the labour market is characterized by a high proportion of informal employment. In many sectors, people work without a formal contract, without adequate social protections, and without effective means of protecting their rights. Against this backdrop, platform work has not created problems that are entirely new, but has rather become embedded in, and exacerbated the problems in a system that was already vulnerable. This is precisely why discussions about the gig economy in Kyrgyzstan are not centred around technology, but rather around inequality, justice, and the future of work.
How Big Is Kyrgyzstan's Gig Economy?
According to data from the National Statistical Committee of the Kyrgyz Republic, in 2023 around 1.8 million people in the country’s workforce were employed in the informal sector (66 percent), while a further 628,000 were self-employed (24 percent). At the same time, regular employment is precarious: 35 percent of these workers are employed through verbal agreements without formal documentation, and a further 18 percent are working as contractors. In other words, more than half are already operating within a framework of weakened protections.
Another important factor is the scale of the informal economy. In 2023, employment in the informal sector accounted for 66 percent of the total employment in Kyrgyzstan. As a result, the majority of the working-age population lacks access to social insurance, pension benefits, and legal protections of labour rights. For example, according to a study by the International Labour Organization, 83 percent of taxi drivers reported that their employers did not make social security contributions based on their full earnings. By integrating into this existing system, digital platforms often reproduce the same vulnerabilities — offering income with virtually no stability or protections.
More than half of all workers are already operating within a framework of weakened protections.
The scale of platform-based employment in Kyrgyzstan is difficult to assess, as official statistics do not distinguish it as a separate category, and the platforms themselves disclose only limited data. Both global platforms (e.g. Yandex Go, Glovo, InDrive, Airbnb) and local services (Navi, Lalafo) are active in the Kyrgyz labour market. For example, according to Yandex Go, in 2024 more than 82,000 drivers and couriers received income monthly via their platform. In 2023, the Glovo platform reported having more than 1,000 active couriers in Kyrgyzstan.
There is also a smaller segment of online freelancing marketplaces (Weblancer, Freelance.ru, Upwork, Freelancer, Guru). For instance, a study by the European Training Foundation on the six most popular online freelancing platforms revealed 2,881 registered users from Kyrgyzstan. These figures are significantly lower than location-based platform work — such as delivery and ride-hailing services — which dominates urban services.
Thus, the growth of platform employment in Kyrgyzstan is taking place against a backdrop of high levels of self-employment and informal employment, as well as structural unemployment among young people and women. In these circumstances, digital platforms are not merely becoming a technological innovation, but a mechanism through which vulnerable groups can adapt to the limited opportunities of the formal labour market.
Platform Workers are Taxed, But Legally Invisible
Proponents of the gig economy often talk about freedom of choice and flexibility. Indeed, for many, it provides an opportunity to earn money quickly, combine several types of work, or fit work around studies and family responsibilities. But this flexibility has a downside. In practice, workers are often dependent on algorithms, ratings, the availability of orders, the platform’s internal rules, and digital sanctions over which they have no control and which they do not always understand. Although they may be formally classed as independent contractors, in reality their income, workload, and access to work are determined by a system whose rules they cannot negotiate. This is one of the key features of platform work: it appears to offer freedom, but often results in a form of dependency without the protections usually associated with employment.
In Kyrgyzstan, the state has taken a first step towards recognizing this new reality. One of its most recent decisions has been the introduction of mandatory payments for taxi drivers and delivery workers: one percent income tax and a one percent social security contribution calculated on the income they earn through digital platforms and automatically withheld and transferred by the aggregators (platforms) to the state budget. This step is significant in itself. It shows that the state can no longer ignore platform-based employment. But does it mean that platform workers have now been legally incorporated into the existing system?
The legal analysis presented in this article shows that Kyrgyz legislation still lacks a clear definition of the platform worker as a distinct category. Such workers are already mentioned in the tax framework, but their status remains undefined under labour law: a platform worker is neither a full-time employee nor a fully independent contractor. This uncertainty leads to limited access to social protections. This means that a person may contribute to the system but not have guaranteed access to the rights that are typical in standard employment: holiday leave, sick pay, health and safety protections, regulation of working hours, proper dispute resolution mechanisms, and collective representation (trade union membership).
Legal protection is asymmetrical — there are obligations, but virtually no protections.
Issues relating to algorithmic management are also left unaddressed in Kyrgyz legislation. For many platform workers, it is the algorithm that determines their working conditions: who receives an order, how ratings are calculated, in which circumstances a worker may be deprioritized, the logic behind how earnings are calculated, and at what point access to work may be completely removed. As there are no legal requirements for algorithm transparency, no established right for workers to receive an explanation of digital decisions, and no explicit provisions protecting workers against algorithmic discrimination, workers become dependent on a system they cannot see or challenge. For the digital economy, this is one of the most sensitive areas, because vulnerability here stems not only from the absence of a contract but also from the lack of transparency in management.
Kyrgyzstan has thus opted for a path of “minimal inclusion”: it has not defined the legal status of platform workers in the Labour Code, but has introduced the term into the Tax Code, along with an obligation to pay taxes and contributions. Consequently, legal protection is asymmetrical — there are obligations, but virtually no protections. The result is the legalization of vulnerability, where the state receives revenue for the budget, but the workers themselves are left without a proper social safety net. Therefore, the main challenge remains how to integrate platform workers into the employment system without undermining the principles of social justice.
How Other Countries Are Regulating Gig Work
Kyrgyzstan is, of course, not alone in this debate. In 2024, for example, the European Union adopted the Platform Work Directive, aimed at improving working conditions for people working via digital platforms. A key element of the directive is the presumption of employment: if a platform controls the work process, for example through algorithms, ratings, and the allocation of orders, then the worker is automatically considered to be an employee. This removes the burden of proving employment status and grants access to full social protections, including paid leave, sick pay, and pension contributions. Furthermore, the EU has introduced rules regarding algorithmic governance, including a ban on discrimination, the right to an explanation of decisions, and requirements for the transparency of digital interfaces. Another important element is the obligation to provide national authorities access to data on the number of workers and their status.
Approaches vary on a national level, but the direction of movement is similar. Spain has recognized couriers working via platforms as employees and has demanded greater transparency regarding algorithms. In France, elements of social partnership and worker representation for platform workers are being developed to partially offset the vulnerability of these workers. In the UK, case law has created an interim category of “worker”, entitling them to the minimum wage, holiday pay, and pension contributions. In this way, a comparative analysis of international practices shows that effective and sustainable protections for digital platform workers require a systematic approach, including the legal recognition of their employment status, the shifting of responsibility for social protections from the worker to the platform, the regulation of algorithmic management, and the safeguarding of collective rights.
Four Steps Kyrgyzstan Needs to Take Now
These examples are important not because Kyrgyzstan can simply copy any of these models, but because they illustrate a general principle: sustainable regulation begins when the state stops viewing platform work as merely a convenient form of part-time work and recognizes that behind the digital interface lie very real relationships of dependency. For Kyrgyzstan, this means that the next step must be institutional rather than fiscal.
Firstly, the legal status of digital platform workers must be defined in the country’s Labour Code. This is a key step towards eliminating legal uncertainty and protecting the basic labour rights of platform workers. The absence of such a status means that those employed in the digital economy effectively remain outside the scope of labour legislation and social protection, which exacerbates the scale of informal employment and social inequality.
Secondly, introducing the presumption of an employment relationship where algorithmic control is present should be considered. This would ensure automatic recognition of the employment status of digital platform workers if the platform controls the work process (order allocation, rating system, working hours). At the same time, this would help extend the coverage of employment protections and reduce legal uncertainty.
We need a discussion about how to protect people in an economy where the employer is increasingly being replaced by an app.
Thirdly, a mechanism for enforcing transparency in algorithms and digital management should be developed. Introducing requirements for platforms to disclose the principles of algorithmic task allocation, ratings, and sanctions, as well as ensuring the right of workers to an explanation of decisions, will significantly help to reduce the risks of digital discrimination, increase trust in platforms, and ensure fair working conditions.
Last but not least, the state needs data on the gig economy. In other words, a system for monitoring and providing data on platform work must be established (a national study on the scale of platform work and social protection coverage could be conducted). This will provide reliable data for policymaking, risk assessment, and monitoring the effectiveness of reforms.
Platform-based work in Kyrgyzstan has already become part of the new economy. The question is no longer about whether to acknowledge its existence, but what form this new model will take. If the current model is retained, the country risks perpetuating a situation in which digital work expands faster than the rights of those engaged in it. However, another path is possible: one that recognizes that flexibility should not mean a lack of rights, and that digital intermediation does not negate social responsibility. Then the debate about platforms will no longer be a discussion about technology per se, but a discussion about how to protect people in an economy where the employer is increasingly being replaced by an app.
Translated by Charlotte Bull & Rowan Coupland for Gegensatz Translation Collective
