Comparative policy analysis reveals structural limits to adopting European platform protections in Southeast Asia, suggesting targeted disclosure and oversight reforms are more feasible.
The rapid expansion of platform-based gig work not only exposes structural gaps in existing employment protection systems but also deepens workers’ precariousness. This study focuses on Thailand and Malaysia to examine how far the European Union Platform Work Directive could strengthen the protection for platform workers within Southeast Asia. It develops a Platform Labour Dual Exclusion framework to investigate five connected forms of exclusion: labour market structure, regulatory exclusion, technological domination, reproduction mechanisms, and workers’ collective demands. It operationalises these using observation indicators and applicability criteria. The analysis is based primarily on legislation, court decisions, policy documents, government reports, and other published sources, supplemented by interviews with scholars and policy specialists. The findings show that both countries lack the legal and administrative conditions needed to adopt the Directive’s provisions on employment status and automated decision-making in full. Requirements concerning information disclosure, reporting, and oversight could be adapted more readily, although their effectiveness would depend on enforcement capacity and access to platform data. It is suggested that the Directive should be used as a reference point for identifying which protections could be implemented within different national institutions.
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Yosuke Uchiyama (2026) studied this question.
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