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The Road Ahead for Gig Worker Protection in Karnataka

We write to bring to your attention the key compliance requirements under the recently introduced Karnataka Platform Based Gig Workers (Social Security and Welfare) Rules, 2025. (“Rules”). The Rules must be read together with the previously notified Karnataka Platform Based Gig Workers (Social Security and Welfare) Ordinance, 2025. (“Ordinance”). The Government of Karnataka on May, 2025 had introduced the Ordinance, to make sure gig and platform workers are provided their basic welfare and social security benefits that they never had under older labour laws. It sets rules for how platform companies must contribute to a welfare fund and protect workers rights. Whereas, the Government of Karnataka has introduced the Rules on November, 2025 wherein it explain how all the provisions of the Ordiance can be practicable in real life, including how workers and aggregators must register, how the welfare money will be collected, how complaints will be handled, and what the agreegator need to do to follow the law. Now, we note that the Rules apply to: All aggregators or platforms operating in Karnataka providing any of the services mentioned in Schedule I of the Ordinance (including ride sharing, food/grocery delivery, logistics, e-marketplace, professional services, healthcare, travel/hospitality, and content/media). For the purposes of the Rules, "Aggregator" means a digital intermediary for a buyer of goods or user of a service to connect with the seller or the service provider, and includes any entity that coordinates with one or more aggregators for providing the services; “Board” means the Karnataka platform based Gig Workers Welfare Board; "Platform" means any arrangement providing a service through electronic means, at the request of a recipient of the service, involving the organization 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; and The Rules further apply to all Gig Workers registered with the Board. “Gig Worker” means a person who performs work or participates in a work arrangement that results in a given rate of payment, based on terms and conditions laid down in such contract and includes all piece-rate work, and whose work is sourced through a platform, in the services specified in the Schedule of the Ordinance. Set out below is a consolidated overview of the key obligations applicable to Aggregators and Platforms under the Rules and the Ordinance. As an Aggregator/Platform, the following obligations are applicable: Registration of the Aggregator or Platform (Section 11 r/w Rule 7): Every Aggregator or Platform operating in the State of Karnataka must register with the Board within forty-five (45) days from date of commencement of the Ordinance as per Section 11 of the Ordinance. Registration is to be effected on the Board's web portal with specified information that includes the name, authorized person, address, email, PAN, GST, CIN. Only a single registration is required where the Aggregator or Platform runs multiple platforms. If a registered legal entity starts a new platform or takes over an existing one, notify the Board within thirty (30) working days of commencement of operations. If an Aggregator or Platform operates across multiple sectors (like ride-hailing, food delivery, logistics, or home services), it must separately report data for each sector, such as the number of Gig Workers and payout structures and must also deposit the welfare fee for each sector individually as per Rule 18(1). Gig Worker Database (Section 10 r/w Rule 8): Provide the Board with a database of all Gig Workers onboard or registered with the Platform/Aggregator. The database must be submitted on the digital portal in a machine-readable format. Platform/Aggregator must update the Board within seven (7) days about any change in the number of Gig Workers, including new additions and separations during the reporting period. All data transfers must utilize secure transport layer security (TLS) encryption or such encryption standards as specified by the Board. The Platform/Aggregator can apply in writing to the Board for an extension of thirty (30) days explaining challenges faced for compliance. Platform/Aggregator shall include the following data for each of the Gig Workers as provided by the Gig Workers during on boarding or registration (the name, date of birth, gender, registered mobile number, aadhar number, primary operating city, aadhar linked bank account, UAN number as generated on the e-Shram portal (if available) and any other data required. All data of the Gig Workers shall be used by the Board as per the provisions of the Digital Personal Data Protection Act, 2023. Automated monitoring and decision-making system (Rule 10) Platform/Aggregator shall publish a designated mechanism on its platform to enable the platform-based Gig Workers to reach out to them seeking information regarding the fares, earnings and customer feedback which may have an impact on the Gig Workers. Right to redressal of grievances by the Gig Workers (Section 22 r/w Rule 11) Any Gig Workers in relation to any violation regarding payouts, deductions etc by the Aggregator or Platform, may file their grievance with the internal dispute resolution committee of the Aggregator or Platform along with the supporting documents and information within a period of seven (7) working days from the receipt of intimation about any violations as mentioned under Section 22(2) of the Ordinance. The Aggregator or Platform shall, through the internal dispute resolution committee, make an endeavor to resolve the matter within fifteen (15) working days. Any Gig Worker dissatisfied with the final decision made by the internal committee, may file an appeal, along with all supporting documents, within thirty (30) days before the authority designated by the Board. An Aggregator or Platform may immediately terminate a Gig Worker, in the interest of customers and public safety, for offences under Chapters V and VI of the Bharatiya Nyaya Sanhita, 2023, for material or financial fraud, or for any other offences specified by the Board Safe and Healthy Working Environment (Section 16 r/w Rule 12): Aggregator or Platform shall include access to safety guidance and panic button options on their applications wherever applicable and ensure other safe working environments for the Gig Workers. Aggregator or Platform must comply with sector-specific occupational safety and health standards that the Board may prescribe via by-laws, within three (3) months from the publication of such by-laws. Aggregator or Platform must also offer information and training on occupational hazards, safe work practices, first-aid guidance, and emergency helpline numbers. Complaints of sexual harassment involving women must be handled as per the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, Publication of information (Rule 13): Aggregator or Platform must make information about their grievance-redressal mechanism easily accessible to all platform-based Gig Workers on their digital platform. Such disclosures must cover instant grievance handling, insurance and welfare schemes, welfare fee deductions, termination and deactivation procedures, accident-related support including contacting legal heirs, and handling complaints of physical harassment. All disclosures must be provided in Kannada, English, and any other language from the 8th schedule of the Constitution preferred by the Gig Workers. All such information must be written in clear, simple language, avoiding technical or legal jargon. Welfare Fee (Section 20 r/w Rule 17 and 18): Within five (5) working days after each quarter, the Aggregator or Platform must automatically calculate and self-declare the welfare fee based on each transaction with the Gig Workers in a standard format and pay it at government-notified rates, excluding settled payments. (Settled payments means any tips, ex-gratia/event based/special payment(s) including referral fees, incentives and other similar payments). The Aggregator shall, on a quarterly basis, electronically remit the welfare fee through any RBI-approved banking mode. If an Aggregator or Platform pays an excess welfare fee, it can apply for a refund within ninety (90) days. If the Board’s finance section finds any short payment during reconciliation, it will issue a show-cause notice requiring the Aggregator or Platform to pay the deficit within a specified time. Reconciliation of welfare fee (Rule 19): The Board may review and reconcile the welfare fee if an Aggregator or Platform is required to pay similar contributions under any other applicable law in Karnataka. Any welfare fee already paid by the Aggregator or Platform to Karnataka or the Government of India will be offset against the amount payable under this Rules and Ordinance on a quarterly basis. The Aggregator or Platform must upload the reconciliation details on the Payment and Welfare Fee Verification System (PWFVS) system, and after verification by the Board’s auditor, the Board will adjust or refund the amount within ninety (90) days of the request. Payment and Welfare Fee Verification System (PWFVS) (Section 21 r/w Rule 20): Every Aggregator or Platform must record payout details and related welfare fee deductions and upload this data in a machine-readable format to the Board’s designated verification system within seven (7) days. Returns must include a unique ID of the Gig Worker, e-Shram UAN (if applicable), payout amount, welfare fee remitted, date of transaction and platform identifier. Every Aggregator or Platform must also reconcile and upload the data by the end of every month. Composition of the Internal Dispute Resolution Committee (IRDC) (Rule 21): Every registered Aggregator or Platform must set up an Internal Dispute Resolution Committee (IDRC) consisting of one (1) chairperson (senior management level), two (2) management personnel, at least three (3) senior Gig Workers, at least two members must be women, and an additional (IRDC) may be formed for other units or branches as needed. The Aggregator or Platform must ensure the IDRC functions as required under Section 22(2) of the Ordinance for grievance redressal. The IDRC must receive all gig-worker grievances submitted through the official portal, and in some cases, through a human point of contact. The IDRC must publish details of its grievance-redressal procedures on the portal and hold regular meetings to resolve gig-worker grievances. All IDRC decisions must be written, follow principles of natural justice, and aim for amicable resolution. Resolving of Petition (Rule 22): After receiving a grievance, the IDRC will review it and may ask the Gig Worker for additional documents or clarifications, which must be provided within seven (7) days. The IDRC must issue a written action-taken report to the complainant within fourteen (14) days and pass a final order on the grievance within forty-five (45) days. Disposal of petition by the Grievance Redressal Officer and its Appeal (Rule 23): A registered Gig Worker can file a grievance in the prescribed format, either in person, via the web portal, or any other mode, regarding entitlements, social security payments, or other benefits under the Ordinance. The grievance redressal officer (as notified by the state government) will review and resolve such grievances, whether filed directly by the Gig Worker or referred by the Aggregator or Platform, within the time frame specified under the Karnataka Sakala Services Act, 2011. Penalty for delayed payment of welfare fund (Rule 25): Aggregator or Platform are liable to pay interest on any delayed payment of the welfare fee if they fail to pay as required under sub-rule 2 of Rule 17. Exception: No interest is payable if the delay is caused by a technical failure of the Payment and Welfare Fee Verification System within the extended period of another thirty (30) days Penalty for general contravention of the Ordinance or this Rule (Rule 28): If an Aggregator or Platform contravenes the provisions of the Ordinance or Rules, the Board will issue a notice regarding the violation. The Board will then pass an order imposing a fine under Section 23(2) of the Ordinance, after giving the Aggregator or Platform an opportunity to be heard. Fines must be deposited into the Board’s account within thirty (30) days of the order. Any aggrieved Aggregator or Platform may seek reconsideration from the State Government within thirty (30) days of receiving the Board’s order. The State Government will consider the appeal and pass an appropriate order. Quarterly Returns (Section 24 r/w Rule 29): Aggregators or Platforms must submit quarterly returns to the Board under Section 24 of the Ordinance by uploading them electronically in machine-readable format on the designated portal within thirty (30) working days from the end of each quarter, using Form ‘A’. Conclusion: Thereby, the Ordinance and the Rules are now final and apply to all Aggregators, Platforms, and Gig Workers (as defined above). With this, a proper system is finally in place that recognises Gig Workers and their basic needs. It ensures that Platforms and Aggregators cannot take advantage of Gig Workers simply because there is no formal employer–employee relationship. Together, the Ordinance and the Rules aim to create a fairer, safer, and more secure working environment for everyone in the gig economy.This note is intended to serve as a high-level summary of the Karnataka Platform Based Gig Workers (Social Security and Welfare) Rules, 2025, and the corresponding provisions of the Karnataka Platform Based Gig Workers (Social Security and Welfare) Ordinance, 2025, from the perspective of Aggregators and Platforms. It does not constitute a comprehensive analysis or legal opinion, and specific obligations may vary depending on the business model and sectoral classifications of individual entities.
Saga Legal - December 11 2025
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