EXTENDED SUMMARY

The rapid expansion of digital platform work is reshaping traditional labour relations, bringing unprecedented flexibility but also creating new occupational health and safety (OHS) challenges that existing legal frameworks often fail to address. This study identifies the main OHS risks in platform work and evaluates possible solutions within the framework of the EU Directive 2024/2831 and comparative legal examples. It analyses both normative regulations and practical challenges, discussing legal tools to ensure that platform workers in Türkiye can work under safe and healthy conditions.

Platform workers face various physical and psychosocial risks that differ according to the nature and organisation of their work. Some risks are not new and resemble those found in other atypical forms of employment. However, the structural features of platform-based work often exacerbate these risks, while certain OHS hazards are unique to platform work. Algorithmic management emerges as a specific source of OHS risk. Research shows a direct link between the level of algorithmic control and the increase in occupational risks. Continuous monitoring, privacy violations, increased workload, loss of autonomy, bias and discrimination, and the complexity and opacity of processes are prominent risk factors, with psychosocial risks being the most intensified. Given these unique dynamics, both the risks and protection mechanisms should be assessed in light of the structural and technological features of platform work.

Uncertainty regarding the legal status of platform workers creates ambiguity over OHS responsibility. In many countries, including Türkiye, OHS legislation mainly applies to dependent employees with worker status. However, a significant portion of platform workers are classified as self-employed, leaving them outside the protection of the OHS system and placing legal and financial responsibility for OHS risks directly on the worker. Some countries address this issue through a presumption of employment, while others focus on improving protection for the self-employed. The country examples analysed reveal varying strategies: clarifying legal status and responsibility, limiting working hours, introducing training and awareness obligations, strengthening OHS through collective bargaining and union representation, and restricting and increasing transparency in algorithmic management.

EU Directive 2024/2831 is the first EU-level regulation specifically addressing the impact of automated systems on OHS in digital platforms. It obliges platforms acting as employers to conduct risk assessments covering not only occupational accidents but also psychosocial and ergonomic risks, and to take preventive measures. The use of algorithmic systems that threaten workers’ physical and mental health or impose excessive pressure is prohibited. However, the Directive covers only those working under an employment contract and lacks a clear definition of psychosocial risks. It also emphasises the need for stronger inspection and enforcement mechanisms, highlighting the importance of inspection capacity capable of understanding algorithmic systems. Despite its limitations, the Directive provides useful guidance for Türkiye.

In Türkiye, digital platform work is becoming increasingly widespread, yet there is still no comprehensive legal framework regulating this form of work. The absence of court decisions that thoroughly assess the legal status of platform workers leaves a significant gap. In one of the few cases, the relationship between a platform company (Uber) and a driver was classified as commercial, not employment. When working as independent contractors, platform workers fall outside the scope of OHS Law No. 6331. As in many other countries, problems in the transport and delivery sectors are most visible, with workers often engaged under a “tradesperson-courier” model as self-employed. In 2025, legislative amendments were introduced to address these issues, adopting an approach similar to comparative examples by granting couriers protective provisions regardless of status. Measures include registering couriers, requiring platforms to record their working hours, providing protective equipment, and monitoring its use. Introducing limits on daily working hours, as seen in other jurisdictions, would also be beneficial.

While algorithm-driven decision-making and digital monitoring systems increase risks, they can also be transformed into preventive tools if designed with OHS in mind. This requires shifting algorithmic management from a purely speed and efficiency-oriented approach to one that integrates safety considerations. While Europe is moving towards specific regulations in this area, similar needs exist in Türkiye.

Self-employed platform workers do not have the authority to organise work or prevent risks, making it essential to clearly assign responsibility for OHS measures to the platforms. Therefore, OHS obligations should apply regardless of employment status. Some countries have already extended such obligations to all workers in location-based digital platforms. ILO Recommendation No. 164 also supports similar protective measures for the self-employed, and the 2025 Turkish regulations for platform couriers reflect this approach.