According to CESI, the following priorities should be considered by an EU policy measure:

• To provide platform workers with adequate protection, four targets are crucial: a precise and fair classification of the type of work and employment, access to adequate social protection, the provision of decent working conditions, and access to information to reduce the information asymmetry between the platform and the worker. In particular, the establishment of new rights related to algorithmic management is a prerequisite for fair working conditions including in the platform economy.
• An EU initiative must cover all people working through platforms, irrespective of their employment status.
• An EU initiative should be based on a (rebuttable) legal presumption that assumes that if platform work involves the provision of services, then the person providing the services is a regular employee.
• Regarding cross-border challenges for national administrations to verify the compliance by (transnational) platforms with existing laws and their enforcement, CESI agrees with measures to facilitate the work of the public services to ensure decent work also across borders. However, CESI believes that the most crucial challenge in this field is the enforcement and control of these policies. To ensure the enforcement, sufficient numbers of staff and adequate resources of the inspecting and controlling authorities are required, as well as further training for the concerned personnel.
• Concerning collective representation and social dialogue in the platform economy, EU action should be mainly focused on two targets: To support the representation of platform workers through the development of digital communication fora embedded in the platforms, accessible to both workers and trade unions, and to remove obstacles to the collective bargaining of the self-employed.
• In the absence of a strong and ambitious social partner agreement, to provide certainty and create binding effects, an EU initiative must take the form of a directive that will lay down binding minimum standards for all Member States. It is essential that the directive covers the whole range of platform work, without leaving anyone outside the scope of the initiative.

CESI’s full contribution is available here.