Delhi recorded temperatures above 49°C several times in the preceding years. Government advisories urged people to stay indoors during the hottest hours of the day. For thousands of food delivery riders and cab drivers, however, staying indoors was never an option. Logging off meant losing income, forfeiting incentives and, in some cases, risking lower platform ratings.
The contrast exposes a deeper governance gap. Delhi’s climate policies recognise extreme heat as a public health emergency, while labour laws acknowledge the existence of gig workers. Yet neither framework protects workers when climate risk and platform work intersect. Gig workers remain trapped in a regulatory gap where no institution has a clear mandate to safeguard them from heat-related occupational risks.
Two Systems, No Protection
The roots of this governance gap lie in the way India’s regulatory institutions have evolved. Heat Action Plans were designed primarily as public health instruments, relying on advisories, early warning systems and emergency responses to protect vulnerable populations. Labour laws, meanwhile, were built around conventional employer-employee relationships. Platform work falls outside the assumptions on which both frameworks were built because digital platforms classify workers as independent contractors rather than employees, while climate policies stop short of imposing enforceable obligations on platform companies.
Platform workers sit at the intersection of two regulatory systems: one governs climate risk and the other governs work. Because neither was designed for digitally mediated labour, responsibility falls between them. The result is that climate and labour institutions operate in parallel, leaving no institution clearly responsible for protecting workers from heat-related occupational risks.
The Regulatory Blind Spot
The consequences extend beyond rising temperatures. Digital platforms govern workers through algorithms that allocate orders, determine incentives and influence earnings. During periods of peak demand, which often coincide with the hottest hours of the day, surge incentives encourage workers to remain on the road. At the same time, rejecting orders or taking extended breaks may reduce earnings or affect performance ratings. Although platform work appears flexible, these incentives substantially limit workers’ ability to prioritise their own safety.
Emerging evidence suggests these incentives already translate into measurable health risks. A 2024 survey by the Telangana Gig and Platform Workers Union and Heat Watch found that more than half of surveyed platform workers experienced heat exhaustion during summer, while nearly one-third reported symptoms consistent with heatstroke. An IDInsight study similarly found that delivery workers earn modest hourly incomes after accounting for fuel and other expenses, making time away from work economically difficult.
This institutional blind spot is becoming more consequential as the platform economy expands. India had an estimated 7.7 million gig workers in 2020-21, and this number is projected to reach 23 million by 2030. Delhi accounts for a substantial share of this workforce. As platform work expands, so does the number of workers exposed to increasingly frequent heatwaves without clear regulatory safeguards.
Protecting Workers Through Policy Design
International experience shows reforms are both practical and enforceable. Spain, for instance, treats extreme heat as an occupational safety issue by requiring employers to adopt preventive measures during periods of high temperatures. In India, the Self-Employed Women’s Association’s (SEWA’s) parametric heat insurance initiative illustrates how innovative protection mechanisms can be developed for workers operating outside conventional employment. The broader lesson is that climate adaptation becomes more effective when responsibility for worker safety is clearly assigned and backed by enforceable obligations.
The first step is for the Delhi government to bring platform companies within the implementation framework of its Heat Action Plan so that worker safety becomes an enforceable component of the city’s climate response rather than a voluntary corporate initiative.
During officially declared heatwaves, participating platforms should be required to suspend performance penalties, issue heat alerts through their applications, and provide basic safety measures such as hydration support, emergency assistance and access to cooling facilities. Occupational safety regulations should similarly establish minimum heat-safety obligations for platform companies, regardless of the contractual status of the workers they engage, ensuring that basic workplace safeguards are not determined solely by employment classification.
Yet the workers who keep cities functioning remain excluded from the systems designed to protect them. Delhi’s dependence on gig workers will only increase as urbanisation and digital platforms continue to expand. India’s next step is to establish clear regulatory responsibility for protecting platform workers during heatwaves. Until occupational heat protection becomes an explicit public responsibility rather than a voluntary corporate practice, one of India’s fastest-growing workforces will remain outside meaningful systems of workplace safety.