HSI-Schriftenreihe

A comparative law perspective: Crowdwork

As the world becomes increasingly digitalized, we are confronted with new, often disruptive, business models also leading to new forms of labour. One feature of this development is the dual phenomenon of crowdsourcing and crowdworking, which spans the whole value-chain of the economy and represents a global labour market. The working conditions in this sector cannot be ignored, because they have a great impact on the situation of established employees, on the competition between crowdworkers, and on the sustainability of the systems of social security.

Although it is too soon to give a final assessment of this emerging workplace,we can be sure it will have a significant influence on the labour market, including (labour) law institutions. Against this background the HSI decided to have a closer look at the factual and legal developments crowdsourcing has brought about in three major legal landscapes. We are very happy and grateful to have
found three high-ranking legal experts to fulfill this task. The findings in this study can be seen as a preliminary evaluation of the dynamic and erratic developments in the "platform economy".

Crowdworkers work under very different arrangements (as our authors show), and each case presents a slightly different employment picture, some crowdworkers perhaps amounting to employees, others more like selfemployed contractors (and others somewhere in between). But because few crowdworkers currently enjoy social protections, this study also offers a broad
variety of legislative options that could work to address such shortcomings within several legal systems.