Comparing institutional models of platform employment regulation: the EU, the USA, and Russia cases

Abstract

A comparative analysis of institutional models of platform employment regulation in the EU, the USA, and Russia is carried out. The relevance of the research topic is due to the rapid spread of digital platforms and the transformation of traditional labor relations under the influence of economy digitalization. Based on the neo-institutional approach and the structural decomposition of the models by key elements (legal status of employees, social protection, fiscal architecture, the role of platforms, and control mechanisms), systemic differences in national regulatory trajectories are identified. 

The research paper shows that the EU forms a proactive and inclusive model focused on the integration of platform labor into the system of labor law and social protection. The USA implements a liberally fragmented structure with a predominance of contractor status and decentralized regulation at the state level. Russia is developing a platform-based fiscal model based on digital administration and income legalization through self-employment. It is established that the differences between the models are determined not only by the peculiarities of legal regulation, but also by the historically formed institutional trajectories of the labor market and social policy. 

The author concludes that it is necessary to form a balanced regulatory strategy combining technological flexibility, institutional stability and social protection of platform employees.