C.2What Kind of Worker Is a Hawker?

The gig-worker premise is half right. Hawkers depend on a single gatekeeper for access to their market, as gig workers do. But they also carry fixed costs, stock and business risk that no gig worker carries.

The ILO's 2018 classification of status in employment has a category for this middle ground: dependent contractors – workers on commercial, not employment, terms who depend on another unit for "organization and execution of the work, income, or for access to the market". The ILO (International Labour Organization) is explicit that the controlling unit can be a government. For most hawkers, that unit is NEA (National Environment Agency, which runs the public hawker centres), or an operator NEA appoints.

C.2 What Kind of Worker Is a Hawker?: table 1
Criterion	Gig / platform worker	Entrepreneur (SME owner)	Hawker in a public centre
Who controls market access	The app	The owner	NEA: a 36-month tenancy, renewal on NEA's terms, no compensation on non-renewal (cl.30, cl.37)
Can the work be delegated	For some platforms	Fully	Barely: must personally operate at least 4 hours a business day and cannot leave the stall to assistants (cl.35); NEA may approve a joint operator, a citizen or PR working his own hours, or a nominee during illness
Who can help	Anyone	Any hire, incl. foreign workers	Citizens, PRs and some long-term visit pass holders only; no work-pass staff
What is sold	Set by the platform	Owner's choice	The food type declared in the bid (cl.19)
Who sets the price	The platform	The owner	The hawker at NEA centres; in operator-run centres, value-meal price changes need approval
Fixed costs and stock at risk	Vehicle only	Yes	Yes: raw materials 56% and manpower 20% of operating costs; rent under 10% (NEA, 2022)
Can it scale	No	Yes	At most two cooked-food stalls (cl.22)
Is there a sellable asset	No	Yes: the business	No: subletting and assignment banned (cl.36); the 1994–97 sale-scheme leases ran out in 2014–17
What happens on a breach	Deactivation	Contract dispute	Termination: about 230 notices for not operating personally, 2012–2024

The Act's own test, and where it leaves the hawker

The Government drew its own line, and it deserves to be stated fairly. The Advisory Committee on Platform Workers kept riders self-employed and added protections only where a company exerts "a significant level of management control", judged on three factors: "data-driven, algorithmic matching of demand and supply of services"; "effectively determining or setting upper limits on price and remuneration"; and "controlling and directing the performance of work" (report, Nov 2022, ¶3.6.2). It left street-hail taxi companies out, because they "do not play a role in matching the taxi driver to the customer" (¶3.6.4), and it set platform workers apart from typical self-employed people because they cannot set their prices or "build their own clientele" (¶3.2.8). The Act followed: MOM's test needs an operator's automated use of data to decide the work, and a restriction on how it is done.

By that test a hawker at an NEA centre is not a platform worker. No algorithm matches his customers; he sets his own price; he builds his own regulars. The resemblance is closest at the operator-run centres, where a value meal is required at every stall, a change to its price needs approval, and fines are written into the contract: the second and third factors met in part, the first not at all. So I argue by analogy, not by statute. The State is the hawker's gatekeeper in a different way from an app, and the floor should follow the dependence, not the algorithm. Granted, the Government's answer is that hawkers enter their terms "voluntarily and knowingly" (Dr Amy Khor, Official Report, 19 Nov 2018). Yet MOM's own test of employment, given the same day, asks whether a worker must "comply with prescribed procedures, follow a fixed schedule, and carry out the work without getting a replacement" (written answer to PQ 86, 19 Nov 2018). A tenancy asks for a version of each: its conditions, minimum hours, and personal operation. I do not say hawkers are employees, or platform workers. I say the terms they cannot negotiate are the very ones MOM (Ministry of Manpower) counts.

Operator-run centres sharpen the resemblance to a platform. There, operators may require stalls to open up to 5 days a week and 8 hours a day, a ceiling NEA set in November 2018, require value meals for 5–20% of sales, and – in one published contract – take 15% of gross turnover. That contract, at Yishun Park in August 2025, also set a $1,750 minimum, a compulsory point-of-sale system and 18 categories of $100 fines (The Online Citizen, 15 Sep 2026). That is a revenue share set by an intermediary: the platform model. Its operator has since left the centre, when its tenure ended in July 2026, and One Punggol's operator left in August 2026, a year early; neither exit has been publicly tied to the scrutiny (The Online Citizen, 15 Sep 2026). Cooked-food stalls in these centres ended tenancies early at 8% a year, against 3% in NEA-run centres (2019–2023).

The real platforms treat hawkers as merchants, not workers. GrabFood publishes a service fee of 30% on every order, plus GST (goods and services tax), and since Deliveroo went offline in Singapore after 4 March 2026 a hawker has fewer apps to choose between. Yet the Platform Workers Act protects only the rider who carries the food – not the hawker who cooked it.