Ensuring Delivery Platform Work is Performed by Singaporeans and Permanent Residents Only

Mr Pritam Singh asked the Minister for Manpower (a) whether the Ministry has been tracking the number of subcontractors and foreign work pass holders that are engaged by platform companies or operators to meet surge demands or for any other reason; and (b) how does the Ministry ensure that income opportunities for local platform workers are not compromised arising from such arrangements.

Sir, only Singaporeans and Permanent Residents (PRs) can perform platform work, as the Ministry of Manpower (MOM) does not issue work passes to foreigners for platform work. Hence, it is illegal for foreigners to enter into platform work arrangements with platform operators or to impersonate local platform workers and perform platform work using their accounts.

That said, platform operators can legitimately outsource delivery jobs to third party logistics companies. These logistics companies may employ foreigners with a valid work pass and the number of foreigners is capped at the industry's Dependency Ratio Ceiling. Unlike platform workers, these foreigners cannot work for multiple platform operators and they can only work for a single employer under an employer-employee relationship. They are paid a fixed monthly salary by their parent company and are not remunerated on a per-job basis by the platform operator. MOM does not track the number of platform operators' subcontractors.

MOM follows up on every complaint received, including feedback from the National Delivery Champions Association (NDCA), and has also conducted enforcement operations at hotspots island-wide over the past months to detect and deter foreigners from performing illegal platform work. A total of 644 delivery workers were checked during these operations, of which only four foreigners, or less than 1%, were found working illegally as delivery workers. Another 22 foreigners were legitimate work pass holders.

The Platform Workers Trilateral Group has released recommendations earlier this month to stamp out illegal platform work performed by foreigners as this compromises the livelihoods of local platform workers. For instance, platform operators with reasonable suspicion of foreigners misusing platform workers' accounts are to notify MOM of such cases for investigation. Should an offence be established under the Employment of Foreign Manpower Act, the major platform operators have collectively agreed to debar the local platform worker who abetted the foreigner from their platforms for a minimum of 24 months. Platform companies that currently permanently debar offenders may continue to do so. The foreigner who performed platform work illegally is liable to a fine of up to $20,000 and imprisonment for up to two years, or both. The local who abetted the foreigner may also face the same penalties. In addition, the foreigner may also be barred from entering or working in Singapore.

To address platform workers' concerns about competition via outsourcing practices, food delivery platform operators that outsource jobs have agreed to: firstly, provide more clarity and assurance to platform workers on their outsourcing practices; secondly, encourage platform workers to head to high-demand areas to reduce the need to outsource these jobs; and thirdly, require outsourced companies to submit foreign workers' work pass documentation and conduct audits where work is outsourced through their app.

These recommendations are scoped to food delivery platform operators as outsourcing is common in the parcel delivery landscape, with platform operators outsourcing jobs to third party logistics companies and vice versa. This practice helps to efficiently consolidate demand and supply, which benefits businesses, consumers and platform workers themselves.

The Government will continue working with platform work associations, tripartite partners and platform operators to support the well-being and livelihoods of our platform workers.

Thank you, Speaker. I declare that I am the advisor to the National Trades Union Congress (NTUC)-affiliated NDCA. Mr Speaker, our delivery riders have, through the association, provided ground feedback that they see more foreigners performing delivery platform work and appreciate the ground checks and enforcement that the MOM has started to ensure that platform work remains only for Singaporeans and Singapore PRs.

I note that some platforms use fleet partners, which are business-to-business (B2B) arrangements between the platform and third party logistics operators to perform delivery in low supply areas, such as the Central Business District and Orchard Road. In such B2B contracts, delivery riders are taken on as full employees and fleet partners can employ foreigners as their employees if they have the necessary foreign manpower quotas to do so.

I ask what measures would the Ministry continue to put in place, to ensure that these fleet partners have indeed the necessary quotas to employ foreigners as delivery riders and would the Ministry also make checks to ensure that these foreign delivery riders are paid full wages by their employers and not paid on a job-by-job basis, so long as the Local Qualifying Salary is met, as this would circumvent the fact that platform gig work should be performed by only Singaporeans and PRs.

Sir, I thank the Member for her questions. Indeed, we have been working closely with NDCA to get a sense of where these hotspots may be and continue to take any enforcement actions as required.

On the first question about how we ensure that the outsourced companies are able to employ workers on legitimate quotas, I think that is part of the broader set of enforcement work that MOM does for all companies that utilises work permits.

What we work with, the platform operators – is to also ensure that when they onboard any of these outsourced workers onto their app system, for example, there are two modes of engagement. Some operators onboard some of these outsource workers, local and foreign, onto the app system. When they do so, these operators usually check whether the outsourced worker has a legitimate work permit, because they are given work passes, so this will be the background checks that the operator must do before they onboard the worker onto their system. If the company does lay off this worker, then that worker must be taken off their app system.

The other model of engagement is where there is a direct B2B outsourcing of jobs, so it could be in bulk, where they give 100 jobs away to a logistics company to decide how the company wants to allocate to their own workforce. In that situation, the company performs just like any other logistics companies that receive a bulk order of work from another third party, and they decide who among their workers would carry out this 100 jobs, because these workers are already paid a fixed monthly salary. It is up to the company, who has received those outsourced work, to decide how to allocate work amongst their workforce, whether it is local or foreign. So, that kind of enforcement actions that we take on any company that hire work permit holders will continue to be enforced, as part of MOM's regular operations.

The second question about whether the payment is through to the outsource worker is on a per job basis or not, I think that has got to do with how the outsourcing company deals with their workers. As I have said, these workers are employed on a work contract. They have an employment contract that stipulates their monthly salary. So, if the foreign workers who are supposed to be paid on contractual terms, are not paid as such, but are given on a piecemeal basis, just like a platform worker, then we have to encourage them to whistle-blow, so we will investigate whether there is a violation of contractual agreement between the outsourcing company and their employed foreign workers. Generally, the platform operators, they do not pay on a per piece basis, per job basis to the foreign workers, because it is outsourced to a company, so it is a B2B arrangement and the payment to the foreign worker, if so engaged in outsourced work, is by the parent company and not by the platform operator, so that is what we understand the landscape to be. I hope that clarifies the Member's concerns.

Thank you, Mr Speaker, and thank you to the Senior Minister of State for his replies. Sir, my questions are specific to local food delivery riders. Does the Ministry intend to track the number of foreigners who are in the food delivery space, by virtue of MOM allowing platform operators to engage third party entities to fulfil, for example, surge demands? That is one reason why MOM allows some of these companies to operate in this space, as I understand. And if so, is the Ministry intending to track these figures more closely and can it share the number of individuals in this space, compared to Singaporeans and PRs?

Secondly, I refer to the recommendations of the Platform Workers Trilateral Group that the Senior Minister of State referred to on 11 September. In one of the recommendations, it advises platform operators to conduct audits of all outsourced workers and to share the work pass documentation of outsourced workers with the Ministry, when the Ministry asks for the information. Does the Minister not believe that this recommendation may be too passive and gives the platform operators too much flexibility, in view of the highly dynamic nature of the platform space? Should platform operators not be required to submit these details more proactively, so that the Government can move swiftly to protect the livelihoods of local workers, should such submissions reveal that platform workers are getting crowded out of the marketplace, as a result of the algorithms and policies of the platform operators?

Thirdly, and finally, Mr Speaker, MOM has shared, and as the Senior Minister of State shared, that since July this year, it checked 644 platform workers in more than 30 hotspots and found that only four were working illegally. Can the Senior Minister of State share how many infringements of foreigners undertaking platform work were reported by platform workers before July, and separately, how many enforcement actions of this scale reported were carried out prior to July this year? And more generally, does the Senior Minister of State believe that MOM's enforcement capacity may need to be increased in this regard to protect the platform workers in Singapore?

Sir, I thank the Leader of Opposition for his clarification questions. On his first question on the local food delivery workers and whether we track the number of foreigners who are from the outsource companies performing this work, operationally it will be quite difficult to track the numbers, because the outsourcing of work from platform operator to a third party logistics company is a B2B arrangement, and it could be dynamic. They can change a partner or how they want to outsource the work on a month-to-month, maybe on a year-to-year basis. So, it is difficult to, at any point in time, have a very accurate sizing and it will increase a lot of administrative burdens on companies to report any change in their contractual agreements as they perform their work.

The second thing is that many of these platform operators actually also have arrangements with the outsource companies to stipulate that, where possible, the work that has been outsourced to them should be performed by Singaporeans or PRs within their company, rather than have a foreign worker engaged by them to do the work, as far as possible. But if they are actual labour constraints by the third party companies, then they may have no choice but to have some of the work to be performed by their legitimate work pass holders.

I would say, operationally, we leave it to the companies to do what is right. Also, in this food delivery scene, there are companies – restaurants, for example, fast food chains – who also legitimately employ foreigners under their work quotas to do their delivery, so I think this is a very variegated landscape. What it needs to do is to allow the companies to make some decisions that allows efficiency of service, that brings benefits both to the company and to the consumers, so that the actual services can be delivered in a timely fashion as far as food orders are concerned.

In terms of the second question about outsourcing, Speaker, Sir, if you do not mind, can Mr Singh restate that question, because it was a long question.

Obliged, Mr Speaker. My second question was specific to one of the recommendations of the Platform Workers Trilateral Group, which advised platform operators to conduct audits of all outsourced workers and to share the work pass documentation of outsourced workers with the Ministry.

I do not mean to add on to this question, but in view of the Senior Minister of State's reply, because of these submission requirements or tracking requirements, does the Minister not agree that it would be possible to have some sense of how many foreigners are operating in this space, since the Platform Workers Trilateral Group does envisage the submission of details, which can reflect what is the footprint of foreigners in this space?

Sir, I thank the Member for his clarification. I understand where he is coming from. I think that what we want to achieve, at the end of the day, is to make sure that those who are participating in platform work are Singaporeans and PRs. As little as possible, in fact, we should try and deter as many of these foreigners from doing so illegally, so there are various ways to do this. We could do it in a way that imposes a lot of onerous demands on companies and workers, or we could do in a way that solves the problem without increasing the burden on the stakeholders.

One of the ways in which our recommendation works is to ask the operators now to go more upstream and do facial verification of workers who are engaging in platform work. As they turn on the apps, as many of the operators do require this, at the onboarding stage when the person signs on to an account, to have facial verification and the identity, so that we know that the account actually belongs to someone with a proper reason to hold the account, a Singaporean or a PR.

And subsequently, on receiving orders for the day, that means when they start the shift for the day, having had the account when they start the shift, there is usually a verification of facial features to make sure that the account holder and the face matches, and there is now a commitment to do more random orders through the day as the shift progresses, to randomly throw in the need for the user of the account to then take off the helmet, take off the glasses and then do another facial scan. It is a live scan that requires the individual to do it in a 3D way, so the person cannot circumvent by uploading a picture, for example. And I think with this, it would be a strong deterrence for a non-legitimate user to use a registered person's account.

And if there were suspicious activities being detected by the operator, the operators are now committed to notifying MOM of a suspicious activity of a particular individual, so that with the notification, MOM can conduct an investigation on that particular account and the individual, and then if it is found that this individual has misused his account and say, rented it out or given it to an illegitimate user, like a foreigner, we will then take necessary penalty actions, as I have laid out in my reply earlier – to take this person to task for a violation of Employment of Foreign Manpower Act.

And if this is established as a violation, we now will take the effort to notify all other platform operators about this particular individual, if he does have an account with another platform, and they will all undertake a minimum debarment of 24 months to kick the person out of the platform system and at the same time, prevent him, even if he has not registered an account with other platforms, to permanently blacklist him from ever registering another account, with another alternate operator.

So, we close the loophole to prevent someone who has misused one account on one platform from being present in other platforms. In that way, it is a strong deterrent signal, both from the legal penalty under Employment of Foreign Manpower Act and also from the practicalities of denying him the access to this platform workspace.

That is something that I think we are committed to do and I think this will reduce the administrative burdens on companies – and also on us, to ask them to keep submitting their workforce that they have employed on the legitimate work pass. As I said earlier, even if a third party logistics company employs foreign workers, they may not all be deployed to engage in platform work, so there will be a lot of abortive work and excessive work that is done for us to collect the data, which may not really lead to the outcome that we want. What we want is to catch people who are using this illegally.

On the other hand, there could well be companies that may have received a small number of outsource work, for which none of it goes to the foreigners that are in their company. To require them to submit information, which is ahead of time, and not really of workers that are involved in platform work, would be a lot of extra work for the companies involved. Many of these are also small companies, so we have to take a very balanced view on how legislation will impact the burden on companies.

On the Member's third question of the 644 workers that we have checked during our enforcement actions, we found about four who are foreigners. I do not have the record on what was the previous enforcement actions and the numbers we found. But in general on an annual basis, we do receive some complaints from either the members of the public or from NDCA. If I remember correctly, the number is about maybe 70-over complaints a year. [Please refer to ​"Clarification by Senior Minister of State for Manpower", Official Report, 26 September 2025, Vol 96, Issue 6, Clarification section.]

And generally, the enforcement actions, when we investigate on these complaints, as what our current 644 enforcement actions have shown, the numbers are very small. Eventually, the numbers that are found to be actually illegal are also a very small percentage of those complaints that we received in the years past.

But the intensive action that we took the last few months with 644 workers checked, probably gives a more accurate reflection of the realities on the ground, because these hotspots are identified by platform workers themselves, who, through their observations, seem to observe more foreigners present in these hotspots. And it was through intel provided by NDCA and by workers on the ground that we identified where the hotspots are. We go there at the peak hours, where people had observed a lot more foreigners congregating there. Even with that intensive operation, at hotspots that are identified by workers on the ground, the number, as I showed earlier, is four out of 644.

But I must also caution that excessive so-called enforcement action has a side effect as well, because to enforce this thing at hotspots, we go there at peak hours where there is a huge crowd of workers trying to get through the day's work, especially say, over lunch time. Each check will require the worker to take off his helmet, his balaclava, his face mask, his sunshades and show the Singpass, show his app, look at what was on the platform app and on the Singpass. It takes probably close to 10 minutes or so. In that process, there is a bottleneck created, the rest of the workers cannot go, they have to wait until we check through all of them before they can go ahead and do their delivery. So, there is a problem with them meeting their delivery timelines and the consumers at the other end waiting for the food to arrive will also have delays receiving their food. So, there is a cost that the system has to bear and a lot of inconvenience for the workers themselves and to the consumers.

So, we have to take a very balanced and calibrated approach. What is more sustainable to do this, is what I described earlier, for the operators to go more upstream, to do more frequent random facial verification through the day – so that if the illegal usage of the account does happen frequent enough, they will be flagged up by some of these random checks as red flags and to point out suspicious activities happening on a particular account to allow us to take more targeted actions to investigate that particular account and take the person to task.

I hope that gives Members a sense of where the effort of enforcement is to make it sustainable for the system as a whole, to reduce demands on the operators and the third party logistics companies, while sending a strong signal to deter illegal users from using the accounts.

Thank you, Mr Speaker. I appreciate the extended reply by the Senior Minister of State. I think for the very reason the Senior Minister of State suggests, enforcement can also be very intensed on the platform worker. I would, if I can advance an idea, that the second supplementary question I asked with regard to giving us a sense of what is the landscape like with regard to outsourced workers in the food delivery space, I think the reporting requirement does not have to be monthly or even quarterly, but at least year on year. There has to be some idea for the public to understand how many foreigners are operating in this space or potentially can be operating in this space. I think that would be helpful, because if the number is minimal, for example, to address surge, then from a behavioural perspective, I think platform workers will also be more receptive to understand that the Ministry has got a handle on this issue and it is prepared to look into the prospect of too many foreigners potentially being in this space.

Sir, I would say it is more of a practical consideration. The outsourcing is not limited to a fixed number of companies. The outsourcing can be any company in the logistics sector and that can span thousands of companies. And each of them can employ a certain variable amount of foreign workers based on their quota.

And if we were to check it, say, on a once a year basis, or submit on once a year basis, the contracting relationship could change several times in a year and what you get as a snapshot in time on a yearly basis will not reflect the relationship that happens in a dynamic fashion, because this is a very fast moving space. As different demand surfaces in different parts of Singapore, the operator may have to bring in more operators for a surge period of time at peak seasons of the year, for example, and then, maybe let go of that contract. And it can be a two-month arrangement, three-month arrangement. So, the dynamism of it will make that annual aggregation of information not very useful in terms of enforcement.

So, to create assurance for our platform workers, I think what we want to do is to reassure them that operators will do more random, frequent facial verification checks. And we will also undertake more stiff penalties for those who are found to be violating the use of their accounts in a legitimate way. And as we catch those, we will publicise them and signal to them that this is something that we will take very tough actions on to send a strong deterrent signal.

We will commit to working closely, at MOM and NDCA, so that the NDCA, with their fleet of workers that are already working regularly on a day-to-day basis on the ground, can be our eyes and ears to highlight to us where the hotspots are. If they do see suspicious activities, our commitment to NDCA is we will work closely with them to undertake any enforcement actions as necessary on the ground, so that our presence on the ground will send, hopefully, a strong signal to not just the illegal workers, but also a measure of support to our delivery champions out there that their feedback are taken seriously, and if they have concerns, we will also deal with them on a timely manner.