[Analysis] Aggregator Obligations under Code on Social Security 2020 – Seventh Schedule | Contribution | Registration

Aggregator obligations under the Code on Social Security 2020 come from section 114 read with the Seventh Schedule. An aggregator falling in any of the nine listed categories may be required to contribute between one and two per cent of its annual turnover to fund schemes for gig and platform workers, subject to a second cap of five per cent of the amount paid or payable by it to those workers. Section 114(5) leaves the date that obligation begins to be notified by the Central Government. The registration duties are not waiting for it: Rule 48(2)(c) of the Social Security (Central) Rules, 2026 requires every aggregator to register each new gig and platform worker on the designated Portal in real time or on a daily basis, and Rule 49(3) fixes a self-assessment in Form XX by 30 June and a final return in Form XXI by 31 October.

Law stated as on 1 September 2026. The Code on Social Security, 2020 was brought into force in stages, the bulk of it with effect from 21 November 2025.

Table of Contents

1. Why the Code reached aggregators at all
2. Who is an aggregator
3. The nine categories in the Seventh Schedule
4. The contribution, and its two ceilings
5. The date that has not arrived, and the machinery that has
6. What the money would fund
7. Registration: what the worker does, and what the platform must do
8. The Fund, and the seat at the table
9. Frequently asked questions
10. Conclusion

1. Why the Code reached aggregators at all

None of the nine repealed Acts knew what a platform was. The Unorganised Workers’ Social Security Act, 2008 came closest, and it was not as narrow as it is usually described. Its section 2(m) defined an unorganised worker as a home-based worker, self-employed worker or wage worker in the unorganised sector, and included a worker in the organised sector who was not covered by any of the Acts mentioned in Schedule II to that Act. Section 2(86) of the Code carries the same structure forward, substituting the Industrial Disputes Act, 1947 and Chapters III to VII of the Code for that Schedule. What the 2008 Act had no word for was the platform.

The Code on Social Security, 2020 supplied three definitions in section 2 that the 2008 Act did not have: gig worker, platform worker and aggregator. Chapter IX then built machinery around them, but only part of that chapter is new, and it is worth being exact about which part. Sections 109 to 113 have predecessors: section 109 corresponds to sections 3 and 4 and Schedule I of the 2008 Act, section 110 to section 7, section 111 to section 8, section 112 to section 9 and section 113 to section 10. Section 114 is the only provision in the chapter with no corresponding section in any of the repealed Acts, and it is the one that reaches the platform.

Our earlier note on gig workers and platform workers covers who falls inside the definitions. This note is about what the platform itself has to do.

2. Who is an aggregator

Section 2(2) defines an aggregator as a digital intermediary or a market place for a buyer or user of a service to connect with the seller or the service provider.

Three features of that definition are worth drawing out. It is functional, not sectoral: what matters is the connecting, not the industry. It covers a “market place” as well as an intermediary, so a platform that merely hosts is not obviously outside it. And it speaks of a service, which leaves an open question about pure goods marketplaces that the Seventh Schedule then answers in a different way.

The definition does not by itself impose anything. The obligation in section 114(4) attaches only to an aggregator “who falls within a category of aggregators, as are specified in the Seventh Schedule”.

3. The nine categories in the Seventh Schedule

The Seventh Schedule is headed “Classification of Aggregators”, carries the note “[See Section 114(4)]”, and lists nine:

Sl. No.	Classification of aggregator
1	Ride sharing services
2	Food and grocery delivery services
3	Logistic services
4	e-Market place (both market place and inventory model) for wholesale/retail sale of goods and/or services (B2B/B2C)
5	Professional services provider
6	Healthcare
7	Travel and hospitality
8	Content and media services
9	Any other goods and services provider platform

Entry 4 answers the goods question left open by section 2(2): an e-market place is in, on either the marketplace or the inventory model, and whether it sells goods or services or both.

Entry 9 is the one that decides the scope of the Schedule. “Any other goods and services provider platform” makes the first eight entries illustrative rather than exhaustive, so no platform falls outside the Schedule by failing to match entries 1 to 8. The classification exercise is about which entry a platform sits in, not whether it is covered, and section 152(1) lets the Central Government amend the Seventh Schedule by notification, by addition or deletion, in any event.

Two qualifications belong beside that, and both sit at the end of section 114. Under section 114(7)(ii) the Central Government may, by notification, exempt an aggregator or a class of aggregators from paying contribution under section 114(4), subject to conditions specified in the notification. So the Schedule catches everyone, but the exemption power can let a class back out. Pulling the other way, the Explanation to section 114 provides that for the purposes of the section an aggregator having more than one business shall be treated as a separate business entity or aggregator. A group running several platforms is not assessed once on a consolidated turnover; each business stands on its own.

4. The contribution, and its two ceilings

Section 114(4) is the operative provision, and it contains two separate caps that have to be applied together.

Cap	What it says
The turnover band	Contribution at such rate as the Central Government notifies, not exceeding two per cent but not less than one per cent of the annual turnover of the aggregator
The payout ceiling	Proviso: the contribution shall not exceed five per cent of the amount paid or payable by the aggregator to gig workers and platform workers

The Explanation removes one thing from the base: for this purpose, annual turnover does not include any tax, levy and cess paid or payable to the Central Government.

The second cap is the one that decides which computation governs, and it is asymmetric in an important way. A platform with very high turnover and comparatively low payouts to workers is protected by it. A platform whose model is labour-heavy, where payouts to gig workers are a large share of revenue, will find that the five per cent ceiling never bites, and the turnover figure governs.

Read together, the two caps mean the liability of a platform cannot be worked out from its turnover alone. It needs the turnover net of Central taxes and levies, and it needs the aggregate paid or payable to gig and platform workers for the same period, and the lower of the two computations is the number.

5. The date that has not arrived, and the machinery that has

Section 114(5) is one line and it governs everything above it: the date of commencement of contribution from aggregator under this section shall be notified by the Central Government.

That notification does not appear among the instruments issued under the Code up to 1 July 2026, which is where the notifications reproduced in Taxmann’s Law & Practice Relating to Code on Social Security end. Nor has a rate been notified within the one-to-two per cent band.

It would be a mistake to read that as an empty chapter. Section 114(7)(i) lists five matters the Central Government may prescribe, and Rule 49 of the Social Security (Central) Rules, 2026 has taken up four of them already.

What section 114(7)(i) allows	What Rule 49 has done
(a) the authority to collect and to expend the proceeds of contribution collected	Rule 49(1)(a): the Central Government designates an officer or an agency as that authority; Rule 49(1)(c) puts the money in a separate account of the Social Security Fund
(b) the rate of interest on delayed, less or non-payment of contribution	Rule 49(2): one per cent for every month or part of a month from the due date until payment
(c) self-assessment of contribution by aggregators	Rule 49(3): provisional self-assessment in Form XX by 30 June; final return in Form XXI by 31 October; refund of excess within ninety days
(d) conditions for cessation of a gig worker or a platform worker	Rule 49(4): age sixty, or not engaged for ninety days with an aggregator, or one hundred and twenty days across several, in the last financial year
(e) any other matter relating to smooth functioning of the social security scheme notified under this section	Not yet taken up. It is the clause under which the administrative detail of a notified scheme would come

So the compliance calendar already exists. The provisional contribution for the preceding year is payable not later than 30 June of the current year, and the final return follows once the audited accounts are finalised under the Income-tax Act, 2025, the Companies Act, 2013 or the Limited Liability Partnership Act, 2008, with any outstanding amount paid by 31 October.

And Form XX does not wait for the rate. Item 6 asks the aggregator to tick whichever is applicable: 6.1, the percentage of annual turnover “as notified under sub-section (4) of section 114 for the preceding year”, or 6.2, “5% of amount paid or payable to gig workers and platform workers, by the aggregator during the preceding year”. Limb 6.1 is unusable until the rate is notified. Limb 6.2 is not, and the proviso to Rule 49(3)(a) plainly contemplates an aggregator making the contribution payable on the basis of five per cent of the amount paid or payable to gig and platform workers, in which case the count must include every worker engaged directly or through an associate company, holding company, subsidiary company, limited liability partnership or third party.

The position is therefore narrower than it first looks. What has not been notified is the rate under section 114(4) and the commencement date under section 114(5). Everything around them has been prescribed: the collecting authority, the interest rate, the self-assessment form, the two payment dates and the refund route. A platform that reads section 114(5) as permission to do nothing is reading only the section.

Notifications as they issue are carried on Taxmann.com | Research.

6. What the money would fund

Section 114(1) lets the Central Government frame and notify social security schemes for gig workers and platform workers on six heads:

• life and disability cover;
• accident insurance;
• health and maternity benefits;
• old age protection;
• crèche; and
• any other benefit the Central Government determines.

Section 114(2) says such a scheme may provide for the manner of administration, the implementing agencies, the role of aggregators in the scheme, the sources of funding, and any other matter. That third item matters: the scheme can put administrative work on the platform, not merely money.

Section 114(3) sets out how a scheme may be funded, and the range is wide. Wholly by the Central Government; partly Central and partly State; wholly by contributions of the aggregators; partly Central, partly State and partly from contributions collected from the beneficiaries of the scheme or the aggregators; from a corporate social responsibility fund within the meaning of the Companies Act, 2013; or, under clause (f), from any other source. Six routes, and the last is open-ended. An aggregator’s exposure to any particular scheme therefore depends on the funding clause of that scheme, not on section 114(4) alone.

7. Registration: what the worker does, and what the platform must do

Section 113(1) puts the registration obligation on the individual. Every unorganised worker, gig worker or platform worker shall be required to be registered, subject to two conditions:

• he has completed sixteen years of age, or such age as the Central Government prescribes; and
• he has submitted a self-declaration, electronically or otherwise, in the prescribed form.

Section 113(2) requires an application for registration in the prescribed form with prescribed documents including the Aadhaar number, and the worker is then assigned a distinguishable number.

Read on its own, section 113 says nothing about the platform, and it is often reported that way. The rules made under it say a great deal, and this is where the live obligations in Chapter IX actually sit. Rule 48(2) of the Social Security (Central) Rules, 2026 places continuing duties on the aggregator itself, and rule 49(5) adds one more.

Rule	What the aggregator must do	When
48(2)(b)	Share, through an Application Programming Interface or other electronic modes, the details of gig and platform workers engaged with it, on the designated Portal of the Central Government, for generation of a Universal Account Number	Within forty-five days from the commencement of the Rules
48(2)(c)	Register every new gig and platform worker it engages on the designated Portal, and share the exit details of workers registered with it	In real time or on a daily basis, through an API or other electronic modes
48(2)(g)	Share electronically the details of the gig and platform workers engaged with it, so their particulars can be updated	Monthly, or at such other periodicity as is specified on the Portal
49(5)	Register itself on the designated Portal, or any other portal specified by the Central Government	No date is specified

So the familiar proposition that registration is the worker’s business is only half the picture. The worker self-registers under Rule 48(2)(a) with Aadhaar and a self-declaration. But the aggregator must register every new worker it engages, in real time or daily, and must report exits the same way. That is a systems obligation rather than a paperwork one: on the face of the rule it presupposes an API integration with the Central Government’s portal.

The forty-five day window in Rule 48(2)(b) is the one to check against the calendar. The Rules were notified by G.S.R. 344(E) dated 8 May 2026 and, by rule 1(2), came into force on the date of their publication in the Official Gazette. Forty-five days from that date expired in June 2026. An aggregator that has not yet shared its worker details for Universal Account Number generation is outside that window, not approaching it.

Rule 48(2)(f) closes the obvious gap. An eligible gig and platform worker “shall include all such workers engaged by the aggregator directly or through associate company or holding company or subsidiary company or limited liability partnership or through a third party”. Routing engagement through a labour supplier does not take the worker outside the count, and the same language reappears in the proviso to Rule 49(3)(a) for the contribution computation.

One distinction is worth keeping clear, because it cuts the other way. Registration is not entitlement. The proviso to Rule 48(2)(e) limits eligibility for benefits under a scheme to a worker engaged as a gig and platform worker for not less than ninety days with an aggregator, or one hundred and twenty days in the case of multiple aggregators, in the last financial year; and the Explanation counts a day whenever the worker has earned income of any amount from that aggregator on that calendar day, cumulatively across aggregators, so a worker engaged with three aggregators on one day counts three days. The aggregator’s duty to register a worker does not wait for the worker to qualify.

8. The Fund, and the seat at the table

Section 141(1) establishes a Social Security Fund for the social security and welfare of unorganised workers, gig workers and platform workers. It has three named sources:

• funding under section 109(3);
• funding under section 114(3), which is where aggregator contributions land; and
• funding from the composition of offences under the Code relating to the Central Government, and from any other Social Security Fund established under any other central labour law.

Section 141(2) requires a separate account for each of the three, and section 141(3) requires each account to be expended only for the purpose for which it was established. The third source is a quiet piece of design worth noticing: compounding fees paid by employers under section 138 do not go into general revenue, they go to the workers’ fund.

Rule 49(1)(c) closes the circuit, tying the aggregator’s contribution to the separate account section 141(2) requires. Section 141(5) then requires a second and separate fund, established by each State Government for the welfare of unorganised workers, credited with the composition of offences under the Code relating to that State Government and such other sources as the State prescribes.

Section 114(6) then gives aggregators representation. The National Social Security Board constituted under section 6(1) is the Board for the welfare of gig and platform workers, but when it sits for that purpose its composition changes: in place of the members specified in section 6(2)(c) and (d), it includes five representatives of the aggregators nominated by the Central Government.

9. Frequently asked questions

Who is an aggregator under the Code on Social Security 2020?

Section 2(2) defines an aggregator as a digital intermediary or a market place for a buyer or user of a service to connect with the seller or the service provider. The contribution obligation in section 114(4) applies only to an aggregator falling within one of the nine categories in the Seventh Schedule, the ninth of which is any other goods and services provider platform.

How much do aggregators have to contribute?

Section 114(4) sets a rate to be notified by the Central Government of not less than one and not more than two per cent of the aggregator’s annual turnover, excluding any tax, levy and cess paid or payable to the Central Government. A proviso caps the contribution at five per cent of the amount paid or payable by the aggregator to gig workers and platform workers, so the liability is the lower of the two computations.

Has the aggregator contribution started?

Section 114(5) provides that the date of commencement of contribution from aggregator shall be notified by the Central Government. Neither that notification nor a notification of the rate within the one-to-two per cent band appears among the instruments issued under the Code up to 1 July 2026. The machinery around the contribution is nevertheless already prescribed. Rule 49(3) of the Social Security (Central) Rules, 2026 requires a provisional self-assessment in Form XX by 30 June of the year in which the contribution is payable and a final return in Form XXI by 31 October, Rule 49(2) fixes interest on late, short or non-payment at one per cent for every month or part of a month, and Rule 49(1) designates the authority that collects it.

Do aggregators have to register their gig workers?

Yes. Section 113(1) places the registration requirement on the worker himself, but Rule 48(2)(c) of the Social Security (Central) Rules, 2026 requires every aggregator engaging any new gig and platform worker to register that worker on the designated Portal of the Central Government in real time or on a daily basis, through an Application Programming Interface or other electronic modes, and to share exit details the same way. Rule 48(2)(b) required aggregators to share the details of workers already engaged, for generation of a Universal Account Number, within forty-five days from the commencement of the Rules on 8 May 2026. Rule 48(2)(g) requires monthly sharing of worker details for updation, and Rule 49(5) requires every aggregator to register itself on the designated Portal.

Which platforms fall within the Seventh Schedule?

Ride sharing, food and grocery delivery, logistics, e-market places on either the marketplace or inventory model for wholesale or retail sale of goods or services, professional services providers, healthcare, travel and hospitality, content and media services, and any other goods and services provider platform. Because the ninth entry is a residual category, no platform is outside the Schedule by virtue of its business not matching entries one to eight. Section 114(7)(ii) separately allows the Central Government, by notification, to exempt an aggregator or class of aggregators from paying contribution under section 114(4), and the Explanation to section 114 treats an aggregator having more than one business as a separate business entity or aggregator.

10. Conclusion

For an aggregator the Code is at an unusual stage, and an easy one to mistake for a dormant stage. The definition binds. The Seventh Schedule leaves nobody out, subject only to the exemption power in section 114(7)(ii). The Board already has five seats reserved for the industry, the Fund that would receive the money is established, and the registration duties in Rule 48(2) are running now rather than pending. What is missing is two numbers: the rate under section 114(4), and the date it starts under section 114(5).

The work that can sensibly be done now is partly systems and partly arithmetic. The systems part is Rule 48(2)(c), which contemplates registering each new worker on the designated Portal in real time or daily through an API, and Rule 48(2)(g), which contemplates a monthly feed. Neither is a year-end exercise.

The arithmetic part is section 114(4), which will require, for whatever period is notified, both the annual turnover net of Central taxes, levies and cesses, and the aggregate paid or payable to gig and platform workers. Platforms generally have the first figure to hand. The second is the one that decides whether the five per cent proviso binds, and it is the one that is harder to reconstruct backwards.

For section 114 and the Seventh Schedule printed with the Chapter IX machinery around them, see Taxmann’s Law & Practice Relating to Code on Social Security. The Ministry of Labour and Employment’s Compliance Handbook for Employers under the Four Labour Codes sets the gig and platform provisions beside the rest of the reform.