Governing Platform Work in the Digital Economy: Comparative Policy Models in Southeast Asia and Pathways to Inclusive Labour Protection

Platform work governance has emerged as a pressing policy challenge in emerging economies, yet comparative scholarship remains dominated by advanced-economy cases and tends to analyse regulatory instruments in isolation rather than as interdependent governance configurations. This article addresses that gap through a theory-informed qualitative comparative documentary analysis of platform work governance across three Southeast Asian countries, Singapore, Malaysia, and Vietnam, selected through a most-different-systems logic to maximise institutional variation. Drawing on a systematically constructed corpus of 127 national policy documents (2015–2024) and a five-dimensional analytical framework—legal classification, social protection, platform accountability, worker representation, and governance capacity—the study tests three falsifiable propositions linking institutional capacity to governance design. The documentary analysis identifies three distinct regulatory pathway designs in the 127-document corpus: managed flexibilisation (Singapore), coordinated transition (Malaysia), and controlled experimentation (Vietnam). Rather than converging on a universal model, platform governance appears to be path-dependent, institutionally mediated, and development-specific, at least in the three cases examined here. The central theoretical contribution is the concept of modular regulation a development-oriented framework proposing that governance configurations, not individual instruments, are the primary unit of cross-national variation in platform labour policy. A four-pillar policy architecture derived from the analysis provides context-sensitive guidance for emerging economies. The principal limitation is the study’s reliance on documentary evidence, which documents governance design but cannot assess implementation quality or worker-level outcomes.