The directive has implications for how its service providers are viewed under the law.

Sirli Heinsoo, who was head of the digital economy department at the economic affairs ministry, will be Baltics policy lead, mostly tasked with implementing the directive, she said. She added she does not see that her move from the ministry to Bolt would create a conflict of interest in any matter.

Moving between private and public sectors in a country the size of Estonia was quite standard, she added.

"I don't see [any conflict of interest]. I believe that in Estonia there are very many people who have previously worked in the public sector and now work in the private sector, or vice versa. I think it is completely normal that people move, and Bolt is not the only place where people have come from the public sector and from which people have gone back. There are certainly many such companies. When I previously worked at the ministry, conflicts of interest were an everyday issue. For me this is also a matter of morality, and I monitor every day to ensure that such issues do not arise," she explained.

Heinsoo: To our knowledge, Estonia will adopt EU directive

Euractiv wrote in 2024 that Bolt had engaged in aggressive lobbying and even drafted a working version of the Estonian government's position with a view to opposing the EU platform work directive and to drum up support for this line from other member states.

However, Heinsoo said that as things stand Bolt does not see any issues with adopting the directive in Estonia, and existing practices do not need to be changed.

"To our knowledge, Estonia will transpose the platform work directive exactly as the European Commission's outcome provides, and this is acceptable for Bolt. Bolt does not dispute it or demand special conditions. Based on the information we have, transposing the directive in Estonia will not bring major changes for Bolt, at most minimal technical adjustments," Heinsoo said.

The directive among other things aims to ensure that platform workers such as those using Bolt to generate income work under the correct contracts corresponding to their substantive work.

For example, if a platform worker's work corresponds to that of a regular employee, then Bolt or any other platform must conclude an employment contract with them.

This, proponents say, ensures greater legal protections, including an employer's obligation to pay social tax on their behalf and to guarantee at least the minimum wage.

Heinsoo: Bolt not obliged to pay social tax

However, Bolt's couriers and taxi drivers are not its employees, Heinsoo said, meaning the social tax aspect is not applicable.

Bolt provides a service and those operating on it are entrepreneurs, she said, be they private limited companies (OÜ), sole proprietors (FIE) or legal persons, operating via an entrepreneurship account.

"Consequently, based on current knowledge, Bolt does not have to assume an obligation to pay social tax," Heinsoo said.

Any differing opinions from other ministries on Bolt's status as an employer, Heinsoo said, should be directed to that ministry. She added that in her role at the economic affairs ministry she had not dealt with the platform work directive.

Maria-Helena Rahumets, head of labor relations policy at the economic affairs ministry, meanwhile told ERR that the platform work directive defines a digital labor platform through four main criteria, and based on these, several taxi and courier service platforms operating in Estonia, including Bolt, meet this definition and must comply with the directive.

"The main purpose of the directive is not to determine that all platform workers must necessarily be either employees or service providers, but that their contract is correct. If the platform directs and controls the performance of work to a significant extent, there should be an employment contract between the parties, which also guarantees social protections for the person," Rahumets said.

"But if the worker is genuinely independent in their activities, it is justified to operate as an independent service provider, for example as a sole entrepreneur," she added.

Anyone who suspects that their work contract does not correspond to their actual work has the right to turn to the labor dispute committee (Tööinspektsioon) or to the courts, Rahumets noted, while the inspectorate also takes on board tip-offs.

In 2024, ERR wrote that a working version of the Estonian government's position prepared by Bolt had reached the Ministry of Economic Affairs and Communications via ministry undersecretary Sandra Särav, a former Bolt employee.

Särav forwarded that letter, noting that she did not wish to deal with matters concerning Bolt, but added that Estonian entrepreneurs should be supported. However, neither this nor other letters exchanged with Bolt were registered in the ministry's document registry. Särav and her colleagues put this down to a "lack of awareness."

Directive enters into force December 2

The platform work directive will enter into force on December 2 this year and so must be transposed into domestic law by then.

On her new role, Heinsoo said it will cover domestic issues and various requirements coming from the EU alike, including the platform work directive and its implementation, and to ensure compliance with the law.

Among many other countries, Bolt operates in all three Baltic states. Heinsoo said Estonia faces fewer issues on the home front than Latvia and Lithuania, she added, at least so far as Bolt goes. For instance in Latvia, using leased or rented vehicles for taxi services is barred, and so cannot be used in Bolt services.

Lithuania recently passed a law requiring all e-scooter riders to wear a helmet, which, since Bolt and other rental services must provide that helmet, raises challenges on "technical questions, from attaching the helmet to the scooter to theft and other issues that need to be helped to resolve," Heinsoo said.

Bolt's main activities in Estonia are food couriering, ride hailing, car rental and e-scooter rental, all ordered via a smartphone app.

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