BUSINESS
Piece-Rate Pay Still Pushes Couriers Onto Illegal E-Bikes
A Heriot-Watt survey told parliament that piece-rate pay drives illegal courier e-bikes, but the state answered with seizures and right-to-work checks.
A Heriot-Watt University survey found that 62% of Scottish food delivery couriers had modified their e-bikes past the legal speed cap. The study, led by Dr Pedro Mendonça at Edinburgh Business School, was later cited in a parliamentary inquiry on unsafe e-bikes.
Riders paid per drop were the ones most likely to strip the limiter, because a legal 15.5 mph bike cannot offset falling platform rates. The tools that followed that evidence were bike seizures and right-to-work checks, not a floor under drop fees.
What the Fair Gig Work Survey Found
The Fair Gig Work in Scotland review gathered 211 usable survey responses from platform food couriers between June and December 2023, plus 39 interviews run from 2019 to the end of 2023. Nine of those interviewees were undocumented migrants. The survey was funded by the Royal Society of Edinburgh and written with Dr Anastasios Hadjisolomou of the University of Strathclyde and Dr Nadia Kougiannou of Nottingham Trent University.
Heriot-Watt said 62 percent of riders surveyed had altered bikes beyond legal specifications, most often couriers on long hours who relied on delivery as their main wage. On 19 February 2026 the university noted that the work had been cited in evidence to the All-Party Parliamentary Group for Cycling and Walking.
THE SCOTTISH COURIER SURVEY
| Finding | Share |
|---|---|
| Modified e-bikes to go faster | 62% |
| Dissatisfied with pay rates | 62% |
| Feel unsafe at work | 81% |
| Work 40 hours or more a week | 40% |
| Delivery is their primary income | 48% |
| Not members of a union | 88.1% |
Those two 62% figures are not the same group doing one thing. One is kit. The other is pay. They sit on the same page because the researchers treat them as one system: low drop fees, then faster bikes.
Seventy-three percent of survey respondents gave a nationality outside the UK, with India, Brazil, Nigeria, Poland and Bangladesh among the larger groups. Eighty-four percent were men (177 people). Over 60% said they had little or no chance to raise concerns at work, and 0.5% said food delivery firms had actually replied on working conditions.
Piece Rates Make a Legal Bike a Pay Cut
Couriers in the study are classed as self-employed, yet 40% still worked 40 hours or more a week. Sixty-two percent were dissatisfied with pay, 77% said the rate was low for the effort, and 63% got nothing for waiting time. The report says pay often sat below the National Minimum Wage once idle time was counted, and that earnings moved with app nudges, demand and location.
Algorithmic management that prioritises speed over safety, combined with limited accountability, is pushing gig workers towards risky road behaviours. It is as important to strengthen regulation as it is to ensure that algorithms managing gig work prioritise the health and safety of workers and other road users.
Dr Pedro Mendonça, Edinburgh Business School, Heriot-Watt University
Over 80% of participants admitted to risky road behaviour. A substantial share, 78%, said they had driven on pavements. When the survey asked why, 78% pointed to time pressure from the platform, and riders named low pay per order in the same breath. Modified bikes cannot be insured in Scotland, so a crash can land on the courier alone.
HOW OFTEN RIDERS SAID THEY BROKE ROAD RULES
| Behaviour | Very frequently | Frequently |
|---|---|---|
| Cross red lights | 17.9% | 22.9% |
| Driven over pavements | 15.8% | 22.9% |
| Go over speed limits | 15.8% | 19.3% |
Workplace harm ran wider than traffic. Ninety percent reported verbal or psychological abuse, 60% racial or ethnic abuse, and 55% physical abuse, much of it from road incidents. Every female respondent reported sexual harassment. Informal work made the bind tighter: undocumented riders in the interview sample rented platform accounts for a weekly fee, with no path into sick pay or workplace insurance.
The researchers’ own fix was blunt. Delivery workers should be paid by the hour at or above the National Minimum Wage, platforms should programme regular pay reviews, and government should enforce it. Policy actions listed in the report include a minimum fee of £5 per delivery and pay for the time it takes to reach the pick-up point.
What UK Law Allows on a Public Road
In Great Britain a legal e-bike must have working pedals, a motor with a continuous rated power of 250 watts or less, and assistance that cuts out at 15.5 mph. Riders must be 14 or over. A compliant electrically assisted pedal cycle needs no licence, tax, registration or motor insurance, and it may use cycle paths. It may not be ridden on pavements.
WHEN THE MOTOR TURNS THE BIKE INTO A MOPED
- Speed: If the motor can propel the bike above 15.5 mph, the machine is classed as a motorcycle or moped.
- Power: A continuous rating above 250 watts has the same effect, even if a software limiter is switched on.
- Pedals: Decorative or dead pedals take the bike out of the legal e-bike category.
- Off-road modes: A factory switch that raises the cap means the whole vehicle fails the test, not only the faster setting.
Once the bike is a motor vehicle, the rider needs a driving licence, insurance, tax, registration and an approved motorcycle helmet, and the machine cannot use cycle tracks. A conversion kit is lawful only if the finished bicycle still meets every one of those tests. High-power kits sold for “private land” leave a courier with a machine that police will treat as an uninsured motorbike the moment it hits a public road, with no practical way to register it without rebuilding the frame, brakes and lights.
A 2024 consultation floated a 500-watt cap and wider throttle use. The government dropped that plan in early 2025, so the 250-watt and 15.5 mph line still stands.
The APPG File on Fake E-Bikes
The All-Party Parliamentary Group for Cycling and Walking’s report, Unregulated and Unsafe: The Threat of Illegal E-Bikes, put gig riders at the centre of a product-safety inquiry. Chair Fabian Hamilton wrote that the people on these machines are often trying to earn a living under intense pressure. The group heard from fire services, police, unions and manufacturers, and it linked piece-rate pay to the uptake of throttle bikes and conversion kits that outrun a legal e-bike while costing far less than a registered moped.
Delivery platforms, the report said, do not take responsibility for the vehicles riders use and give little guidance on what to buy. London Councils told the inquiry that pay based on completed rides encourages both dangerous riding and faster modifications. Transport for London banned e-bikes from its network in January 2025 after a fire risk on the system, a rule that also hits legal machines.
WHAT THE INQUIRY ASKED GOVERNMENT TO DO
- Worker status: Reintroduce worker status for riders, with minimum wage and health and safety rights, and structure pay so a living wage is earned across a full shift rather than per drop.
- Platform checks: Require delivery firms to run live compliance checks with GPS or accelerometer data and timestamped bike photos before and during shifts.
- Scrappage: Fund a national swap scheme for dangerous bikes and batteries, paid for by the delivery companies that profit from the work.
- Marketplaces: Pull uncertified kits, batteries and chargers, then make online marketplaces liable for unsafe listings.
- Police powers: Give officers a clearer seizure route for unsafe e-bikes, separate from existing Road Traffic Act tools.
The legitimate cycle trade made the same point in sharper language.
Companies in the legitimate UK cycle industry take full legal responsibility for the safety of the products they supply. We think it’s high time that the online marketplaces and gig economy delivery companies take on that same level of responsibility.
Bicycle Association, written evidence to the APPG for Cycling and Walking
Police Can Now Take a Bike Without a Warning
The seizure half of that list moved. The pay half did not. Police already had powers under section 165A of the Road Traffic Act 1988 to take unregistered motor vehicles, which is how modified e-bikes are treated. The Crime and Policing Act 2026 then changed section 59 of the Police Reform Act 2002 so that, from 29 June 2026, officers no longer have to give a warning before they seize vehicles used anti-socially. Transport minister Justin Madders confirmed that this includes faster, more powerful e-bikes even where they have been registered as motor vehicles. From 22 July 2026, disposal windows were cut to seven days.
THE POLICY CALENDAR AFTER THE RESEARCH
- May 2024: The Fair Gig Work in Scotland report is published, tying modified bikes to per-delivery pay.
- June 2025: The APPG issues Unregulated and Unsafe, asking for worker status, shift-level pay, scrappage and platform checks.
- 19 February 2026: Heriot-Watt flags that its survey has been cited in that inquiry.
- 29 June 2026: Police may seize a vehicle used anti-socially on the first stop, with no prior warning.
- 22 July 2026: Seized vehicles can be disposed of after seven days.
- 1 October 2026: Right-to-work liability extends to platforms that match riders with jobs.
Seizure numbers were already climbing before the new Act. Police tallies circulated in 2026 put confiscations at 7,049 machines in the 12 months to 19 May 2026, up 83% from 3,858 the year before, with the Metropolitan Police recording 2,367. That window closed five weeks before the no-warning power took effect, so the rise cannot be read as a product of the June change. Police Scotland had already taken 233 e-bikes in the 12 months to September 2024 and warned that couriers were modifying bikes to go faster. A private member’s bill from Julie Minns MP to ban the sale of illegal e-bikes and conversion kits never reached a second reading and fell when the session ended in April 2026.
On the street, the argument is almost never about drop fees. Posts about delivery e-bikes dwell on uninsured machines, masked riders and apps that skip identity checks. The 62% modification finding, and the pay structure behind it, barely features. That gap matters, because a clamp and a seven-day crush remove the kit a rider bought to hit the app’s clock. They do not change the clock.
The First New Duty Is a Papers Check
From 1 October 2026, right-to-work rules stop treating food-delivery apps as a technology layer sitting above self-employment. Under the Border Security, Asylum and Immigration Act 2025, an online matching service can be treated as the employer of people who take jobs through it, including a delivery rider who logs in, accepts drops and is paid per job. Civil penalties run to £60,000 per illegal worker. Home Office examples in the new guidance put that delivery-app case in black and white.
The Fair Gig Work interviews had already described undocumented riders renting accounts by the week. Seventy-three percent of the survey sample were not UK nationals. The first hard platform duty that followed the safety inquiry is therefore an immigration check, not a £5 drop fee, not hour-based pay, and not a GPS test of whether the bike is still an EAPC. Kate Dearden, Minister of State for the Future of Work, told the App Drivers’ and Couriers’ Union in a 1 September letter that a consultation on employment status would come in due course, and that bogus self-employment is unacceptable. No date was attached to that consult.
So the sequence is lopsided. The research named an algorithm that pays for speed. Parliament’s cycling group named worker status and shift-level pay. The statutes that actually switched on let police take the bike on the first stop and make the app check the rider’s papers.
GMB Takes the Pay Fight to Holyrood
Paul McLaughlin, GMB Scotland’s organiser in the gig economy, has written to Holyrood’s Economy, Tourism and Energy Committee asking MSPs to look at low pay, insecure earnings and the race to finish jobs faster. Employment status remains reserved to Westminster. The union’s case is that the effects, from crashes to street clutter to exhausted migrant labour, sit in Holyrood’s fair-work file whether or not London rewrites the contract.
Scotland’s own Fair Work framework talks about voice, opportunity, security, respect and safety. The Heriot-Watt team’s later journal paper, drawing on the same 211 responses and 39 interviews, found platform food delivery misaligned with all five. Union membership in the survey was 88.1%, which means almost nobody had a formal channel, even though more than 65% said unions mattered for conditions.
A legal 15.5 mph e-bike still cannot outrun a per-drop fee that falls as more riders log on. Until the fee, the hour, or the contract changes, the same 62% finding will keep describing the trade riders make when they open a kit box. Police can take the bike in seven days. The app can still ping the next order.
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