Dual-Payment Model in Delivery-Specific Law Favors Riders: Efficiency Gains Should Be Shared by All Four Parties

Since the formal implementation of the delivery-specific law, public attention has largely focused on minimum pay guarantees for delivery riders. However, as operational details emerge, the law’s mandatory pricing rules for stacked orders have revealed troubling policy side effects.

Under current regulations, if a rider accepts three consecutive route-optimized orders delivered at 20, 25, and 30 minutes respectively, their statutory minimum earnings would be approximately NT$82, NT$102.5, and NT$123—totaling over NT$300 for just 30 minutes of work. This compensation structure, far exceeding that of typical基层 workers, exposes an alarming 'double-counting' issue that warrants reevaluation by government and stakeholders.

First, the efficiency gains from route-stacking are not merely extended labor but the product of advanced technology. Some view stacked order compensation as a dilution of rider output by platforms, but this overlooks modern logistics. In reality, 'stacked orders' do not occur organically—they are high-cost technological achievements. Platforms invest hundreds of millions of dollars annually to develop algorithms and real-time traffic data models, enabling millisecond-level precision in calculating route overlap between orders.

This 'efficiency dividend,' created through technology, stems from platforms eliminating traditional delivery waste such as 'waiting' and 'detours' via capital and technical investment. At its core, it represents a 'technological rent.' Since platforms exclusively generate this efficiency, it is reasonable for them to retain part of the gain to sustain operations while sharing incentives with merchants, riders, and consumers—this balance is essential for long-term business sustainability.

If laws mandate full fare payment per stacked order—even re-paying hourly wages for already-compensated travel segments—it erases the value of innovation and deprives other ecosystem participants of their rightful share.

Second, there is no such thing as a free lunch. Favoring riders unilaterally disrupts market equilibrium. The primary cost for riders is movement time, which stacked orders significantly reduce. More critically, when stacked deliveries cause delays, cold meals, or customer cancellations, the financial and satisfaction risks are overwhelmingly borne by merchants, consumers, and platforms—not riders.

Given that riders face lower mobility costs and bear no risk for order success, demanding full pay equivalent to standalone orders constitutes economically unjustified excess compensation. If platforms abandon stacking—even when routes align—and instead dispatch three different riders to pick up from one store and deliver separately to three nearby customers, the consequences are severe: longer wait times for merchants and consumers, higher per-order shipping fees (effectively turning each into a dedicated delivery), the disappearance of benefits like 'free shipping,' 'trip bonuses,' and 'peak-hour discounts,' plus increased carbon emissions. Is this outcome truly desirable?

Third, rigid regulations risk triggering a four-party lose-lose scenario. Market mechanisms follow objective laws that cannot be overridden by legislation. If laws force double-payment for stacked orders, platforms will either reduce or eliminate stacking features—or pass the added costs onto consumers and merchants. International precedents already show the fallout: riders handle fewer orders per hour; despite higher per-order fees, total hourly income may decline. Consumers abandon orders due to rising prices and longer waits, leading to market collapse and threatening merchant livelihoods.

With the current law already ensuring a minimum of NT$45 per order and hourly pay at 1.25 times the minimum wage, we urge the government to reevaluate stacked-order pricing while protecting rider rights. Regulations must return to market-driven flexibility to prevent the vibrant delivery economy from collapsing under inflexible legal mandates.

(Authored by: Co-Managing Attorney, Chung Yin Law Firm / Supervisor, DEAT Taiwan Digital Platform Economy Association)