The City of Seattle recently concluded its first investigations under its independent contractor protection ordinances, resulting in Uber Eats being fined an unprecedented $15 million for pay violations impacting 16,000 independent contractors. The case is particularly significant for businesses that hire independent contractors and app-workers because it highlights the kinds of pay violations that can lead to enforcement action by the City.
Below is a summary of the Uber Eats case and key takeaways from the case.
What Led to this Historic Settlement
As you may recall, Seattle’s Independent Contractor Protections Ordinance went into effect on September 1, 2022. Under the law, companies must notify workers how much a job pays — including how earnings are calculated — before work begins and at the time of payment. The law also creates express rights for workers to enforce a company’s promises about pay.
The City initiated its first investigation against Uber Eats in 2023 after workers complained that Uber Eats misled them about how much they would earn under Uber Eats’ “Boost” incentive program and failed to provide required disclosures about pay and worker rights. Then in 2024, the City launched a second investigation against Uber Eats under the App-Based Worker Minimum Payment (ABWMP) Ordinance alleging that workers were not paid – or underpaid – for jobs that were cancelled with cause. Under ABWMP, app-based workers were supposed to receive a minimum payment based on the time worked and the miles traveled for a job, including when a job is “cancelled with cause.”
Although Uber Eats denied any wrongdoing in either of the investigations, it agreed to overhaul its policies, and pay the settlement amount, which the city of Seattle boasts is the largest settlement in the history of the Office of Labor Standards (OLS). And indicative of the compliance and enforcement climate in Seattle, the settlement has been praised by several prominent figures in Seattle as the Ordinance doing exactly what it was designed to do:
“This historic $15 million settlement is a major win for workers and a strong reminder that in Seattle, we hold large companies accountable when they sidestep their responsibilities and shortchange workers,” said Mayor Bruce Harrell.
“When workers don’t get paid what they were promised for delivering food by Uber Eats, it means they can’t put food on their own tables. I applaud OLS for helping make sure working people get what they are owed, and that no company, no matter how big or small, can exploit people with impunity,” said District 8 King County Councilmember Teresa Mosqueda.
“This settlement represents exactly the kind of change in policy that the Independent Contractor Protections Ordinance was meant to prompt”, said Elizabeth Ford, who chaired the Labor Standards Advisory Commission when the Commission recommended City Council enact the ICP Ordinance. “This settlement should encourage other companies to make sure all their workers have the basic information about their terms of engagement.”
Companies who hire independent contractors should therefore expect that Seattle will continue to aggressively enforce its independent contractor protection ordinances, and should therefore take necessary precautions to ensure strict compliance with these ordinances. We recommend the following:
- Prioritize Transparency in Pay: Be upfront and accurate about how independent contractors are compensated. Misleading promotions, unclear incentives, or shifting payment terms invite scrutiny, and could prompt contractors to complain to the city.
- Comply with Disclosure Requirements: Provide workers with written notices of their rights, earnings breakdowns, and timely pay statements.
- Document and Communicate Policies: Have clear, written policies for issues like cancellations or deductions, and make sure they are shared with workers.
- Audit Your Practices Proactively: Conduct internal compliance reviews before investigators do. Identify where worker pay, documentation, or communications may fall short of local ordinances.
- Understand Local Laws: Municipalities like Seattle set high standards for compliance. If you operate in multiple jurisdictions, tailoring your practices to meet Seattle’s high standards will likely ensure that you’re in compliance in other jurisdictions.
For more information about the investigations, see the City’s press release here: https://news.seattle.gov/2025/08/26/seattle-office-of-labor-standards-reaches-historic-15000000-settlement-with-portier-llc-dba-uber-eats-for-alleged-violations-of-independent-contractor-protections-and-app-based-worker-minimum/