The Super App Monopoly Probe in Southeast Asia

The Southeast Asian digital economy, which was projected to reach $263 billion in Gross Merchandise Value (GMV) by the end of 2024, is no longer a competitive open field. It has calcified into a rigid duopoly. As of February 2025, Singapore-based Grab and Indonesia’s GoTo (the parent company of Gojek) shared control over 70% of the region’s ride-hailing GMV and approximately 60% of the food delivery market. This consolidation is not a result of organic growth; it is the calculated aftermath of Uber’s 2018 exit and a subsequent war of attrition that has left smaller players fighting for scraps or exiting key markets entirely.

The market power of these two entities is most visible in their stronghold territories. In Indonesia, the region’s largest economy, the two giants are locked in a near-perfect deadlock, with Gojek holding approximately 43% of the ride-hailing market and Grab close behind at 39% as of late 2024. The situation is even more acute in Singapore, where Grab has maintained a dominant position since acquiring Uber’s regional operations, a move that triggered a combined S$13 million fine from the Competition and Consumer Commission of Singapore (CCCS) for eroding market contestability. Yet, the fines did little to reverse the consolidation. This report about Super App Monopoly Probe, highlights that the barrier to entry for new platforms is mathematically prohibitive, requiring billions in subsidies to break the network effects established by the incumbents.

Market Share Distribution by Key Territory (Q1 2025)

The following data, aggregated from regulatory filings and market intelligence reports, illustrates the uneven distribution of power across major Southeast Asian markets. Note the retreat of Gojek from markets like Vietnam and Thailand, ceding territory to Grab and local specialists.

Country	Dominant Player(s)	Market Status (2024-2025)	Key Competitors
Indonesia	GoTo (Gojek) & Grab	Duopoly: Combined share>90%. Gojek leads slightly in two-wheeler segments.	Maxim, inDrive
Singapore	Grab	Monopoly-leaning: Grab holds majority share. Gojek serves as a distant second.	Gojek, Tada, Ryde
Vietnam	Grab & Xanh SM	Disrupted: Gojek exited in Sept 2024. EV taxi firm Xanh SM overtook Grab in Q4 2024 (37. 4% vs 36. 6%).	Be Group
Thailand	Grab & Line Man	Duopoly: Foodpanda exited. Grab and Line Man control nearly 90% of food delivery.	AirAsia Move
Philippines	Grab	Dominant: Grab remains the primary ride-hailing option after Uber’s exit.	JoyRide, Move It

The contraction of competition is further evidenced by GoTo’s strategic retrenchment. In September 2024, Gojek ceased operations in Vietnam, unable to sustain the cash burn required to fight a three-front war against Grab and the rising local contender, Xanh SM. This exit left Grab as the sole regional “Super App” operating in all major Southeast Asian economies, reinforcing its pricing power. Analysts from Bloomberg Intelligence noted in February 2025 that a chance merger between Grab and GoTo—a topic of recurring boardroom discussions—would result in a single entity controlling 85% to 90% of the ride-hailing market in Indonesia and Singapore. Such a concentration would trigger immediate antitrust “red alerts” from the KPPU in Indonesia and the CCCS in Singapore.

Financial metrics from the 2024 e-Conomy SEA report by Google, Temasek, and Bain & Company indicate that the transport and food delivery sectors have finally pivoted to profitability. yet, this profitability comes at the cost of consumer surplus. With fewer competitors to check pricing algorithms, platform fees and commission rates have stabilized at higher baselines. In 2025, Grab’s delivery segment GMV grew 26% to $3. 7 billion in Q3 alone, while ShopeeFood has emerged as a distant but growing challenger, capturing 14% of the regional food delivery market. The absence of a third major regional player means that price wars, which once benefited consumers with deep discounts, have largely, replaced by “loyalty programs” that lock users into a single ecosystem.

“If Grab acquires GoTo, their combined market share exceeding 50 percent could violate Law Number 5 of 1999 and harm consumers by reducing competition. In digital platform markets, traditional assumptions about market entry and consumer switching no longer apply.”
— Ditha Wiradiputra, Executive Director, Institute for Competition and Business Policy Studies (July 2025)

The trajectory is clear: the era of expansion is over, replaced by an era of extraction. The duopoly has shifted its focus from acquiring new users to maximizing revenue per user, leveraging their entrenched market positions to squeeze both drivers and consumers. As 2025 progresses, the regulatory can inevitably turn to whether these “Super Apps” have become too big to behave.

Algorithm Opacity: How Pricing Masks Predatory Rates

The proprietary algorithms governing Southeast Asia’s ride-hailing duopoly are not neutral arbiters of supply and demand; they are profit-maximization engines operating inside a “black box” designed to extract maximum value from both riders and drivers. While Grab and GoTo publicly attribute fare fluctuations to real-time market conditions, investigations conducted between 2023 and 2025 reveal a pattern of manufactured scarcity and decoupled pricing that defies basic economic logic.

The most damning evidence of this manipulation surfaced in the Philippines. A 2024 investigation by the Philippine Center for Investigative Journalism (PCIJ) exposed that Grab’s “surge” pricing was not an occasional response to peak demand but a near-permanent feature. Data collected over a six-month period showed that surge fees were applied to rides regardless of the time of day or actual driver availability. In instances, high surge rates for hours without any corresponding reduction in wait times, debunking the platform’s claim that higher prices incentivize more drivers to get on the road. The algorithm established a new, inflated baseline fare under the guise of pricing.

Regulators have struggled to pierce this algorithmic veil. The Philippine Competition Commission (PCC) has been the most aggressive, levying a total of PHP 63. 7 million in fines against Grab since 2018 for violating pricing commitments. In May 2023, the PCC imposed an additional PHP 9 million penalty specifically for the company’s failure to refund overcharges to customers, citing “incorrect and misleading information” in compliance reports. These sanctions, yet, represent a fraction of the revenue generated through unclear pricing method.

In Singapore, the opacity has shifted from consumer fares to driver commissions. In late 2023, Grab replaced its fixed 20. 18% commission structure with a “variable service fee.” While the company marketed this as a fairness measure—claiming it would reduce fees for long pickup distances—drivers reported take rates climbing as high as 25% on standard trips. This ” commission” model decouples the rider’s fare from the driver’s earnings, allowing the platform to charge a passenger a high surge price while paying the driver a standard rate, pocketing the difference as an “efficiency” fee.

The disconnect between rider payments and driver earnings is widespread. In Vietnam, a “heatwave surcharge” introduced by Grab in July 2022 was swiftly challenged by the Vietnam Competition and Consumer Authority. The regulator found that while the app charged customers extra for extreme weather conditions, the method to pass this revenue to drivers was either nonexistent or technically flawed at launch. The surcharge was canceled within days, but it highlighted a broader strategy: using external factors to justify price hikes that do not correlate to increased driver compensation.

The following table outlines the key regulatory interventions and pricing anomalies detected across major Southeast Asian markets from 2022 to 2025.

Table 2. 1: Regulatory Probes into Algorithmic Pricing (2022–2025)

Market	Regulator	Key problem Identified	Action / Outcome
Philippines	PCC	Persistent “surge” pricing unrelated to actual supply; failure to refund overcharges.	PHP 63. 7M total fines; PHP 9M additional fine in May 2023 for refund delays.
Singapore	CCCS	Introduction of “variable service fees” masking higher commissions.	Ongoing monitoring; 2024 provisional decision against Trans-cab acquisition dominance concerns.
Vietnam	VCCA	“Heatwave Surcharge” collected from riders but not transparently passed to drivers.	Surcharge forced to cancel days after launch in July 2022; strict disclosure mandates issued.
Indonesia	KPPU	Discriminatory algorithm prioritizing fleet partners (TPI) over independent drivers.	Investigation into “predatory pricing” and preferential order allocation; merger scrutiny active as of late 2025.

This algorithmic control extends beyond pricing to behavioral modification. Drivers in Indonesia and Thailand report that the “batched matching” systems—which assign a new ride before the current one ends—prevent them from seeing the fare or destination of the trip. If they decline these blind assignments, their acceptance ratings drop, removing them from eligibility for incentives. This creates a forced labor loop where drivers must accept unclear, chance unprofitable rides to maintain their status on the platform.

The “black box” defense remains the super apps’ primary shield against antitrust litigation. By claiming their pricing logic is a trade secret, these companies prevent independent auditors from verifying whether a 2. 5x surge is a legitimate market signal or an artificial price floor. Until regulators mandate open-book auditing of these algorithms, the pricing model can continue to function as a tool for wealth extraction rather than market efficiency.

Indonesia’s KPPU and the TikTok-Tokopedia Merger

The consolidation of Southeast Asia’s digital economy reached a flashpoint in late 2023 when the Indonesian government issued Minister of Trade Regulation (Permendag) No. 31/2023. This regulation banned “social commerce” transactions on social media platforms. The policy targeted TikTok Shop directly. Officials concerns over predatory pricing and the protection of local MSMEs from a flood of cheap imported goods. TikTok halted its e-commerce operations in Indonesia in October 2023 yet returned weeks later through a strategic acquisition that reshaped the market.

By January 31, 2024, TikTok completed a $1. 5 billion investment to acquire a 75. 01% controlling stake in Tokopedia, the e-commerce arm of GoTo. This deal allowed TikTok to bypass the regulatory ban by processing transactions through Tokopedia’s backend while keeping the user interface within the TikTok app. The maneuver saved TikTok’s most lucrative market yet immediately triggered scrutiny from Indonesia’s Business Competition Supervisory Commission (KPPU).

Antitrust Scrutiny and Penalties

The KPPU launched a rigorous investigation into the merger. They focused on chance monopolistic practices such as tying, bundling, and algorithm manipulation that could favor TikTok’s own products over independent merchants. In September 2025, the watchdog imposed a fine of 15 billion Indonesian Rupiah (approximately $900, 000) on TikTok for failing to notify the agency of the acquisition within the statutory 30-day period. The deadline for notification was March 19, 2024, but the company missed this window.

Beyond the administrative fine, the KPPU issued a conditional approval for the merger in June 2025. This approval came with strict behavioral remedies to prevent market. The agency mandated that the combined entity must maintain open access for payment and logistics providers. It explicitly prohibited self-preferencing algorithms that would disadvantage competitors. The KPPU also established a monitoring period until June 17, 2027, requiring the company to submit quarterly compliance reports.

Workforce Reductions and Integration Costs

The integration of two massive organizational structures resulted in immediate and recurring workforce reductions. In June 2024, Tokopedia laid off approximately 450 employees, representing nearly 9% of its workforce at the time. The cuts targeted duplicate roles in customer operations and marketing. This was not an event. In July and August 2025, the company executed another round of layoffs affecting roughly 420 additional staff members. These reductions signaled a shift from growth-at-all-costs to a focus on operational efficiency under ByteDance’s control.

Metric	Shopee (Sea Group)	TikTok Shop + Tokopedia
Indonesia Market Share (GMV 2024)	46% – 52%	34% – 46%
Primary Strategy	Logistics & Mass Market	Live Commerce & Content
Regulatory Status	Compliant	Under KPPU Monitoring (until 2027)

The merger has created a duopoly in Indonesia’s e-commerce sector. Data from 2024 indicates that Shopee retains a lead with approximately 46% to 52% of the market share. The combined TikTok-Tokopedia entity follows closely with a share estimated between 34% and 46%. Smaller players like Lazada and Bukalapak have been marginalized. They hold single-digit market shares. This concentration of power leaves Indonesian merchants with fewer alternatives and increases their dependency on the algorithms of two dominant platforms.

Singapore’s CCCS Probe into the Trans-cab Acquisition

The unchecked expansion of Southeast Asia’s super apps hit a rare, concrete regulatory wall in Singapore between 2023 and 2024. While Grab and GoTo have historically absorbed competitors with relative impunity, Grab’s attempt to acquire Trans-cab—Singapore’s third-largest taxi operator—triggered a decisive intervention by the Competition and Consumer Commission of Singapore (CCCS). This case serves as the region’s most significant antitrust precedent in the post-Uber era, marking a shift from passive monitoring to active enforcement against market entrenchment.

In July 2023, Grab Holdings proposed to acquire 100% of Trans-cab through its subsidiary, GrabRentals. The deal, estimated by industry analysts to be valued around S$100 million, was not a purchase of assets but a strategic maneuver to lock in driver supply. Trans-cab controlled a fleet of over 2, 500 vehicles, including taxis and private-hire cars. Crucially, Trans-cab drivers were largely “non-affiliated,” meaning they were not contractually bound to any single ride-hailing platform and frequently utilized multiple apps or relied on street hail. Absorbing this fleet would have removed a neutral supply pool from the market, forcing those drivers into Grab’s ecosystem.

The CCCS launched a preliminary review in August 2023, quickly identifying red flags that the standard “efficiency” arguments could not mitigate. By October 2023, the regulator rejected Grab’s initial commitments as insufficient and escalated the probe to an “Phase 2” review in January 2024. This phase is reserved for mergers with a high probability of infringing Section 54 of the Competition Act, which prohibits deals that substantially lessen competition.

On July 11, 2024, the CCCS issued a Provisional Decision that dismantled the rationale for the merger. The regulator’s findings were explicit: the acquisition would “entrench and strengthen” Grab’s already dominant position. The CCCS highlighted that rival platforms faced a severe driver absence and that Trans-cab represented a important source of independent drivers. If the deal proceeded, the “stickiness” of Trans-cab drivers to Grab’s platform would increase, starving competitors like Gojek, Tada, and Ryde of the liquidity needed to offer reliable service. Furthermore, the commission noted that Grab would likely reduce driver incentives once it secured this captive fleet, directly harming driver earnings.

Faced with the regulator’s provisional block, Grab and Trans-cab abandoned the deal on July 22, 2024. The withdrawal was a tactical retreat; proceeding would have required offering remedies so severe they likely destroyed the commercial logic of the acquisition. The collapse of the deal preserved Trans-cab’s independence, and in an ironic twist, the taxi operator later secured a provisional ride-hail service operator license in December 2024, positioning itself to compete directly against Grab in 2025.

Timeline of the Regulatory Blockade

The following table outlines the serious milestones in the CCCS investigation that halted the acquisition.

Chronology of the Grab-Trans-cab Antitrust Probe (2023–2024)

Date	Event	Significance
July 20, 2023	Acquisition Announced	Grab proposes to buy 100% of Trans-cab to acquire its fleet of 2, 500+ vehicles.
October 16, 2023	Phase 1 Conclusion	CCCS finds Grab’s initial commitments “insufficient” to address competition concerns.
January 2024	Phase 2 Review Begins	Regulator launches probe, citing risks of “substantial lessening of competition.”
July 11, 2024	Provisional Decision	CCCS formally states the deal would entrench Grab’s dominance and harm drivers/riders.
July 25, 2024	Deal Abandoned	Grab and Trans-cab withdraw the application; CCCS ends assessment.
December 23, 2024	Trans-cab Pivot	Trans-cab receives provisional license to operate its own ride-hailing service in 2025.

The failure of this acquisition exposes the limits of the “super app” growth model in mature regulatory environments. For years, players like Grab relied on capital dominance to buy out threats or supply constraints. The CCCS ruling established that protecting the structure of the market—specifically the existence of independent supply pools—is a priority over the operational claimed by dominant firms. This decision has likely chilled similar consolidation attempts across the region, forcing platforms to compete for drivers through better earnings and terms rather than acquisition-led coercion.

Merchant Commission Hikes: Tracing the Rise from 15% to 35%

The trajectory of merchant commissions in Southeast Asia’s digital economy reveals a calculated shift from subsidized acquisition to aggressive monetization. Between 2015 and 2025, the standard “take rate”—the percentage of Gross Merchandise Value (GMV) retained by platforms—more than doubled. What began as a 15% introductory rate during the fierce subsidy wars has hardened into a non-negotiable 30-35% baseline, a financial reality that dictates the survival of millions of small and medium-sized enterprises (SMEs) across the region.

The “Honeymoon” Phase (2015–2017)

In the nascent stages of the on-demand economy, platforms like Grab, Gojek, and the -defunct Uber Southeast Asia operated with a “growth at all costs” mandate. To populate their marketplaces, these companies offered artificially low commission rates, typically ranging from 15% to 20%. In markets like Vietnam and Indonesia, early adopters were frequently onboarded with zero-commission incentives for the 6 to 12 months. This period was defined by venture capital subsidies paying merchants to join the ecosystem, creating a dependency that would later be exploited.

The Post-Uber Pivot (2018–2019)

The turning point arrived with Uber’s exit from Southeast Asia in March 2018. With the primary competitive threat neutralized, the surviving duopoly of Grab and Gojek began an immediate recalibration of their pricing power. By late 2019, the average base commission for new food delivery merchants in Singapore and Thailand had quietly climbed to 25%. The “exclusive partner” model was introduced during this window, offering merchants a slightly lower rate (typically 25%) in exchange for platform exclusivity, while non-exclusive merchants were penalized with rates as high as 30%.

Pandemic Lock-in and the 30% Standard (2020–2022)

The COVID-19 pandemic served as an accelerant for fee increases. With dining-in prohibited or restricted, restaurants had no alternative but to accept platform terms. By 2021, the standard commission rate across major markets—Singapore, Thailand, and the Philippines—had solidified at 30%. In Thailand, the “GP” (Gross Profit) share model became the industry standard, with GrabFood and LINE MAN charging restaurants approximately 30% on every order. Data from 2021 indicates that while platforms offered temporary “support packages” or marketing credits, the base contractual rates remained rigid.

“The math changed overnight. In 2017, we paid 15% and got free marketing. By 2021, we were paying 30% just to be visible, with another 5-10% required for ad spend to appear in the top carousel.” — Restaurant Association Representative, Bangkok (2024)

The Profitability Squeeze (2023–2025)

The most aggressive hikes occurred following the public listings of Grab (2021) and GoTo (2022). Under immense pressure to deliver net profits, these companies ceased subsidies and introduced fees. In Singapore, Grab increased its platform fee from S$0. 70 to S$0. 90 in January 2025, while Gojek raised its fee to S$0. 50. While these are consumer-facing fees, they are part of a broader yield-maximization strategy that includes higher merchant commissions.

The exit of lower-cost competitors further reduced pricing pressure. Foodpanda’s exit from Thailand in May 2025 and Gojek’s withdrawal from Vietnam in September 2024 removed the last checks on market dominance. In Vietnam, where commissions had historically been lower (20-25%), rates began trending toward the regional norm of 30% immediately following Gojek’s departure.

Evolution of Standard Merchant Commission Rates (2015–2025)

Year	Average Commission Rate	Market Context
2015–2017	15% – 20%	Heavy VC subsidies; aggressive merchant acquisition.
2018–2019	20% – 25%	Uber exits SEA; introduction of “exclusive” tiers.
2020–2022	25% – 30%	Pandemic demand lock-in; 30% becomes the new standard.
2023–2025	30% – 35%	Post-IPO profitability drive; exit of competitors (Foodpanda TH, Gojek VN).

As of late 2025, the “take rate” for a non-exclusive merchant in a Tier-1 city like Bangkok or Jakarta frequently exceeds 35% when mandatory marketing contributions and delivery surcharges are factored in. The 2025 exit of Robinhood, a zero-commission delivery app in Thailand backed by Siam Commercial Bank, marked the final failure of the low-fee alternative model, leaving merchants with no use to negotiate against the entrenched giants.

The Fintech Trap: Digital Banking as an Anti-Competitive Moat

While Grab and GoTo publicly market their financial services as tools for “financial inclusion” to aid the unbanked, the data reveals a more calculated strategy: the construction of a high-margin debt trap that locks users into their ecosystems. By 2025, these “super apps” have pivoted from subsidized ride-hailing to predatory fintech, using their duopoly power to force adoption of their own high-interest credit products.

The mechanics of this “fintech trap” are visible in the revenue shifts. Grab’s financial services revenue surged to $253 million for the full year 2024, a 44% year-over-year increase. This growth was not driven by low-cost savings accounts, but by high-yield lending. By the fourth quarter of 2025, Grab’s total loans disbursed grew by 53% to $979 million. Similarly, GoTo’s financial technology segment saw its core Gross Transaction Value (GTV) jump 65% year-over-year in Q2 2024, with its outstanding loan book more than tripling to 3. 5 trillion rupiah ($215 million). These figures confirm that credit issuance has become the primary engine for monetization, replacing the low-margin transport business.

The High Cost of “Inclusion”

The “inclusion” offered by these platforms comes at a steep price for Southeast Asia’s working class. Unlike traditional bank loans capped by stricter regulatory oversight, the Buy, Pay Later (BNPL) and micro-loan products in these apps carry interest rates that rival credit cards, frequently disguised as “processing fees.”

For instance, GoTo’s GoPay Later product charges a flat fee starting at 2% per month for short tenors. While this appears low, it annualizes to an Interest Rate (EIR) exceeding 24%, far above the prime lending rates in Indonesia. Grab’s PayLater in Malaysia imposes a 1. 5% “processing fee” per instalment for longer plans. For a missed payment, users face immediate penalties—RM10 per missed instalment for Grab, and daily fines for GoTo after a short grace period. These fee structures disproportionately impact the gig workers and lower-income users who rely on these apps for daily necessities.

Table 6. 1: The Duopoly’s Fintech Arsenal (2024-2025 Data)

Metric	Grab (GrabFin / GXS / GXBank)	GoTo (GoTo Financial / Bank Jago)
Primary Digital Bank	GXS Bank (SG), GXBank (MY), Superbank (ID)	Bank Jago (ID) (22% stake)
Active Users (2025)	50 Million+ Monthly Transacting Users	20. 6 Million Monthly Transacting Users
Loan Book Growth	+53% YoY (Q4 2025)	+300% YoY (Q2 2024)
Standard BNPL Fee	1. 5% per instalment (MY 8-12 mo. plans)	2. 0% – 2. 75% flat fee per month
Late Payment Penalty	RM10 flat fee per missed instalment	Rp2, 000 daily fine (after 5 days)

Ecosystem Lock-in and Data Monopoly

The anti-competitive nature of this fintech push lies in the “walled garden” effect. Both companies use their dominance in transport and food delivery to strong-arm merchants and consumers into their financial ecosystems. In Indonesia, GoTo’s integration with Bank Jago allows it to funnel its 15. 3 million bank customers (as of late 2024) directly into its e-commerce and ride-hailing loops. Data from 2024 shows that 67% of Bank Jago’s new funding accounts originated directly from the GoTo ecosystem.

This integration creates a barrier to entry for standalone digital banks. A competitor cannot simply offer a better interest rate; they must overcome the friction of an app that users already open five times a day for food and travel. Grab has replicated this model with Superbank in Indonesia and GXBank in Malaysia, leveraging its 50 million monthly users to drive deposits that are then lent back to the same user base at a premium. The result is a closed-loop economy where the platform controls the transaction, the payment rail, and the credit line, acting as both the marketplace and the taxman.

“The mathematical reality is that combining these market positions creates a near-monopoly. A merger would result in 90% control of ride-hailing and substantial power in digital payments, where the entity could control upwards of 85% of the market.” — Verry Iskandar, Partner at Soemadipradja & Taher (July 2025)

Regulatory Blind Spots

Regulators in Singapore and Indonesia have been slow to address the cross-sector use these super apps wield. While the Competition and Consumer Commission of Singapore (CCCS) fined Grab and Uber in 2018 for their merger, the current threat is more subtle. By 2025, the problem is no longer just horizontal consolidation in ride-hailing, but vertical integration where financial data from rides is used to price predatory loans. The “super app” model allows these firms to bypass traditional credit scoring, using behavioral data—like how frequently a user orders food or rides—to underwrite loans. While, this practice raises serious privacy concerns and creates an information asymmetry that traditional banks cannot compete with.

The failure to regulate this intersection of big data and high-interest lending has left the region’s digital economy. As Grab and GoTo continue to deepen their fintech moats, they are not servicing the unbanked; they are converting a captive audience into a permanent debtor class.

Gig Labor Arbitrage: Wage Stagnation Amidst Record Revenues

While Southeast Asia’s super apps celebrate their years of sustained profitability, the gig workers fueling this financial turnaround face a clear different reality. By February 2026, a clear has emerged: platform revenues and take rates have surged to record highs, while driver earnings have stagnated or collapsed in real terms. This phenomenon, a form of labor arbitrage, relies on a surplus of driver supply to suppress wages while simultaneously extracting higher fees from both workers and consumers.

The financial reports from late 2024 and early 2025 paint a picture of corporate triumph built on austerity for the workforce. Grab Holdings reported a full-year 2024 revenue of $2. 78 billion, a 19% year-over-year increase, achieving a record Adjusted EBITDA of $313 million. Similarly, GoTo Group swung to positive adjusted EBITDA in the quarter of 2025. yet, these balance sheet victories were not shared with the fleet. In Singapore, private-hire drivers reported a 10% to 20% drop in take-home income between mid-2024 and early 2025, even with working identical or longer hours. The primary drivers of this decline were “optimized” incentive structures—corporate speak for reduced bonuses—and the dilution of earnings caused by oversaturated driver pools.

The Fee Escalation method

To secure their margins, platforms have systematically increased the “take rate”—the percentage of Gross Merchandise Value (GMV) retained by the company. This is frequently achieved through unclear fee structures rather than direct commission hikes, which attract regulatory scrutiny.

In January 2025, Singapore witnessed a coordinated hike in platform fees. Grab increased its platform fee from $0. 70 to $0. 90 per ride, while Gojek raised its fee to a range of $1. 00 to $1. 50. While these companies publicly stated that the hikes were to cover increased Central Provident Fund (CPF) contributions mandated by the Platform Workers Act, the load shifted to consumers and drivers, as higher total fares frequently dampen demand or reduce the discretionary tips that drivers rely on.

2024-2025: The of Fortunes (Selected Markets)

Metric	Grab / GoTo Corporate Performance	Driver/Partner Reality
Revenue Growth	+19% to +22% YoY (2024-2025)	-10% to -20% Real Income (Singapore/Indonesia)
Incentive Spend	“Optimized” (Reduced as % of GMV)	Bonuses harder to hit; tiers elevated
Work Hours	Corporate headcount stabilized	Increased to 12-14 hours/day to maintain parity
Commission/Fees	take rate increased via “Platform Fees”	Capped at 20% nominally, but higher

The “Partner” Revolt: Strikes and Protests

The disconnect between corporate narrative and street-level reality has sparked significant labor unrest. In Indonesia, the region’s largest market, the tension boiled over in August 2024 when over 1, 000 drivers staged strikes in Jakarta, protesting low fares and demanding the government enforce a strict 20% cap on total deductions. This was followed by a massive mobilization in May 2025, where approximately 25, 000 drivers across the archipelago protested a rumored merger between Grab and GoTo, fearing that a monopolistic consolidation would further their bargaining power.

Drivers that while the nominal commission is capped at 20%, the addition of application fees, top-up costs, and other deductions frequently pushes the take rate closer to 30%. In Vietnam, similar grievances have, with drivers squeezed by rising petrol prices that platforms have been slow to offset with fare adjustments. The “partnership” model, which legally classifies drivers as independent contractors, absolves the platforms of minimum wage obligations, allowing them to offload the inflationary costs of fuel and vehicle maintenance entirely onto the workforce.

The 14-Hour Day: Data vs. Reality

A contentious point in the labor debate is the measurement of “fair pay.” A study commissioned by the International Labor Organization (ILO), released in February 2026, claimed that Transport Network Vehicle Service (TNVS) drivers in the Philippines earned an average net weekly income of 6, 704 PHP ($120 USD), surpassing the national minimum wage. yet, labor groups immediately contested these findings, noting that the data failed to account for the sheer volume of hours required to achieve that sum.

Ground reports indicate that to hit these “above minimum wage”, Filipino drivers are averaging 12 to 14 hours on the road daily, up from 8 to 10 hours in 2021. The hourly wage, when adjusted for the true time commitment and the uncompensated “dead miles” spent waiting for bookings, frequently falls the poverty line. This “time theft”—where unpaid waiting time is a feature, not a bug, of the algorithm—remains the central method of gig labor arbitrage.

“We are working factory hours in a casino economy. The house always wins, and we just pay for the gas.” — Statement from a representative of the National Online Taxi Coalition (Indonesia), August 2024.

Data Silos and Cross-Vertical Targeting: The Privacy Black Box

The “super app” model, championed by Grab and GoTo, is frequently sold to Southeast Asian consumers as a triumph of convenience. The reality is a triumph of surveillance. By February 2026, these platforms have evolved into closed-loop data ecosystems where every interaction—a morning commute, a lunch order, a digital payment—is harvested to build high-fidelity user profiles that traditional banks and competitors cannot match. This is not service integration; it is the weaponization of behavioral data to lock in users and lock out competition.

The core method driving this monopoly is cross-vertical targeting. Unlike a standalone ride-hailing app or a dedicated digital bank, a super app observes a user’s life from multiple angles simultaneously. In early 2026, Grab Finance solidified this advantage by expanding its partnership with analytics firm FICO. The collaboration uses the “FICO Platform” to ingest non-traditional behavioral signals—ride frequency, merchant revenue stability, and location history—to generate real-time credit scores. While marketed as “financial inclusion” for the unbanked, this system converts a user’s physical movements into a financial gatekeeper. A missed ride payment or a change in commute patterns can silently influence a user’s eligibility for a loan or a “Buy, Pay Later” (BNPL) offer.

This data alchemy creates a formidable barrier to entry. A traditional bank in Indonesia or Singapore assesses creditworthiness based on income statements and credit bureau history. Grab and GoTo assess it based on how frequently a user orders premium food delivery or whether they travel to high-income commercial districts. This information asymmetry renders the market uncompetitive; external lenders cannot price risk as accurately because they are blind to the granular, daily behavioral data that the duopoly hoards.

Table 8. 1: The Super App Data-to-Product Pipeline (2024-2026)
Mapping how non-financial behavioral metrics are converted into financial products.

User Behavior Tracked	Inferred Metric	Resulting Financial Product
Ride Consistency (e. g., Daily commute to CBD)	Income Stability & Employment Status	Pre-approved “PayLater” limits; Micro-loans.
Food Order Value (e. g., Average basket size>$20)	Disposable Income Level	Premium credit card offers; Wealth management ads.
Location History (e. g., Frequent late-night trips)	Risk Profile / Lifestyle Stability	insurance pricing (higher premiums for “risky” profiles).
Merchant Activity (e. g., Restaurant opening hours)	Business Cash Flow	Merchant working capital loans (daily repayment deducted from sales).

The opacity of these algorithms extends beyond credit scoring to basic pricing. A July 2024 investigation by the Philippine Center for Investigative Journalism (PCIJ) exposed the “black box” nature of Grab’s surge pricing algorithms. The investigation revealed that higher fares did not consistently correlate with shorter wait times, contradicting the supply-and-demand justification typically used to defend surge pricing. Instead, the algorithm appeared to maximize revenue extraction based on user willingness to pay, leveraging the platform’s dominance to dictate prices without transparency. Users are left paying a premium not for efficiency, but for the platform’s monopoly power.

Regulatory bodies in the region have struggled to keep pace with this dominance. In Singapore, the Personal Data Protection Commission (PDPC) has penalized Grab multiple times for data breaches, including a S$10, 000 fine in September 2020 when a flaw in the GrabHitch app exposed the data of over 21, 000 users. yet, these fines are negligible compared to the revenue generated by the data itself. The maximum financial penalty under Singapore’s amended PDPA was raised to 10% of annual turnover October 2022, yet enforcement actions rarely reach these ceilings for operational lapses, leaving the core business model of aggressive data harvesting largely untouched.

In Indonesia, the Personal Data Protection (PDP) Law, which became fully in October 2024, theoretically imposes stricter consent requirements and mandates data portability. yet, the “state-loss” doctrine complicates enforcement against entities with state-owned enterprise (SOE) investment. With Telkomsel holding a stake in GoTo, and the ongoing scrutiny over SOE investment losses, the regulatory environment is politically charged. The intersection of business risk and state asset protection creates a fog of war that frequently shields these national champions from the aggressive antitrust and privacy audits seen in the European Union.

“We had millions of drivers and merchants who were invisible to traditional banks but were earning real income every day on our platform. We knew we could change that equation.” — Andre Tan, Regional Head of Lending Risk Platforms at Grab Finance, commenting on the FICO partnership, February 2026.

This statement show the double-edged sword of the super app model. The “invisibility” to traditional banks is cured not by open banking standards that would allow users to take their data to any lender, but by enclosing the user in a proprietary garden. The data silo does not just protect privacy; it protects the platform’s ability to cross-subsidize and predatory price. When a super app knows a user’s credit risk better than the user does, the power shifts entirely from service provider to economic governor.

Blocks to Entry: Why Foodpanda and AirAsia Superapp Faltered

The consolidation of Southeast Asia’s digital economy into a duopoly was not a product of Grab and GoTo’s operational excellence, but a testament to the blocks erected against challengers. By 2024, the “super app” model had calcified, creating a market environment where capital efficiency and network density acted as impenetrable moats. The struggles of Foodpanda and the AirAsia Superapp (later rebranded as AirAsia MOVE) serve as primary case studies in this failure to breach the incumbents’ defenses.

Foodpanda, owned by Berlin-based Delivery Hero, entered 2024 with a defensive strategy that signaled its inability to compete for market leadership. even with being an early mover in the region, the platform’s market share eroded significantly as it failed to match the cross-vertical subsidies that Grab utilized to lock in users. In February 2024, negotiations for Delivery Hero to sell its Southeast Asian operations—spanning Singapore, Malaysia, the Philippines, and Thailand—collapsed after parties could not agree on valuation. This failed exit was a serious indicator of the asset’s diminishing use. By the end of 2024, Foodpanda held approximately 16% of the region’s food delivery Gross Merchandise Value (GMV), a clear contrast to Grab’s commanding 55% share.

The mechanics of Foodpanda’s decline reveal the lethality of the “ecosystem tax.” Unlike Grab, which could cross-subsidize food delivery promotions with high-margin mobility revenues or fintech transaction fees, Foodpanda operated primarily as a single-vertical logistics player. This structural disadvantage forced the company into a pattern of cost-cutting. Throughout 2023 and 2024, Foodpanda executed multiple rounds of layoffs across its Asia-Pacific offices to losses, prioritizing unit economics over the aggressive growth required to challenge a duopoly. The platform’s retreat was further evidenced by the rise of ShopeeFood, which, backed by the deep pockets of Sea Limited’s e-commerce arm, began to encroach on Foodpanda’s position as the second-largest player in key markets like Vietnam and Indonesia.

2024 Southeast Asia Food Delivery Market Share (GMV)

Platform	Regional GMV Share (Est.)	Key Strategic Weakness
Grab	55%	N/A (Market Leader)
Foodpanda	16%	Single-vertical reliance; absence of ride-hailing cross-sell
Gojek (GoTo)	10%	Concentrated primarily in Indonesia
ShopeeFood	12%	Dependent on e-commerce ecosystem subsidies

The failure of the AirAsia Superapp (Capital A) to disrupt the market show a different barrier: the sheer cost of building fleet density. Launched with the ambition of rivaling Grab by leveraging AirAsia’s travel database, the app struggled to convert airline passengers into daily active users for ride-hailing and food delivery. By early 2024, the company rebranded its digital arm to “AirAsia MOVE,” a tacit admission that the broad “super app” dream was unsustainable. Instead, it pivoted back to its core competency: travel booking and airport-related services.

Financial disclosures from Capital A in 2024 highlighted the severity of the challenge. While the group reported revenue growth, its ride-hailing division, AirAsia Ride, faced chronic driver absence, particularly during peak demand periods like Ramadan. In Q1 2024, the ride-hailing segment saw a 24% drop in Gross Booking Value (GBV) due to an inability to supply enough drivers to match demand. This supply-side failure illustrates the “cold start” problem: without the massive liquidity of drivers that Grab and GoTo had spent billions accumulating over a decade, new entrants could not offer the reliability needed to retain customers, regardless of price incentives.

Furthermore, the capital requirements to break the duopoly proved prohibitive. Grab and GoTo had already absorbed billions in losses to build their networks. For AirAsia, attempting to replicate this infrastructure while simultaneously recovering from the pandemic’s devastation on its airline business was fiscally impossible. The “super app” thesis requires high-frequency daily usage—ride-hailing and food delivery—to drive engagement for lower-frequency, higher-margin services like travel and finance. AirAsia MOVE’s inability to capture that high-frequency daily utility left it as a niche travel companion rather than a daily lifestyle operating system.

, the faltering of these challengers solidified the market structure. The blocks to entry in Southeast Asia are no longer just about technology; they are about the immense capital moats required to sustain logistics networks and the regulatory inertia that favors established giants. For new entrants, the window to build a generalist super app has likely closed, leaving the field to specialized vertical players or the two entrenched hegemons.

Malaysia’s Competition Act Amendment: Closing the Digital Gap

For seven years, Malaysia stood as a regulatory anomaly in Southeast Asia: a major digital economy with no legal method to block monopolies from forming through acquisition. This legislative void allowed the 2018 merger between Grab and Uber to proceed unchecked in the Malaysian market, while neighboring Singapore and the Philippines levied heavy fines and imposed strict operational conditions. By February 2026, yet, the era of permissive consolidation ended. The Malaysia Competition Commission (MyCC) has moved to close this loophole with the most significant overhaul of the Competition Act 2010 since its inception, introducing a rigorous merger control regime designed specifically to the “buy-to-kill” strategies of Super Apps.

The urgency of these amendments was underscored by a stinging legal defeat for the regulator in late 2025. On October 14, 2025, the Federal Court dismissed MyCC’s final application to reinstate a proposed RM86. 77 million fine against Grab for abusive clauses imposed on drivers. The court’s decision, which hinged on procedural technicalities regarding the “proposed” nature of the penalty rather than the substance of the anti-competitive conduct, exposed the toothlessness of the existing framework. MyCC CEO Iskandar Ismail characterized the loss not as a vindication of the platform’s practices, but as a “structural failure” of the old law, stating that digital giants had long “disguised dominance as efficiency” while operating in a regulatory blind spot.

The Merger Control Regime: A Hybrid Shield

The core of the amendment is the introduction of a hybrid merger control regime, a direct response to the unchecked consolidation of the p-hailing (parcel and food delivery) and e-hailing sectors. Unlike the voluntary notification systems that previously allowed giants to bypass scrutiny, the new law mandates compulsory notification for any merger exceeding a defined monetary threshold. Transactions falling this threshold but possessing high “competitive impact” risks—common in the tech sector where startups with low revenue but high user bases are acquired—can be voluntarily notified or called in by MyCC for review.

Under the new Section 10 provisions, MyCC gains the power to:

“Unwind completed mergers that substantially lessen competition, impose interim measures to freeze integration during investigations, and levy penalties up to 10% of global turnover for failure to notify.”

This “look-back” capability is serious. It addresses the “killer acquisition” phenomenon where Super Apps acquire nascent competitors solely to shut them down and migrate their user base. The amendments also refine the definition of “market” to encompass multi-sided digital platforms, ensuring that GMV (Gross Merchandise Value) and data concentration are weighed alongside traditional revenue metrics.

The 2024-2025 Digital Economy Market Review

The legislative push was grounded in data from MyCC’s detailed Market Review on the Digital Economy Ecosystem, conducted between July 2024 and December 2025. The review dissected four key sub-sectors: mobile operating systems, retail e-commerce, digital advertising, and online travel agencies (OTAs). The findings were clear. The report identified a “web of market struggles” where proprietary algorithms and exclusive data access created blocks for local entrants.

The review highlighted that while the digital economy contributed significantly to national GDP, the benefits were increasingly concentrated. In the food delivery sector alone, the review found that commission structures had calcified at 25-30% even with increased volume, a classic symptom of duopolistic pricing power. These findings provided the empirical bedrock for the Ministry of Domestic Trade and Cost of Living to fast-track the bill to Parliament in late 2025.

Timeline of Enforcement Failure and Reform

The trajectory of Malaysia’s competition enforcement reveals a painful learning curve, where initial regulatory paralysis necessitated the draconian reforms coming into force.

Table 10. 1: The MyCC vs. Grab Legal Saga (2018–2025)

Date	Event	Outcome/Significance
March 2018	Grab acquires Uber’s SEA operations.	Regulatory Gap: MyCC cannot intervene due to absence of merger control powers.
Oct 2019	MyCC proposes RM86. 77 million fine.	Allegation: Grab abused dominance by preventing drivers from promoting competitors.
July 2023	High Court quashes the proposed fine.	Procedural Loss: Court rules MyCC breached natural justice; no internal appeal method existed.
March 19, 2025	Court of Appeal dismisses MyCC appeal.	Judicial Blow: Court upholds that “proposed decisions” are amenable to judicial review, paralyzing enforcement.
Oct 14, 2025	Federal Court rejects final leave to appeal.	Final Defeat: The RM86. 77m fine is dead. MyCC pivots to legislative amendment.
Dec 2025	Competition Act Amendments tabled.	The Fix: New powers to block mergers and clearer investigation procedures introduced.

For the Super App Duopoly

The implementation of these amendments fundamentally alters the exit strategy for startups in Malaysia. The “build-to-flip” model, where local innovators aim solely to be bought by Grab or GoTo, faces a regulatory firewall. For the incumbents, the days of expanding market share through checkbook diplomacy are over. MyCC has signaled that future investigations can focus on “ecosystem locking”—the practice of using dominance in ride-hailing to cross-subsidize and monopolize financial services or logistics.

With the legal battles of 2025 settled, the regulator has traded its blunt instrument of fines for the sharper tool of structural remedies. The message to the region’s digital giants is clear: the Malaysian market is no longer a lawless frontier for consolidation.

The Exclusivity Clause: Forcing Merchants into Single-Platform Deals

The battle for Southeast Asia’s digital economy is not fought with consumer subsidies but through the systematic enclosure of supply. For millions of small and medium-sized enterprises (SMEs), particularly in the food and beverage sector, the “choice” to join a platform has mutated into a contractual ultimatum. By 2024, the prevailing commission structure across the region had calcified into a binary trap: merchants could either pay a standard commission rate of 30% to remain independent or accept a reduced rate—typically 20% to 25%—in exchange for signing an exclusivity agreement. For a low-margin hawker in Jakarta or a bubble tea shop in Manila, this 5-10% differential is not a business expense; it is the difference between solvency and bankruptcy.

This method, frequently branded under euphemisms like “Signature,” “Preferred,” or “Super Partner,” penalizes multi-homing—the practice of listing on multiple apps to maximize reach. In Indonesia, the Business Competition Supervisory Commission (KPPU) has repeatedly flagged these arrangements under Article 15 of Law No. 5/1999, which prohibits “exclusive dealing” agreements that impede competition. Yet, the enforcement gap allows the practice to in “soft” forms. A merchant is technically free to list elsewhere, but doing so strips them of the “Preferred” badge, removes them from the app’s high-visibility carousels, and hikes their transaction fees by up to 50%. The result is a de facto monopoly at the neighborhood level, where a consumer opening GrabFood sees a completely different restaurant inventory than one opening GoFood, not due to culinary specialization, but due to contractual lock-in.

The Cost of Freedom: Merchant Commission Tiers (2023-2024)

Platform	Market	Standard Commission (Non-Exclusive)	Exclusive Partner Commission	“Soft” Penalties for Non-Exclusivity
GrabFood	Regional (Avg)	30%	25% + Marketing Support	Loss of “Signature” badge, lower algorithmic ranking, exclusion from “Free Delivery” promos.
GoFood	Indonesia	20% + 1, 000 IDR	Variable (Tiered Benefits)	Reduced visibility in “Near Me” feeds; higher delivery fees for customers.
ShopeeFood	Vietnam/Malaysia	25% – 30%	~20%	Ineligibility for platform-funded discount vouchers.

Regulatory bodies have attempted to these walls with varying degrees of success. In Singapore, the Competition and Consumer Commission of Singapore (CCCS) set a precedent in 2018 following the Grab-Uber merger. The watchdog fined the parties a combined S$13 million and explicitly ordered Grab to remove exclusivity obligations from its drivers and taxi fleets. While this ruling primarily addressed transport, it sent a warning shot regarding merchant exclusivity. In 2020, Thailand’s Trade Competition Commission (TCCT) followed suit, issuing guidelines that specifically identified “exclusive dealing” without justification as an unfair trade practice, forcing platforms to justify their tiered commission structures.

The Philippines has taken the most aggressive recent stance. The Philippine Competition Commission (PCC) has kept Grab under a microscope since 2018, imposing cumulative fines exceeding PHP 63 million for various breaches, including pricing and service quality. In a significant move, the PCC and Grab signed a “2025 Undertaking” to extend the independent monitoring of Grab’s driver incentives and non-exclusivity commitments. This continued scrutiny highlights the regulator’s recognition that without constant vigilance, the natural tendency of the super app model is to revert to a “walled garden” state, where the platform, not the consumer, dictates the market.

“The danger is not just high fees; it is the invisibility of the non-exclusive merchant. If you do not sign the deal, the algorithm buries you. You are free to leave, but you are also free to starve.”

The economic impact of these clauses extends beyond the merchants themselves. By fragmenting the supply, platforms artificially lower the utility of the network for consumers, who must download multiple apps to access the full range of local services. For the platforms, yet, the strategy is rational. Lock-in reduces the “churn” of merchants to competitors like Foodpanda or AirAsia Superapp ( Move), creating a defensive moat that has little to do with service quality and everything to do with contract law. As the region’s digital economy matures, the of these exclusivity clauses remains the single most serious step toward restoring a competitive, open market.

Philippines PCC: Investigating Late Payment pattern for Vendors

The Philippine Competition Commission (PCC) has intensified its scrutiny of the “super app” duopoly, shifting focus from consumer pricing to the financial stranglehold these platforms exert on Micro, Small, and Medium Enterprises (MSMEs). While public attention in 2023 and 2024 centered on the PCC’s P63. 7 million and subsequent P9 million fines against Grab Philippines for delayed consumer refunds, a parallel and equally serious investigation has targeted the operational “black box” of vendor remittances. For thousands of restaurant partners, the difference between a daily payout and a 14-day remittance pattern is the difference between solvency and bankruptcy.

In early 2022, a viral complaint from a small business owner exposed the in payment terms that defines the current market. The merchant revealed that Foodpanda Philippines enforced a “2-week payment scheme,” holding vendor capital for half a month, whereas GrabFood offered a daily remittance model. This operational is not a matter of policy but a symptom of market power; in a competitive, platforms would race to offer the fastest liquidity to attract merchants. In a duopoly, terms are dictated, not negotiated.

The “Float” Economy: Vendor Liquidity vs. Platform Cash Flow

The PCC’s monitoring of “abuse of dominance” under Section 15 of the Philippine Competition Act (PCA) encompasses these unilateral payment terms. Regulators are examining whether the extended remittance pattern constitute an unfair trade practice that forces small vendors to essentially provide interest-free loans to the platforms. For a small carinderia or milk tea shop operating on thin margins, a 14-day delay in receiving revenue from 30% to 50% of their daily orders creates an unsustainable cash flow gap.

Comparative Payment pattern & Vendor Costs (2022-2024)

Platform	Standard Remittance pattern	Commission Rate (Est.)	Vendor Complaint Focus
GrabFood	Daily ( Banking Day)	25% – 30%	High commissions; occasional system glitches delaying “daily” transfers.
Foodpanda	Bi-Weekly (14 Days)	25% – 30% + Add-ons	Extended capital hold; “Agency fees” and tax pass-throughs reducing net income.
Direct/In-House	Immediate (Cash/GCash)	0% (Logistics cost only)	Limited reach; high marketing effort required.

The Department of Trade and Industry (DTI) has corroborated these friction points through its mediation channels. Between 2022 and 2024, the DTI received a surge in complaints not just regarding delayed deliveries, but specifically about “unreasonable charges” and “delayed remittances.” In one documented instance, a merchant noted that after the 27% commission, 12% VAT, and additional “agency fees” were deducted, the net payout was delayed by weeks, leaving them unable to restock inventory. This practice transfers the financial risk of the delivery ecosystem onto its smallest participants.

Regulatory Precedents and Future Enforcements

The PCC’s aggressive stance on Grab’s consumer refunds serves as a warning shot for vendor payments. In May 2023, the Commission imposed a P9 million fine on Grab for failing to fully refund customers more than three years after the initial order. This pattern of “holding” funds—whether from consumers or vendors—is central to the antitrust probe. If a platform can delay P25 million in consumer refunds for years, the widespread delay of millions in vendor payouts raises similar concerns about the misuse of market dominance to platform liquidity at the expense of partners.

Furthermore, the legislative branch has moved to criminalize “hoax ordering” and fake bookings, which exacerbate payment delays. When a rider or vendor is victimized by a fake order, the reversal of funds frequently takes weeks, freezing capital that the vendor cannot access. The PCC and DTI are currently harmonizing their oversight to ensure that “super apps” cannot hide behind bureaucratic to justify these delays. The message from the regulators is clear: operational dominance does not grant the right to act as a de facto bank, holding merchant capital hostage to subsidize platform operations.

“Competition—or the absence of it—can be felt at home, at work, and in one’s daily activities. The may have chosen [a provider], but the developer should not limit the choices… for other services.”
— Arsenio Balisacan, Former PCC Chairman (referencing the landmark Abuse of Dominance case which set the precedent for current digital market probes).

As of late 2024, the PCC continues to monitor these payment pattern as part of its voluntary commitment reviews. While no specific “vendor payment” fine has matched the magnitude of the consumer refund penalties yet, the framework is in place. The investigation highlights a serious reality of the Southeast Asian digital economy: without strict regulatory intervention, the efficiency gains of the “super app” model are frequently extracted from the margins of the very vendors who populate the platform.

Thailand’s TCCT: The Battle Over Capped Delivery Fees

In the high- arena of Southeast Asia’s digital economy, Thailand became the primary battleground for one of the region’s most contentious regulatory fights: the war over Gross Profit (GP) commission fees. While Indonesia and Singapore allowed market forces to largely dictate platform economics, Thailand’s Trade Competition Commission (TCCT) launched a targeted intervention that fundamentally altered the operating for super apps. The conflict centered on the standard 30% to 35% commission fees charged to restaurants—a rate that vendors, particularly small street food hawkers (SMEs), decried as predatory during the pandemic-induced lockdowns of 2020 and 2021.

The regulatory friction began in earnest when the TCCT issued the Guidelines on Unfair Trade Practices between Digital Platform Operators for Food Delivery and Restaurants, which came into effect on December 23, 2020. Unlike the hard price caps seen in U. S. cities like San Francisco or New York, the Thai regulator opted for a “fairness doctrine” method. The guidelines prohibited platforms from charging “unreasonable” fees or increasing rates without justification. While it stopped short of mandating a 15% cap—a figure publicly floated by the Department of Internal Trade (DIT) and demanded by vendor associations—it froze the aggressive fee hikes that had characterized the early expansion phase of Grab and Foodpanda.

The “Zero-GP” Disruption and Market Correction

The regulatory pressure was compounded by a unique market: the entry of Robinhood, a delivery platform backed by Siam Commercial Bank (SCB X). Launching with a strictly “zero-GP” model, Robinhood acted as a non-profit market corrective, onboarding over 200, 000 small merchants who could not afford the 30% cut demanded by the giants. This “white knight” strategy forced competitors to react; Grab and LINE MAN Wongnai were compelled to introduce tiered commission structures and temporary fee reductions to prevent a merchant exodus.

yet, the sustainability of this model was short-lived. By mid-2024, SCB X announced the closure of Robinhood, citing cumulative losses that had widened to 2. 1 billion baht ($58 million) in 2023. The platform was eventually saved from total dissolution in September 2024, when it was acquired by a consortium led by the Yip In Tsoi Group. The acquisition marked the end of the “zero-GP” era, as the new owners transitioned the platform toward a commercial model, realigning market rates closer to the industry standard of 20-25%.

The 2025 Consolidation: A Duopoly Emerges

The regulatory shifted dramatically in May 2025 with the exit of Foodpanda from the Thai market. After years of burning cash to maintain a distant third place, the Delivery Hero-owned entity withdrew, ceding its remaining 5% market share to the dominant players. This exit crystallized a rigid duopoly between Grab and LINE MAN Wongnai, who shared controlled nearly 90% of the market by the end of 2025. ShopeeFood remained as a distant challenger, leveraging its e-commerce logistics network to capture the value-conscious segment.

Thailand Food Delivery Market Share Evolution (2023–2025)

Platform	2023 Share (GMV)	2024 Share (GMV)	2025 Share (GMV)	Status (2026)
Grab Thailand	47%	46%	55%	Market Leader
LINE MAN Wongnai	36%	40%	35%	Strong #2
ShopeeFood	6%	7%	10%	Challenger
Foodpanda	8%	5%	0%	Exited May 2025
Robinhood	3%	2%	<1%	Acquired/Restructured

The Shift to Ex-Ante Regulation

By late 2025, the TCCT acknowledged that reactive (ex-post) fines were insufficient to curb the power of the entrenched duopoly. In response, the commission drafted new “ex-ante” regulations specifically targeting multi-sided platforms. These rules, expected to be fully enforced in 2026, moved beyond simple fee caps to address structural unfairness. Key provisions included a ban on “forced logistics”—where platforms compel merchants to use their proprietary delivery fleets—and strict prohibitions against algorithmic discrimination that favors exclusive vendors.

The battle has thus evolved from a simple dispute over percentage points to a complex war over ecosystem control. While the 30% GP fee remains the nominal standard, the take rate has been obfuscated by a web of advertising fees, priority listing charges, and “marketing contributions” that merchants must pay to remain visible. The TCCT’s new mandate is to untangle this pricing structure, ensuring that the duopoly cannot use its logistical dominance to strangle the very SMEs the digital economy was promised to.

Vietnam’s Local Resistance: Be Group versus the Regional Giants

While Grab and GoTo have carved up much of Southeast Asia, Vietnam remains a stubborn outlier in their conquest. Here, the “super app” narrative has collided with a fierce, localized resistance led by Be Group, a domestic technology company that has refused to yield ground. Unlike the capital-intensive, burn-rate-heavy strategies of its foreign rivals, Be Group has executed a defensive war of attrition, leveraging deep local alliances and a favorable regulatory environment to disrupt the duopoly’s consolidation.

As of early 2026, the battle lines in Vietnam are drawn not just on pricing, but on national identity and regulatory compliance. Be Group, which launched in 2018, has survived the exit of Uber, Gojek, and Baemin, positioning itself as the primary Vietnamese alternative to Singapore-based Grab. The company’s survival strategy hinges on a “transportation-” multiservice model that prioritizes high-frequency utility over the sprawling, frequently incoherent service expansions seen elsewhere.

The Market Share Conflict

Determining the true victor in Vietnam’s ride-hailing war depends entirely on which data source is believed—a gap that highlights the chaotic nature of the market. Reports from Q4 2024 by Mordor Intelligence placed Green SM (Xanh SM), a taxi operator owned by Vingroup’s founder, as the shock market leader with approximately 37. 41% share, edging out Grab’s 36. 62%. In this dataset, Be Group trailed significantly at 5. 55%.

Be Group have vehemently disputed these figures, claiming their internal metrics show a market share closer to 35%. This claim is supported by the company’s operational resilience; in January 2024, Be Group secured $30. 3 million (739. 5 billion VND) in funding from VPBank Securities, a move that would be unlikely for a company holding only a single-digit sliver of the market. Rakuten Insight data from 2025 offers a middle ground, showing Grab with 55% usage frequency, followed by Green SM at 32% and Be at 9%, suggesting that while Grab retains the “top-of-mind” advantage, the combined force of local players is eroding its dominance.

Conflicting Market Share Data: Vietnam Ride-Hailing (2024-2025)

Entity	Mordor Intelligence (Q4 2024)	Rakuten Insight (2025 Usage Freq.)	Company Claimed Share
Green SM (Xanh SM)	37. 41%	32%	N/A
Grab	36. 62%	55%	N/A
Be Group	5. 55%	9%	35%

Strategic Alliances as a Moat

Be Group’s resilience is built on a strategy of “ecosystem borrowing” rather than building everything from scratch. Instead of burning cash to build a digital bank, Be partnered with VPBank to launch “Cake,” a digital banking entity directly into its app. This partnership allows Be to offer financial services without the heavy regulatory capital requirements of a full banking license.

Furthermore, Be Group has turned the rise of electric vehicles (EVs) into a tactical advantage through a partnership with Green and Smart Mobility (GSM). By integrating GSM’s electric taxi fleet into the Be platform, the company instantly expanded its supply without the capital expenditure of purchasing vehicles. This move directly counters Grab’s fleet dominance and aligns Be with Vietnam’s national green energy goals. The company recorded a five-fold growth in Gross Merchandise Value (GMV) from 2021 to 2023 and has set a target of $200 million in annual gross revenue by 2026.

Regulatory Home Field Advantage

The Vietnamese government has increasingly tightened the digital leash, creating an environment that subtly favors domestic entities. The Law on Data, approved in November 2024 and July 1, 2025, imposes strict data localization and processing requirements. Foreign platforms like Grab face higher compliance blocks regarding the storage of “core data” and “important data” within Vietnam’s borders. also, Decree 147/2024, December 2024, mandates rigorous user identity verification, forcing platforms to purge anonymous accounts and share data with authorities upon request—a process frequently smoother for local firms with established government ties.

Tax policy has also shifted. The government’s decision to enforce stricter tax management on digital platforms, requiring them to declare and pay taxes on behalf of drivers, has leveled the playing field. Previously, foreign apps could exploit gray areas in cross-border tax law;, the regulatory gap is closing. For Be Group, which has always operated under local transport and tax frameworks, these changes validate their compliance-heavy business model.

“When a platform serves millions of people, is profitable, and grows at 72% CAGR, a market share estimate of 4-6% only reflects the inadequacy of the measurement method, not the reality of the business.” — Be Group Representative, responding to third-party market reports, February 2026.

The exit of Gojek in September 2024 left a vacuum that Be Group has aggressively moved to fill. By positioning itself as the stable, local alternative to the volatile foreign giants, Be is betting that Vietnamese consumers and drivers can prefer a platform that is not subject to the whims of regional restructuring. With a target of positive EBITDA for the 2024 financial year, Be Group is attempting to prove that a focused, national champion can survive in the shadow of regional monopolies.

Investor Demands: How SoftBank and Alibaba Drive Consolidation

The consolidation of Southeast Asia’s digital economy is frequently framed as a natural market evolution, yet the evidence points to a more orchestrated reality. The trajectory of the region’s “super apps”—Grab, GoTo, and Sea Group—has been dictated less by consumer preference than by the balance sheets of their largest backers: SoftBank Group and Alibaba. By 2025, the era of “growth at all costs” had been forcibly terminated, replaced by a mandate for profitability that reshaped the competitive into a rigid duopoly.

The “Ceasefire” Mandate

The primary architect of this contraction was Masayoshi Son, CEO of SoftBank Group. By 2020, SoftBank’s Vision Fund had poured billions into Grab, fueling a subsidy war that made ride-hailing artificially cheap for millions of Southeast Asians. yet, following the collapse of WeWork and mounting losses in its portfolio, SoftBank’s strategy shifted abruptly from expansion to preservation. In late 2020, Son directly intervened in the rivalry between Grab and Gojek, pressuring the two companies to negotiate a “ceasefire.” Reports from that period indicate Son favored a merger that would see Grab acquire Gojek’s operations in most markets, leaving Indonesia as a shared territory. This pressure was driven by a need to stop the “cash burn” that was hemorrhaging investor capital. While that specific deal collapsed due to antitrust concerns and valuation disagreements, the directive was clear: the subsidy tap was closing.

Alibaba and the GoTo Pivot

While SoftBank pulled strings at Grab, Alibaba exerted its influence through Tokopedia, the Indonesian e-commerce giant it had backed with a $1. 1 billion investment in 2017. By 2021, facing intense competition from Sea Group’s Shopee, Alibaba needed to fortify its Indonesian stronghold. When merger talks between Grab and Gojek stalled, Alibaba blessed an alternative union: the merger of Gojek and Tokopedia to form GoTo in May 2021. This was not a defensive move but a consolidation of capital. By combining Gojek’s logistics fleet with Tokopedia’s commerce platform, Alibaba sought to create a self-sustaining ecosystem capable of rivaling Shopee without requiring endless external capital injections. The formation of GoTo locked the Indonesian market into a three-way battle, protecting Alibaba’s stake while adhering to the broader investor demand for over fragmentation.

The Profitability Squeeze (2022–2025)

The “funding winter” that began in 2022 served as the enforcement method for these investor demands. With interest rates rising and the Vision Fund posting record losses—$32 billion in the fiscal year ending March 2023—SoftBank could no longer subsidize losses. The impact on operations was immediate and severe. Grab, under pressure to demonstrate financial viability, slashed incentives and cut 1, 000 jobs (11% of its workforce) in June 2023. GoTo followed suit, exiting non-core markets like Vietnam and Thailand to focus entirely on Indonesian profitability. These moves were not optional; they were preconditions for continued investor support. By the third quarter of 2023, Grab reported its adjusted EBITDA profit, a milestone achieved not through innovation, but through the systematic of the subsidy structures that had built its user base.

The Investor Mandate: Capital Injections & Strategic Shifts (2017–2024)

Year	Investor	Target	Amount / Action	Strategic Outcome
2017	Alibaba	Tokopedia	$1. 1 Billion Investment	Cemented Alibaba’s control over Indonesian e-commerce infrastructure.
2020	SoftBank	Grab / Gojek	Merger Pressure	Masayoshi Son demands a “ceasefire” to end subsidy wars; initiates merger talks.
2021	Alibaba / SoftBank	GoTo (Gojek + Tokopedia)	Merger Approval	Formation of GoTo to counter Sea Group; consolidates logistics and commerce.
2023	SoftBank (Vision Fund)	Grab	Profitability Ultimatum	Grab cuts 1, 000 jobs and slashes incentives to hit EBITDA breakeven.
2024	ByteDance / GoTo	Tokopedia	Acquisition (75% stake)	TikTok Shop acquires Tokopedia’s operation, ending GoTo’s e-commerce independence.

The Final Consolidation

By 2024, the had shifted again. The aggressive entry of TikTok Shop (owned by ByteDance) forced a new capitulation. Unable to compete with TikTok’s capital, GoTo surrendered operational control of Tokopedia to ByteDance in early 2024, retaining only a minority stake. This move, while dissolving the original “super app” vision of GoTo, was celebrated by investors as a necessary step to stop the bleeding in its e-commerce division. As of early 2026, the pressure remains relentless. With stock prices for both Grab and GoTo languishing their IPO levels, major shareholders continue to agitate for the final endgame: a merger of Grab and GoTo. even with regulatory blocks, the logic of the balance sheet dictates that a monopoly is the only way to recover the billions sunk into the region over the last decade.

The Super App Myth: Unbundling Services for Regulatory Evasion

The narrative of the “super app”—a direct, all-encompassing digital ecosystem—has long served as a convenient shield for Southeast Asia’s duopoly. By claiming to be integrated technology platforms rather than transport, logistics, or financial service providers, Grab and GoTo successfully engaged in regulatory arbitrage for nearly a decade. yet, data from 2024 and 2025 reveals a clear pivot: these companies are quietly unbundling their services, shedding assets, and restructuring operations to evade tightening antitrust nets and financial reality. The “super app” is no longer a product strategy; it is a regulatory camouflage that is rapidly disintegrating.

The most flagrant example of this strategic unbundling occurred in January 2024, when GoTo finalized the sale of a 75. 01% stake in its e-commerce arm, Tokopedia, to TikTok for $840 million. For years, GoTo pitched its “Gojek-Tokopedia-GoTo Financial” trinity as an inseparable flywheel of value. Yet, when Indonesia’s Ministry of Trade banned in-app transactions on social media platforms in late 2023—a move targeting TikTok Shop but threatening the broader ecosystem—GoTo decapitated its own structure. By offloading Tokopedia to a Chinese-owned entity while retaining a passive service fee stream, GoTo admitted that its “super app” integration was fungible. The move was not about user experience; it was a survival tactic to bypass regulatory heat and offload a cash-burning vertical.

The Asset-Light Retreat

Grab has executed a similar, albeit quieter, retreat from the “owned ecosystem” model. Between 2023 and 2024, the Singapore-based giant aggressively shut down its “dark stores” (GrabMart) and cloud kitchens (GrabKitchen), pivoting to an asset-light partnership model with retailers like Trans Retail. While Grab marketed this as an efficiency drive to achieve its annual adjusted profit in 2024, the mechanics suggest a defensive unbundling. By divesting physical assets, Grab distanced itself from the liabilities of inventory management and logistics labor, retreating to the safer, higher-margin role of a rent-seeking matchmaker. This shift complicates antitrust definitions: regulators can no longer easily classify them as logistics operators if they own no warehouses, even with their algorithms dictating the entire supply chain.

Table 16. 1: Strategic Unbundling Events (2023–2025)

Company	Event Date	Action	Regulatory/Financial Implication
GoTo	Jan 2024	Sold 75% of Tokopedia to TikTok	Evaded social commerce ban; offloaded e-commerce losses while keeping fee stream.
Grab	2023-2024	Shut down GrabKitchen & Dark Stores	Shifted to asset-light model to avoid inventory liability and boost margins.
Shopee	Jun 2024	KPPU Antitrust Ruling	Found guilty of monopolizing logistics by favoring Shopee Express; forced to open platform.
Grab/GoTo	2025	Singapore Platform Workers Act	Forced to reclassify gig workers, ending “tech partner” labor arbitrage.

Piercing the “Tech Company” Veil

The primary engine of the super app monopoly—labor arbitrage—suffered a serious blow in 2025. For years, these platforms classified drivers as “partners” to avoid the costs associated with formal employment, a loophole that subsidized their expansion. Singapore’s implementation of the Platform Workers Act in 2025 marked the end of this era in the company’s home market. The legislation forced platforms to provide Central Provident Fund (CPF) contributions and work injury compensation, piercing the corporate veil that separated the “app” from the “employer.”

This regulatory shift has exposed the fragility of the super app unit economics. With the labor cost advantage eroded in Singapore, and similar pressures mounting in Indonesia—where thousands of drivers staged “off-bid” strikes in May 2025 demanding employee recognition—the platforms are scrambling to ring-fence their profitable financial services from their labor-intensive transport arms. The “super app” is increasingly looking like a holding company for businesses with conflicting regulatory needs.

The Algorithmic Tie-In

Regulators are also the algorithmic tying that binds these services together. In June 2024, Indonesia’s antitrust agency (KPPU) ruled against Shopee for restricting consumer choice by prioritizing its own logistics arm, Shopee Express. This precedent is devastating for the super app model, which relies on cross-subsidizing loss leaders (like ride-hailing) with high-margin captive services (like payments or deliveries). If regulators enforce a “neutral platform” mandate, prohibiting the apps from favoring their own payment gateways or delivery fleets, the economic rationale for the super app collapses. The ecosystem becomes a series of standalone competitive markets, exposing the that the monopoly structure previously hid.

Furthermore, the KPPU’s January 2025 fine of $13. 1 million against Google for forcing its billing system on developers serves as a warning shot to Grab and GoTo. Both regional giants rely heavily on “walled garden” payment loops (GrabPay, GoPay) to lock in users and merchants. The Google ruling signals that Southeast Asian regulators are no longer accepting “user experience” as a justification for closed-loop monopolies. The unbundling is not just a corporate strategy; it is becoming a legal mandate.

The Golden Age is Over: From Cash Burn to Cash Cow

The era of the “subsidy war”—where Southeast Asian consumers enjoyed artificially low prices funded by venture capital—has definitively ended. Between 2015 and 2021, Grab and GoTo engaged in a scorched-earth battle for market share, frequently subsidizing up to 50% of a ride’s true cost. By February 2026, this has inverted. With both companies public and under immense pressure to deliver shareholder returns, the focus has shifted from user acquisition to aggressive monetization. The result is a systematic of consumer surplus, visible not just in higher base fares, but in the proliferation of unavoidable “platform fees” and the disappearance of blanket promo codes.

Financial reports from 2025 confirm this pivot is complete. Grab reported its full year of net profit in 2025, posting $268 million in earnings, a clear turnaround from the billion-dollar losses that characterized its growth phase. This profitability was not achieved solely through operational efficiency; it was engineered by transferring costs to consumers. Similarly, GoTo slashed its incentives and marketing spending by approximately 38% in 2023 alone, a strategy that continued through 2024 and 2025 as it raced toward adjusted EBITDA breakeven.

The “Platform Fee” method: Boiling the Frog

The primary vehicle for this price escalation has been the introduction and gradual increase of “platform fees”—surcharges applied to every transaction regardless of distance or demand. These fees, initially introduced as nominal charges for “safety” or “app improvements,” have morphed into a significant revenue stream that bypasses driver earnings entirely.

In Singapore, the trajectory of these fees illustrates the strategy. In May 2023, Grab introduced a flat $0. 70 platform fee. By January 1, 2025, this was hiked to $0. 90. Just one year later, in January 2026, the fee climbed again to $1. 20. Competitors followed suit in a classic oligopolistic lockstep. Gojek, which had maintained a lower fee to undercut Grab, raised its platform fee from $0. 30 to $0. 50 in early 2025, and then aggressively hiked it to a range of $1. 10 to $1. 70 in February 2026. For a short 3-kilometer trip, these fees can constitute over 15% of the total fare, a cost previously non-existent.

The Rise of Platform Fees in Singapore (2023–2026)

Operator	Fee (May 2023)	Fee (Jan 2025)	Fee (Feb 2026)	% Increase (2023-2026)
Grab	S$0. 70	S$0. 90	S$1. 20	+71%
Gojek	S$0. 30	S$0. 50	S$1. 10 – S$1. 70	+266% (min)
TADA	S$0. 55	S$0. 75	S$1. 00	+81%

The Disappearance of Broad-Based Incentives

While base fees rise, the “promo code” economy has collapsed. In 2019, it was common for users to receive unconditional discounts (e. g., “50% off your 5 rides”). By 2025, these have been replaced by highly targeted, algorithmic incentives designed to stimulate specific behaviors rather than reward loyalty. Data from Grab’s Q4 2023 earnings showed incentives had been reduced to 7. 3% of Gross Merchandise Value (GMV), down from double-digit percentages during the peak of the Uber wars. Although there was a slight uptick in incentive spend to ~10% in late 2024 to defend market share, the nature of these incentives has changed. They are no longer “free money” for the consumer; they are frequently tied to subscription models like “GrabUnlimited,” forcing users to pay a monthly fee to access the discounts they once received for free.

In Indonesia, GoTo’s strategy mirrors this trend. The company reported a 61% year-over-year reduction in incentives and marketing spending in Q3 2023, saving nearly Rp 344 billion. This austerity was necessary to reverse a 255% operating margin loss, but it had a chilling effect on consumption. GoTo’s Gross Transaction Value (GTV) growth decelerated significantly in 2023 as price-sensitive users, no longer shielded by subsidies, reduced their frequency of use. The market has segmented: “Saver” options (like GrabShare or longer-wait food delivery) serve the price-conscious demographic at a degradation of service quality, while standard services have become a premium luxury.

The “Saver” Illusion and Service Degradation

To mitigate the shock of rising prices, Super Apps have introduced tiered service levels. Options such as “GrabSaver” or “GoRide Hemat” offer lower fares but come with longer wait times or batched orders. This allows the duopoly to price-discriminate, extracting maximum value from time-sensitive users while retaining lower-value users with a degraded product. In 2024, Grab noted that “Saver” deliveries accounted for 23% of its delivery transactions. This shift signals a permanent structural change: the on-demand convenience that defined the 2015-2020 boom is a premium tier, priced accordingly, while the “affordable” mass-market option has become slower and less reliable.

Regulatory Arbitrage: Exploiting Jurisdictional Gaps in ASEAN

The operational architecture of Southeast Asia’s super apps is built upon a calculated strategy of regulatory arbitrage, leveraging the fractured legal frameworks of the Association of Southeast Asian Nations (ASEAN) to maximize valuation while minimizing compliance costs. While Grab and GoTo project the image of unified regional champions, their corporate structures are designed to exploit the dissonance between Singapore’s rigorous financial oversight and the developing regulatory method of Indonesia, Vietnam, and the Philippines. This jurisdictional fragmentation allows these conglomerates to headquarter in a low-tax, high-stability jurisdiction while deploying capital in markets where labor protections and competition enforcement remain porous.

The in competition law enforcement is the most visible fracture. The aftermath of Grab’s 2018 acquisition of Uber’s Southeast Asian operations serves as the primary case study for this arbitrage. In Singapore, the Competition and Consumer Commission (CCCS) determined the merger substantially reduced competition, levying a combined fine of S$13 million (approximately US$9. 5 million) and imposing strict exclusivity bans. In clear contrast, the Vietnam Competition Council ruled in June 2019 that the same transaction did not violate its Competition Law, citing insufficient evidence of monopoly power even with Grab holding a near-total market share post-merger. This allowed Grab to absorb a financial penalty in one market to secure a monopolistic foothold in another, treating regulatory fines as a cost of customer acquisition.

As of late 2025, this has shifted toward merger control regarding the rumored consolidation between Grab and GoTo. Indonesia’s Business Competition Supervisory Commission (KPPU) operates under a mandatory post-merger notification system, a structural weakness that limits its ability to block anti-competitive deals before they consummate. Unlike the Philippines, which requires pre-merger review for transactions meeting specific thresholds, Indonesia’s retroactive framework forces regulators to attempt to unscramble the egg after integration has occurred. This legal lag incentivizes super apps to execute consolidations rapidly, betting that regulators can be hesitant to a fully integrated operational entity.

The Labor Classification Divide

The most lucrative form of arbitrage exists in the classification of the gig workforce. Super apps have long relied on the “partnership” model to avoid the costs associated with formal employment. yet, 2025 marked the beginning of a sharp legislative within the region, creating a two-tier labor market.

On January 1, 2025, Singapore enforced the Platform Workers Act, a landmark statute creating a distinct legal category for gig workers. This law mandates platform operators to make Central Provident Fund (CPF) contributions for workers born in or after 1995, aligning their social security benefits with formal employees. It also enforces standardized work injury compensation. Conversely, Indonesia continues to rely on the Mitra (partnership) model, where drivers are classified as independent contractors with minimal safety nets. Revisions to Indonesia’s Manpower Law remained in the legislative drafting stage throughout 2025, allowing platforms to cross-subsidize their compliance costs in Singapore with the higher margins derived from low-protection labor in their largest market.

Table 18. 1: Comparative Gig Worker Protections in Key ASEAN Markets (2025)

Jurisdiction	Legal Status	Social Security (Pension)	Injury Compensation	Union Rights
Singapore	Platform Worker (Distinct Class)	Mandatory CPF (Operator + Worker)	Mandatory (WICA aligned)	Platform Work Associations (legal rep)
Malaysia	Self-Employed (Regulated)	Voluntary/Partial (EPF i-Saraan)	Mandatory (SOCSO Scheme)	Limited Association Rights
Indonesia	Mitra (Partner)	Voluntary (BPJS Ketenagakerjaan)	Voluntary / Personal Insurance	Informal Driver Communities
Vietnam	Independent Contractor	Voluntary Social Insurance	None (Platform Discretion)	None

Data Sovereignty and Tax Base

Data localization laws present another frontier for arbitrage. Vietnam’s Decree 53, since late 2022, enforces strict data localization, requiring foreign enterprises to store user data within Vietnamese territory. In response, super apps have adopted a “hub-and-spoke” data architecture. They maintain primary processing and high-value analytics in Singapore—leveraging the city-state’s open data flow corridors established under the PDPA—while establishing minimal viable server presence in Vietnam to satisfy local inspectors. This dual structure allows them to benefit from Singapore’s intellectual property protections while technically complying with Vietnam’s digital sovereignty mandates.

Taxation follows a similar pattern of avoidance. While Indonesia raised its Value Added Tax (VAT) on digital services to 11% in 2022, and the Philippines imposed similar levies, the core revenue recognition frequently bypasses these jurisdictions. By booking regional booking fees and commissions through Singapore-based headquarters, super apps can optimize their corporate income tax exposure. Although Indonesia has introduced “Significant Economic Presence” (SEP) rules to tax entities without physical offices, the enforcement remains complex. The platforms operate as local entities for user acquisition but as foreign digital services for revenue recognition, exploiting the gap between physical operations and fiscal domiciles.

This regulatory patchwork does not complicate compliance; it entrenches the duopoly. Smaller local competitors cannot afford the legal overhead to navigate five different data privacy regimes or the capital reserves to pay Singaporean fines while fighting Indonesian labor disputes. The result is a region united by digital platforms but divided by the laws that govern them, a fragmentation that Grab and GoTo have engineered into a competitive moat.

The Brussels Effect: Importing the ‘Gatekeeper’ Doctrine

The European Union’s Digital Markets Act (DMA), fully applicable as of March 2024, has transcended its continental borders to become the primary architectural blueprint for Southeast Asian regulators. Facing the calcified Grab-GoTo duopoly, regional authorities are abandoning traditional ex-post enforcement—which reacts only after market abuse occurs—in favor of the DMA’s ex-ante “gatekeeper” model. This shift represents a fundamental change in legal philosophy: rather than punishing monopolies for bad behavior, regulators are moving to define strict behavioral parameters before dominance is even leveraged.

For Southeast Asia, the appeal of the DMA lies in its clarity regarding “core platform services.” The EU model designates specific firms as gatekeepers based on quantitative thresholds—turnover, user base, and market capitalization—subjecting them to immediate obligations like data portability and bans on self-preferencing. In a region where Super Apps have hermetically sealed their ecosystems, preventing users from moving data or services between platforms, the DMA offers a ready-made legislative template to these digital walled gardens.

Thailand: The Mover

Thailand has aggressively positioned itself as the region’s testing ground for EU-style regulation. The Royal Decree on Digital Platforms, which came into full effect in August 2023, requires operators to notify the Electronic Transactions Development Agency (ETDA) of their operations. This was the precursor. The more ambitious Draft Platform Economy Act, currently under review, explicitly mirrors the DMA’s structure.

The Thai draft introduces the concept of “gatekeeper” platforms, defined by revenue and user thresholds similar to the EU’s, though calibrated for the local economy. It proposes prohibiting these entities from barring third-party merchants from offering better prices on other channels—a direct attack on the “price parity” clauses frequently imposed by food delivery giants. If passed, this legislation would force Grab and Line Man Wongnai to fundamentally alter their merchant contracts, stripping them of the exclusivity method that currently lock in restaurant partners.

Vietnam and Indonesia: The Legislative Catch-Up

Vietnam is actively drafting its Law on Digital Transformation, with an expected date in 2026. Unlike previous competition laws which were broad and frequently toothless against foreign tech giants, this draft law specifically “dominant platforms” and “intermediary digital platforms.” The Ministry of Science and Technology has proposed detailed obligations including algorithmic transparency and restrictions on self-preferencing, directly borrowing from the DMA’s Article 6. This would compel platforms to disclose how their algorithms rank ride-hailing drivers or food listings, a “black box” that has long frustrated Vietnamese gig workers.

Indonesia, the region’s largest digital economy, has taken a fragmented but potent method. While not enacting a single “DMA” clone, the KPPU (Indonesia Competition Commission) is pushing for amendments to Law No. 5/1999 to introduce mandatory pre-merger notifications, replacing the ineffective post-merger system that allowed the GoTo merger to proceed with minimal friction. Furthermore, Presidential Regulation No. 32 of 2024 (Publisher Rights), enacted in February 2024, forces digital platforms to pay media outlets for content, a move that signals a willingness to impose direct financial obligations on tech giants, echoing the EU’s Copyright Directive which complements the DMA.

The Penalty Gap: A serious Weakness

While the regulatory language mimics Europe, the enforcement teeth remain significantly duller. The EU DMA the European Commission to levy fines of up to 10% of a company’s global annual turnover for infringements, and 20% for repeat offenses. In contrast, Southeast Asian penalties have historically been capped at nominal amounts that act as mere operating expenses for multi-billion dollar conglomerates.

Indonesia’s current competition law caps fines at levels that fail to deter decacorns. yet, the proposed amendments seek to remove these ceilings, allowing fines based on a percentage of profits or sales—a serious with global standards. Without this fiscal threat, the “gatekeeper” designation remains a bureaucratic label rather than a deterrent.

Table 19. 1: EU DMA Provisions vs. Southeast Asian Regulatory Counterparts (2024-2025)

Regulatory method	EU Digital Markets Act (DMA)	Southeast Asian Implementation Status
Ex-Ante Regulation	Fully enforced. Rules apply before abuse occurs.	Thailand: Draft Platform Economy Act (Under Review). Malaysia: MyCC Market Review (Report due Dec 2025).
Gatekeeper Definition	Quantitative thresholds (Turnover, Users, Market Cap).	Vietnam: “Dominant Platforms” defined in Draft Law on Digital Transformation. Singapore: CCCS studying metrics but retaining “balanced” ex-post method.
Interoperability	Mandatory for messaging and data portability.	Indonesia: Discussed in KPPU amendments but no technical mandate yet. Philippines: PCC “Konektadong Pinoy Bill” pushes for open access in data transmission.
Algorithmic Transparency	Mandatory disclosure of ranking parameters.	Vietnam: Explicitly included in 2026 Draft Law. Thailand: Required under Royal Decree for notified platforms.
Max Penalties	10-20% of Global Turnover.	Indonesia: Moving from fixed cap to % of profit/sales (Amendment pending). Singapore: Up to 10% of turnover in Singapore (current law).

The Interoperability “Nuclear Option”

The most disruptive element of the DMA for Southeast Asia is the mandate for interoperability. In the EU, this forces gatekeepers to allow third-party services to function within their ecosystem. Applied to Southeast Asia, this would theoretically require Grab to allow Gojek users to book a GrabCar directly from the Gojek app, or permit a third-party wallet to pay for services on either platform without punitive fees.

While no SEA nation has yet mandated full platform interoperability, the Malaysia Competition Commission (MyCC) has highlighted “data privacy and protection” and “market structure” in its 2024 Market Review, signaling that data portability is on the table. If Malaysia or Singapore were to enforce a “right to port” reputation data—allowing a driver to transfer their 5-star rating from Grab to a new competitor—it would instantly lower the blocks to entry that currently protect the duopoly. This specific provision is viewed by industry analysts as the “nuclear option” that could finally reopen the market to competition.

Future Outlook: The Probability of Forced Divestitures in 2026

The collapse of the proposed merger between Grab and GoTo in July 2025 marked a definitive turning point for Southeast Asia’s digital economy. For years, the region’s “Super Apps” operated under the assumption that consolidation was inevitable and regulatory fines were the cost of doing business. That assumption is dead. As we move through 2026, the regulatory conversation has shifted from blocking future mergers to existing monopolies. The probability of forced divestitures—state-mandated breakups of business units—has risen from a statistical impossibility to a credible threat, particularly in Indonesia and Singapore.

Regulators are no longer satisfied with behavioral remedies. The failure of the Grab-Trans-Cab acquisition in Singapore in July 2024 served as the domino. When the Competition and Consumer Commission of Singapore (CCCS) issued a provisional decision to block the deal, it signaled that the “efficiency defense”—the argument that bigger companies offer better prices—no longer outweighs the risks of market concentration. By mid-2025, when Grab and GoTo abandoned their merger talks amid intense scrutiny from Indonesia’s KPPU (Business Competition Supervisory Commission), the message was clear: the ceiling for organic growth has been reached.

The Structural Remedy Shift

The primary driver for chance divestitures in 2026 is the “ecosystem lock-in” strategy. Super apps rely on cross-subsidizing loss-leading services (like ride-hailing) with high-margin verticals (like fintech and food delivery). Regulators view this not as innovation, but as anti-competitive tying. In January 2025, the KPPU fined Google 202 billion IDR for similar practices, proving they have the appetite to attack platform mechanics. The logical step for the KPPU is to apply this precedent to Grab and GoTo, chance forcing them to unbundle their payment gateways from their transport apps to allow fair competition for other digital wallets.

In Malaysia, the Malaysia Competition Commission (MyCC) suffered a setback in March 2025 when the Court of Appeal quashed a RM86. 77 million fine against Grab on procedural grounds. Yet, this legal defeat has only accelerated legislative calls to strengthen MyCC’s arsenal. Policy analysts expect Malaysia to amend its Competition Act by late 2026 to include specific provisions for “digital gatekeepers,” mirroring the European Union’s Digital Markets Act. This would grant MyCC the power to order structural separation without relying on the lengthy judicial processes that failed them in 2025.

Market Concentration vs. Regulatory Tolerance

The data supporting regulatory intervention is damning. By the end of 2025, the combined market share of Grab and GoTo in key verticals exceeded the thresholds that typically trigger antitrust action in mature markets. In Indonesia, the two companies control over 90% of the ride-hailing Gross Merchandise Value (GMV). Such concentration leaves zero room for new entrants, as evidenced by the stagnation of smaller players like Maxim and inDrive, who remain relegated to the fringes of the market.

Jurisdiction	Regulatory Body	2025 Action Status	2026 Divestiture Probability
Indonesia	KPPU	Blocked Grab-GoTo merger talks; Fined Google for ecosystem tying.	High (Fintech unbundling)
Singapore	CCCS	Blocked Trans-Cab acquisition; Reviewing “ecosystem” dominance.	Medium (Transport exclusivity)
Philippines	PCC	Imposed PHP 9M fine (May 2023) & extended monitoring to 2025.	Medium (Refund/Pricing compliance)
Malaysia	MyCC	Lost court appeal (March 2025); Seeking legislative amendments.	Low (Pending new laws)
Thailand	TCC	Enforcing logistics choice rules for e-commerce (late 2025).	Medium (Logistics unbundling)

The Financial Reality of Breakups

Investors have long feared that a breakup would destroy shareholder value. Yet, the opposite may be true. Grab reported its quarterly net profit of SGD 10 million in Q1 2025, driven by cost-cutting rather than user growth. This suggests the “growth at all costs” model is exhausted. A forced divestiture of their financial services arms could unlock value, allowing these units to operate as independent fintech entities unburdened by the operational drag of a transport fleet.

The chart illustrates the between the duopoly’s market control and the “Safe Harbor” limits typically respected by competition laws. The breach of these thresholds in Indonesia and Singapore is the primary metric fueling the divestiture debate.

2026: The Year of Enforcement

The stalled merger of 2025 was a warning shot. The real war begins in 2026. With the KPPU explicitly stating that financial distress is not a valid defense for monopoly, and the CCCS moving to block even minor acquisitions like Trans-Cab, the regulatory shield has hardened. The probability of a forced divestiture is highest in Indonesia, where the government views the digital economy as a national strategic asset that cannot be held hostage by a duopoly. If Grab and GoTo do not voluntarily unbundle their services to lower entry blocks, the courts can likely do it for them.

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