Travel between jobs : calculate what you are owed

• Ordinary commuting (home to the first place of work, and the last place of work back home) usually does not count as working time for NMW, unless you are actually working while travelling.
• Travel between assignments during the working day often does count: for example a care worker driving from one client to another between appointments (GOV.UK wording).
• Waiting connected to work travel (trains, connections, waiting to start a job) can count; a genuine rest break taken during a journey does not.
• From April 2026, workers aged 21 and over get at least £12.71 an hour on hours that count for NMW. Always re-check the live GOV.UK rates table.
• Pay disputes still sit inside tribunal time limits: today usually 3 months minus 1 day; from 1 October 2026, most claims become 6 months minus 1 day if the clock starts on or after that date (Acas).

The National Minimum Wage Regulations 2015 set out when travelling hours count. Regulation 20 defines "travelling" widely: journeys by transport or on foot, waiting to begin or re-commence a journey (except rest breaks), and waiting at the end of a journey to carry out duties or receive training (again except rest breaks).

For time work (pay that varies with hours), regulation 34 treats travelling for the purposes of time work as hours of time work where the worker would otherwise be working, unless the travel is between the worker's home (or temporary residence not for work purposes) and a place of work or assignment. Critically, hours when the worker is travelling to carry out assignments at different places between which they are obliged to travel, and which are not places occupied by the employer, are treated as hours when they would "otherwise be working".

GOV.UK's working-hours chapter of Calculating the minimum wage restates the practical split:

• commuting between home and place of work does not count (unless the worker works while travelling, for example on a laptop on a train);
• travelling from home to a task or assignment will generally not be working time for NMW either;
• travelling from one work assignment to another (the care-worker example) does count;
• travelling for the purpose of carrying out work, waiting for transport connections in connection with work travel, waiting to collect goods or meet someone for work, and travel from work to training venues can count;
• travel between home and a training venue generally does not.

HMRC's National Minimum Wage Manual NMWM08490 (unmeasured work travelling time) matches that pattern: travel between assignments that must be carried out at different places counts; home-to-work travel does not. HMRC also says officers look at the actual journey (traffic, weather, real routes), not an employer's "optimal" model route, and that waiting in queues or for connections is likely working time rather than an automatic "break".

Think in three buckets:

1. Home to first job / last job to home. Usually outside NMW hours. A longer drive to a distant first client is still typically commuting for NMW purposes, even if it feels unfair. Separate Working Time Directive case law about "mobile workers" does not automatically rewrite NMW pay; GOV.UK notes pay is governed by the contract and minimum wage rules.
2. Between clients or sites in the middle of the day. Often inside NMW hours when you are obliged to move from one assignment to another.
3. Working while travelling. If you are required to take calls, complete paperwork, or otherwise work on the journey, that working time can count even on a journey that looks like a commute.

Do not rely on the rota label alone. An "unpaid travel" column on a timesheet does not decide the NMW test. Rebuild the hours that the Regulations and GOV.UK say must be included, then divide pay by those hours for each pay reference period.

You are 35 and entitled to the April 2026 NLW of £12.71. You are a care worker paid as time work. In one week you work five days. Each day:

• 20 minutes home to first client (commute: usually not NMW hours)
• 6 hours of client contact time across several visits
• 1 hour 15 minutes (1.25 hours) driving between clients during the day
• 20 minutes last client back home (commute: usually not NMW hours)

Weekly hours that count for NMW on this framing:

• client contact: 5 x 6 = 30 hours
• between-client travel: 5 x 1.25 = 6.25 hours
• total counting hours: 36.25

Suppose your employer only pays the 30 contact hours at £12.71 and treats the 6.25 hours as unpaid:

• pay received: 30 x £12.71 = £381.30
• if all 36.25 hours must be in the NMW calculation: £381.30 ÷ 36.25 ≈ £10.52 an hour

That average sits below £12.71. The gross shortfall to bring the week up to the floor is:

• 36.25 x £12.71 = £460.74 legal floor
• minus £381.30 paid = £79.44 for that week

Over four similar weeks the gross gap is about £317.76 before you look at earlier pay reference periods. If your contract also promises paid travel time above the NMW floor, keep that contractual claim distinct: NMW is the legal floor; the contract can still owe more.

Variant: day rate that hides travel

Same hours, but you are paid a flat £400 for the week with "travel included".

• £400 ÷ 36.25 ≈ £11.03 an hour

Still under £12.71. The flat label does not rescue the average. You need either more pay or fewer unpaid counting hours.

Regulation 20 and NMWM08490 treat waiting for transport connections and queuing traffic as part of travelling time in the ordinary case. A rest break you take during a journey (stopping for lunch away from duties) is not working time for NMW in the same way as other rest breaks.

Employers sometimes quote map apps for the "shortest" minutes. HMRC's manual is clear that officers will not accept adjusting your actual travel as if you had taken another mode or an ideal route that does not match distance, weather, or traffic. Log what you actually did.

GOV.UK lists travel from work to training venues as time that can count, while home-to-training generally does not. That sits beside the training-time rules (see the companion article on mandatory training). Business travel for carrying out work, and waiting to collect goods or start a job, are also in the "counts" list on GOV.UK.

• Ordinary home-to-work and work-to-home commuting (unless you work while travelling)
• Genuine rest breaks during travel
• Time away from work such as holidays or sick leave (those absences have their own pay rules; they are not "travel hours")

Also remember: NMW is about the average hourly rate in a pay reference period after the right hours and the right pay elements are included. A mileage expense that reimburses fuel is not the same as paying NMW for the travel time. Do not assume a fuel claim fixes an underpayment of hours.

1. Diary each leg: home → first site, site → site, last site → home, with times and purpose.
2. Keep rota, app logs, and payslips that show which minutes were unpaid.
3. Rebuild the pay reference period: add counting travel hours to contact hours, then divide pay by total counting hours.
4. Cross-check age band rates on https://www.gov.uk/national-minimum-wage-rates (from April 2026, £12.71 for most workers aged 21+).
5. Raise it in writing with the employer or agency payroll. If it is an NMW shortfall, Acas explains you generally choose either an HMRC complaint or an employment tribunal for the same underpayment.

Dual time-limit regime: most pay claims remain 3 months minus 1 day as at September 2026. From 1 October 2026, most claims become 6 months minus 1 day if the time limit starts on or after that date (Acas). Early Conciliation can pause the clock if you notify Acas in time; a grievance does not extend the limit.

• Treating every minute in the car as automatically NMW. The first and last commute legs usually still sit outside the NMW hour count.
• Ignoring between-client travel because the contract says "travel unpaid". Contract labels do not override the Regulations where travel between assignments must be counted.
• Using ideal map times. HMRC looks at actual journeys.
• Mixing mileage expenses with pay for time. Fuel money is not a substitute for including hours in the NMW average.
• Waiting too long. Limitation clocks run from when you were not paid correctly for a period.

Travel disputes turn on a clean hour log. Paye Mes Heures can help you separate commute legs from between-job travel and estimate whether the week still clears £12.71 before you contact payroll or Acas. It is a preparation aid, not a ruling on your exact route pattern, and not a substitute for Acas, HMRC, legal advice or a tribunal.

Between-jobs travel often counts. Ordinary commuting usually does not. Count the middle legs, test the average, and keep the first and last journeys in the right bucket.

• GOV.UK - Calculating the minimum wage: https://www.gov.uk/guidance/calculating-the-minimum-wage
• GOV.UK - Working hours for which the minimum wage must be paid (travel on business): https://www.gov.uk/guidance/calculating-the-minimum-wage/working-hours-for-which-the-minimum-wage-must-be-paid
• HMRC National Minimum Wage Manual NMWM08490 (travelling time): https://www.gov.uk/hmrc-internal-manuals/national-minimum-wage-manual/nmwm08490
• National Minimum Wage Regulations 2015 (contents): https://www.legislation.gov.uk/uksi/2015/621/contents
• National Minimum Wage Regulations 2015, regulation 20 (hours spent travelling): https://www.legislation.gov.uk/uksi/2015/621/regulation/20
• National Minimum Wage Regulations 2015, regulation 34 (travelling treated as hours of time work): https://www.legislation.gov.uk/uksi/2015/621/regulation/34
• GOV.UK - National Minimum Wage and National Living Wage rates: https://www.gov.uk/national-minimum-wage-rates
• Acas - Employment tribunal time limits: https://www.acas.org.uk/employment-tribunal-time-limits