Domiciliary Care Travel Pay: What Registered Managers Must Get Right on NMW

Practical guidance for home-care providers in Great Britain

1. Purpose and scope

This guideline explains how the organisation should schedule, record and pay travel, waiting time and breaks for workers delivering domiciliary care at different locations. It is designed for managers, rostering teams, HR and payroll.

It assumes the worker is an employee or worker in Great Britain (England, Scotland or Wales). Northern Ireland has separate working-time legislation. Employment contracts, collective agreements, TUPE-protected terms and local-authority or NHS commissioning contracts may provide more generous rights and must also be followed.

This is operational guidance, not legal advice. Individual arrangements must be reviewed where the facts are unusual or disputed.

2. Quick decision guide

Journey or period	Minimum-wage treatment	Organisation action
Home → first service user	Generally excluded for NMW	Pay only if the contract/policy requires it. Consider it separately for Working Time Regulations purposes.
Service user → next service user	Included	Record actual reasonable travel time and include it in the NMW hours calculation.
Last service user → home	Generally excluded for NMW	Pay only if contract/policy requires it. Consider it separately for working-time limits and rest.
Visit → required office, pharmacy, key collection, training or other work location	Included where undertaken for work	Record the journey and the associated task. Exclude only a genuine rest break.
Visit → home for a genuine split-shift break → later visit	Break and home journeys generally excluded	The worker must be genuinely free from duties. Record the break clearly.
Travel toward next visit, then a break away from home	Travel included; genuine break excluded	Separate travel from break time. Do not remove the whole gap from working hours.
Required waiting or standby near a workplace	Fact-sensitive; may be included	Assess location restrictions, required availability and duties. Record and escalate uncertain cases.

Source note: GOV.UK gives specific domiciliary-care examples covering travel between appointments and a worker going home between morning and afternoon visits.

3. National Minimum Wage requirements

For most hourly paid care workers, care delivery and other required duties are time work. Travel undertaken for the purpose of work, including travel between assignments at different locations, is treated as working time for NMW purposes. Ordinary home-to-work travel is excluded.

3.1 Hours that must normally be counted

•     Time delivering care and completing required records or handovers.

•     Actual travel between service users and other required work locations.

•     Work-related training and qualifying travel from a workplace to training.

•     Required waiting time, such as waiting to collect goods, meet someone for work or start a job.

•     Any work performed during an otherwise unpaid gap, including calls, documentation or responding to the office.

3.2 How to test compliance

Payroll check. For each worker and each pay reference period: NMW pay ÷ total NMW hours must be at least the statutory rate applicable to that worker. Total NMW hours include qualifying travel even if the payslip does not show travel as a separate line.

A pay reference period is normally the period for which the worker is paid and cannot exceed one month. It is not enough for the worker’s visit-only rate to exceed the minimum wage if adding qualifying travel and other work brings the average below the statutory rate.

The organisation may use a separate contractual travel-time rate or a consolidated rate, provided the employment terms and any commissioning requirements allow it and the NMW calculation remains compliant in every pay reference period. No agreement can waive the statutory minimum.

3.3 Current statutory rates

Worker category	Rate from 1 April 2026
Age 21 and over	£12.71 per hour
Age 18 to 20	£10.85 per hour
Under 18	£8.00 per hour
Apprentice rate	£8.00 per hour, subject to eligibility rules

Rates normally change on 1 April each year. Payroll must use the rate applicable during the relevant pay reference period and check apprentice eligibility rather than applying the apprentice rate automatically.

3.4 Actual travel rather than unrealistic estimates

HMRC states that the mode of transport is not decisive and that employers should not substitute an alternative route or optimal computer-calculated time where it does not reflect the actual journey, distance, weather or traffic. The organisation should therefore record actual reasonable travel, investigate anomalies and avoid relying only on planned rota minutes.

4. First and last journeys: two different legal tests

Do not merge the tests. National Minimum Wage rules determine which hours must be included in the pay calculation. Working Time Regulations determine working-hours limits and rest. A journey can be working time for the second purpose without attracting a separate minimum-wage payment under the first.

For NMW purposes, travel between the worker’s home and the first place of work, and between the final place of work and home, is generally excluded. GOV.UK expressly states that employers are not required under minimum-wage legislation to pay the minimum wage for those journeys.

For a peripatetic worker with no fixed or habitual workplace, ACAS says travel between home and work is likely to count as working time. The Tyco judgment similarly held that, in the circumstances of that case, travel from home to the first customer and from the last customer home was working time.

Therefore, even where the organisation’s contract makes the first and last journeys unpaid, it should consider and, where needed, record them when monitoring the 48-hour average weekly limit, night work and adequate daily/weekly rest. Whether a particular care worker is genuinely peripatetic depends on the actual arrangement, not just the wording used in a contract.

5. Breaks, gaps and split shifts

An adult worker is generally entitled to an uninterrupted 20-minute rest break if working more than six hours in a day. The statutory break does not have to be paid unless the contract or another agreement makes it paid. Workers are also generally entitled to 11 hours’ daily rest and weekly rest.

5.1 When the worker goes home

GOV.UK gives the following care-worker position: where there is a morning appointment and an afternoon appointment and the worker goes home for a break, the travel from the first appointment home and from home to the second appointment does not count towards the minimum wage. The break itself is also excluded.

The organisation may therefore treat a genuine return-home split as unpaid unless the contract, custom and practice, collective agreement or commissioner requires payment. The roster should show a clear break rather than presenting the entire day as one continuous paid shift.

5.2 When the worker stays out

If the worker travels from one assignment toward the next and takes a break on the way, the qualifying travel remains NMW time; only the genuine break is excluded. A long gap between calls is not automatically an unpaid break.

5.3 Test for a genuine unpaid break

•     The worker is told clearly when the break starts and ends.

•     The worker is not required to perform documentation, calls, visits or other duties.

•     The break is uninterrupted and the worker can use it for personal purposes.

•     The worker is not required to remain at a specified place or maintain an immediate response capability that materially restricts the break.

•     Any work actually performed during the gap is recorded and paid appropriately.

On-call and standby arrangements are fact-sensitive. HMRC directs employers to consider the contractual restrictions, specified location, duties and burden placed on the worker. Managers must not simply rename restricted waiting time as a break.

6. Mileage and travel expenses

Payment for the worker’s time and reimbursement of vehicle costs are separate. The organisation may comply with the NMW travel-time requirement while still having a mileage-expense issue, or vice versa.

•     There is no general rule requiring an employer to pay the HMRC approved mileage rate. The contractual policy and commissioning terms determine the rate, subject to minimum-wage expense rules.

•     For 2026/27, HMRC’s approved tax-free amount for an employee’s own car or van is 55p per business mile for the first 10,000 miles and 25p thereafter. These are tax rules, not compulsory wage rates.

•     Where the organisation pays less than the approved amount, an eligible employee may claim tax relief on the shortfall. Tax relief is not the same as receiving the shortfall in cash.

•     Mandatory unreimbursed expenses incurred in carrying out the job can reduce NMW pay. Payroll should assess fares, fuel and other required costs carefully and obtain specialist advice on how vehicle costs should be quantified.

•     Tax treatment of home-to-first and last-to-home mileage can differ from the NMW treatment. Payroll must apply the HMRC business-travel rules rather than assuming the two tests are identical.

Example: 35p per mile. Paying 35p per mile is not automatically unlawful. In 2026/27 it is below HMRC’s 55p approved amount for the first 10,000 business miles, so an eligible worker may be able to claim tax relief on the 20p difference. The organisation must still check the employment contract, commissioner requirements and whether unreimbursed work expenses cause an NMW shortfall.

7. Organisational procedure

1.   Plan realistic runs. Allocate enough time between calls for the route, parking, walking, traffic and predictable local conditions. Do not overlap commissioned visit time and travel time.

2.   Record actual activity. The worker records visit start/end, departure/arrival for qualifying travel, genuine break start/end, business mileage and any required work completed during a gap.

3.   Review exceptions promptly. Managers review material differences between planned and actual travel without automatically replacing actual time with an ideal route. Repeated late or missed calls should trigger a rota and capacity review.

4.   Confirm the classification. The manager identifies whether each gap was travel, waiting, a genuine break, home-to-work travel or active work. Uncertain restricted-waiting and on-call cases go to HR/payroll before payroll closes.

5.   Run the payroll compliance test. For every pay reference period, payroll includes all NMW hours and removes any payments or deductions that do not count as NMW pay. Any shortfall is corrected immediately.

6.   Monitor working-time limits. For workers without a fixed workplace, include relevant first and last journeys when assessing working-time limits and rest, even if those journeys are unpaid under the employment terms.

7.   Retain evidence. Keep sufficient NMW records for at least six years. Keep Working Time Regulations compliance records for two years, including any written 48-hour opt-out.

8. Recommended employment/policy wording

The following wording can be adapted for an employment contract, travel agreement or staff handbook. It should be checked against existing contractual terms before introduction.

Travel time. Travel between consecutive service-user visits and between a service-user visit and another location which the organisation requires the worker to attend will be recorded as working time and paid in accordance with the organisation’s published pay arrangements.

Home journeys. Ordinary travel from home to the first assignment and from the final assignment home is not paid unless the organisation confirms otherwise, the employment contract provides otherwise, or payment is required by law or an applicable commissioning agreement.

Split-shift breaks. Where the worker is released from all duties and goes home during a genuine split-shift break, the break and the journeys home and back to the later assignment are unpaid unless the organisation confirms otherwise.

Availability. If the worker is required to remain at a specified place, stay immediately available, undertake duties or respond to work during a scheduled gap, the worker must record the time and notify the manager so that it can be assessed correctly.

Minimum wage. The organisation will ensure that pay for every pay reference period complies with National Minimum Wage law after all qualifying working time, including travel between assignments, and relevant deductions or expenses are taken into account.

Mileage. Business mileage and other authorised travel expenses will be reimbursed at the rates and subject to the evidence requirements set out in the current Expenses Policy. Mileage reimbursement is separate from payment for travel time.

9. Manager and payroll checklist

☐ Contracts and staff guidance clearly distinguish travel time, mileage and breaks.

☐ Rota systems capture actual travel and do not rely only on planned route times.

☐ Travel between all required work locations is included in NMW hours. ☐ Home-return split shifts are genuine, clearly recorded and free of work duties.

☐ Restricted waiting and on-call gaps are reviewed rather than automatically deducted.

☐ Each pay reference period is tested against the correct age/apprentice rate.

☐ Mandatory unreimbursed work expenses are considered in the NMW calculation.

☐ Peripatetic workers’ first and last journeys are considered for working-time limits and rest.

☐ Commissioning contracts, collective agreements and existing contractual terms have been checked.

☐ Records are retained for the applicable legal period and can be produced by worker and pay period.

10. References and live links

All sources below were checked on 15 August 2026. Legislation and rates can change; review this guideline at least annually and before changing pay arrangements.

1. National Minimum Wage Regulations 2015, regulation 34 — travelling treated as hours of time work, with the home-to-work exclusion in the regulation.

2. GOV.UK — Working hours for which the minimum wage must be paid — official guidance distinguishing commuting, first/last journeys, travel between assignments, waiting and breaks.

3. GOV.UK — Minimum wage for different types of work — includes the specific care-worker examples for travel between appointments and returning home during a split.

4. HMRC National Minimum Wage Manual NMWM08300 — assignment travel, home-to-work exclusion, actual travel conditions and breaks during journeys.

5. ACAS — Working time for someone who travels for their job — peripatetic workers, first/last journeys and the distinction between working time and pay.

6. Working Time Regulations 1998 — statutory framework for working-time limits and rest.

7. Tyco judgment, Case C-266/14 — first and last customer journeys for workers without a fixed or habitual workplace.

8. GOV.UK — Rest breaks at work — 20-minute break after more than six hours, daily rest, weekly rest and contractual pay for breaks.

9. HMRC National Minimum Wage Manual NMWM08270 — on-call and standby restrictions and when responding to work counts.

10. GOV.UK — National Minimum Wage and National Living Wage rates — current and historic statutory hourly rates.

11. GOV.UK — Employers and the minimum wage — pay reference periods, deductions, enforcement and six-year record retention.

12. HMRC — Business travel mileage for employees’ own vehicles — 2026/27 approved mileage amounts and tax treatment when the employer pays less or more.

13. HMRC National Minimum Wage Manual NMWM11170 — unreimbursed third-party expenses incurred in carrying out employment.

14. ACAS — Understanding the Working Time Regulations — working time, rest rights and two-year compliance record guidance.