Home care travel time and the minimum wage: the rules and how to check your pay

Home care pay often looks fine on paper: a decent hourly rate for time with clients. The problem is the time in between. A care worker who drives between eight visits a day can spend an hour or more on the road, and if that time isn't covered by their pay, their real hourly rate can fall below the minimum wage without anyone noticing.

This guide explains the rule, the 2026 rates, a worked example and a simple monthly check.

The rule: travel between visits is working time

Under regulation 34 of the National Minimum Wage Regulations 2015, time a worker spends travelling for the purposes of their work counts as working time, unless the journey is between their home and a place of work or assignment. Regulation 34(2)(a) specifically covers travel between assignments at different places.

Government guidance on calculating the minimum wage uses home care as its example of travel that counts: a care worker driving from one client to another between appointments. It also says travel from home to a task or assignment will generally not be working time.

So for a typical run:

Gaps between visits

The guidance doesn't directly deal with every gap in a split run. It says time spent waiting to meet someone in connection with work or to start a job counts, and that rest breaks, including breaks taken while travelling, don't. Its own example treats a break on the way to the next appointment as unpaid while the travel itself is paid. The practical test is whether the care worker is genuinely free to use the time for their own purposes. A two-hour gap between the morning and teatime calls when they can go home is likely to be a break; ten minutes sitting outside the next client's house is not.

The 2026 minimum wage rates

From 1 April 2026:

Rates change on 1 April each year. Sponsored care workers and senior care workers on the Health and Care visa have their own floor under the sponsor guidance: at least £25,000 a year and £12.82 for each hour worked. See our guide to sponsor licence duties.

How the check works: average over the pay reference period

You don't have to pay an hourly rate for travel. You can pay per visit, per contact hour, or a day rate. What the law checks is the average over the pay reference period (usually the week or month you pay for): total pay for the period divided by total working hours in the period, including travel between visits, must be at least the minimum wage.

A worked example

A care worker aged 30 is paid £13.00 an hour for contact time only. In a week they work:

• 30 hours of contact time with clients;
• 7 hours travelling between visits;
• (plus commuting to the first visit and home from the last, which doesn't count).

A contact rate above the minimum wage still underpays by more than £80 a week once travel is counted. The fix is either to pay for travel time, raise the contact rate, or build runs with less travel. To pass at 37 hours with no travel pay, the contact rate would need to be at least £15.68 an hour (£470.27 ÷ 30).

Things that reduce minimum wage pay

• Mileage and expenses. Money paid back for work expenses, like mileage, doesn't count as pay for minimum wage purposes. You can't use a generous mileage rate to make up for unpaid travel time. HMRC's approved mileage rate for cars is 55p a mile for the first 10,000 business miles (from 6 April 2026), then 25p.
• Deductions and payments for work costs. If a worker has to pay for something connected to the job, such as transport or uniform, it reduces their pay for minimum wage purposes.
• Unpaid training and meetings. Time spent on training, supervisions or team meetings the worker is required to attend is working time too.

Wales, Scotland and Northern Ireland

The National Minimum Wage and its travel time rules are UK-wide, so the calculation above works the same in every nation. Wales adds care regulations on top:

• Wales: regulation 41 of the Regulated Services (Service Providers and Responsible Individuals) (Wales) Regulations 2017 requires a schedule of visits for each domiciliary care worker that shows travel time, visit time and rest breaks separately, with enough travel time for the distance, traffic and parking, and a record of the time each worker actually spends travelling, on visits and on breaks. Its definition of travel time matches the minimum wage rule: between visits counts, home to the first visit and the last visit home don't. Visits must also be at least 30 minutes unless an exception in the 2016 Act applies. Regulation 42 requires an offer of a contract reflecting average hours after three months of regular hours on a non-guaranteed hours contract. Care Inspectorate Wales checks these.
• Scotland: the Care Inspectorate regulates care at home, and the Health and Care (Staffing) (Scotland) Act 2019 requires appropriate staffing; the minimum wage calculation is the same as above.
• Northern Ireland: RQIA regulates domiciliary care agencies. The minimum wage applies as in Great Britain, but other employment rights, such as working time, come from separate Northern Ireland legislation.

Enforcement and records

• Since 7 April 2026, the Fair Work Agency has enforced the minimum wage.
• Arrears are worked out at the current minimum wage rate, not the rate at the time.
• Penalties are 200% of the arrears, with a maximum of £20,000 per worker (halved if everything is paid within 14 days), and employers can be named.
• Employers must keep records showing they paid at least the minimum wage for at least six years.

A monthly travel-time pay check

• For each care worker, total contact hours, travel time between visits, waiting time and required training for the pay period.
• Total pay for the period, excluding mileage and expense reimbursements.
• Divide pay by hours. Is it at least the right rate for their age?
• Check anyone close to the line, and anyone whose run changed a lot this month.
• If anyone is under, pay the arrears now and fix the run or the pay structure.
• Keep the workings with your payroll records for at least six years.

How ShiftComplete helps

ShiftComplete for care builds the run and runs the check:

• Visit runs per care worker with estimated travel time between each visit, so tight or long gaps show before the day starts.
• Check-in and check-out at the client's address on the care worker's phone, recording what actually happened.
• Planned versus actual reports by client and by care worker.
• A minimum wage check that adds paid time including travel between visits, and compares pay with the National Living Wage using the hourly rate you enter for each care worker.
• Mileage recorded so you can reimburse it separately.

ShiftComplete doesn't run payroll; it gives you the hours and the warning. It costs £2.49 per active staff member per month with no minimum or contract, and the first 60 days are free with no card needed. Read more about domiciliary care rota software or see it on our home care page.