Do You Have to Pay Carers for Travel Time? The Minimum Wage Trap in Domiciliary Care

Do you have to pay carers for travel time between visits?

Yes. Time a carer spends travelling from one client to the next during their working day is working time for the national minimum wage, and it has to be paid. This is not a grey area or a matter of opinion: the rules on which hours count for the minimum wage are clear that travel between assignments during the working day is included, and only ordinary commuting to the first visit and home from the last is left out.

The trap is not that agencies refuse to pay it. It is that many pay per visit, or per contact hour, and never check what that works out to once the travel between visits is added into the hours. A round can look well paid on the visit rate and still breach the minimum wage on the average, because the driving in between is unpaid time that still counts as work.

This guide is written by LOYALS, a King's Cross firm of accountants and business consultants that runs payroll and compliance for domiciliary care agencies across London, including through our accountants for care agencies. The whole point here is to help you see whether your pay model is safe before HMRC, a union or a former carer raises it, because by then it is arrears, not a fix.

What travel counts, and what does not?

Travel between assignments counts; commuting does not. The line HMRC draws is about when the working day starts and ends. Once a carer has begun their round, the driving or travel from one client to the next is part of the working time you must pay for. The journey from home to the very first visit, and from the very last visit back home, is treated as commuting and does not have to be paid, unless the carer is genuinely working while they travel.

The gov.uk guidance on which working hours the minimum wage must be paid for gives the care worker driving between clients as its own example of travel that counts. So a typical domiciliary round, which is mostly short visits with drives in between, is full of exactly the travel that must be paid. The detail sits in HMRC's national minimum wage manual on travelling time. The flowchart below sorts a journey in one question.

How unpaid travel drops carers below the minimum wage

The minimum wage is not tested minute by minute. It is tested across a pay reference period: you add up everything the worker was paid, divide by all the hours they worked, and the answer has to be at least the minimum wage for their age. For someone 21 or over in 2026-27 that is 12.71 pounds an hour. It is this averaging that catches the contact-time-only model.

Take an illustrative carer paid 12.71 pounds for each hour of contact time. On a typical shift they deliver seven hours of contact time but spend another hour and a half driving between visits. They are paid seven times 12.71, which is 88.97 pounds, but they have actually worked eight and a half hours. Divide 88.97 by 8.5 and the real rate is 10.47 pounds an hour, well under the minimum. The carer looks well paid on the visit rate and is being underpaid on the law.

Multiply that gap across a rota. In this illustration the carer is short by about 19 pounds a shift once the hours are counted properly. Across fifty carers doing four or five shifts a week, the weekly exposure runs to several thousand pounds, and it compounds every week it is not fixed. That is why this is the issue that turns into a six-figure arrears bill for agencies that leave it unaddressed for years.

What it costs if HMRC finds an underpayment

If HMRC decides carers were underpaid, three things follow, and none of them is small. First, you repay the arrears to the workers, calculated at current minimum wage rates, and it can look back up to six years. Second, HMRC can charge a penalty of up to 200 percent of the arrears. Third, it can name your agency on the government's public list of employers who broke minimum wage law.

For a care business that lives on council and CQC relationships, the naming can do as much damage as the money. Commissioners and families read those lists, and a place on one sits against you at the next tender. The broader rules on working out the wage, correcting underpayments and the penalties involved are set out in the gov.uk guidance on calculating the minimum wage. The honest summary is that the cost of getting this wrong is far larger than the cost of paying travel time correctly in the first place.

How to fix it and stay compliant

The fix is not complicated, but it has to be run on real data every pay run, not assumed once. There are three moving parts: pay for all the working time, run the average check worker by worker, and keep the records that prove it.

In practice that means either paying for all working time including travel, or adding a travel payment sized so the average never dips below the line, then reconciling actual rota hours against pay each period. Where an agency inherits a legacy underpayment, the sooner it is quantified and corrected, the better the position, because voluntary correction is always cheaper than an HMRC assessment. This is the sort of thing a managed care payroll function does as routine rather than as a fire drill.

LOYALS works specifically with domiciliary care and home care agencies, so payroll here is built around the way rounds actually run: contact time, travel between visits, sleep-ins and holiday pay all handled together. You can see the full picture on our care agency accountants page, and the payroll detail on our payroll and PAYE service.