Travel Time and the Minimum Wage in Home Care: What Counts (2026)

Travel time is where home care pay most often goes wrong. A carer can be paid well above the minimum wage for every hour they spend with clients and still end up below it once the time driving between those clients is counted. This guide sets out what counts, what does not, and how to check, using GOV.UK's guidance and HMRC's National Minimum Wage manual (checked 26 October 2026).

How the minimum wage is checked

The minimum wage is not checked hour by hour. It is checked on average across a pay reference period: the period pay is worked out for, such as a week or a month, and never longer than a month. The test is:

pay that counts ÷ hours that count = effective hourly rate, which must be at least the rate for the worker's age.

Time that counts

• Time at visits.
• Travel between visits. GOV.UK gives the example of "a care worker driving from one client to another between appointments". It is the actual time taken that counts: HMRC says it will not accept travel based on computer-planned routes that do not reflect what really happened.
• Waiting the carer is required to do. Time when a worker must be available at or near a place of work counts, even if they are simply waiting.
• Required training, including outside normal hours.
• Delays during a journey, such as queuing traffic, are likely to count as time worked.

Time that does not count

• Home to the first visit and the last visit home. "Travelling from home to a task or assignment will generally not be considered as working time" for minimum wage purposes.
• Going home for a break. If a carer goes home between visits, the journeys home and back do not count, and nor does the break.
• A genuine break. Time the carer actually takes as a break, free to use as they wish, does not count, whether or not it is paid. There is no fixed number of minutes that turns a gap into a break: it depends on what really happened.

Pay that counts, and pay that does not

• Mileage and expenses do not count as pay, even if they are called an allowance.
• Enhanced rates only count at the basic rate. If weekend or unsocial hours are paid at a higher rate, the extra is taken out and the hours are valued at the lowest basic rate in the contract.
• Tips do not count.
• Some costs reduce pay: business travel costs the carer pays and is not repaid, such as fuel between visits, and deductions such as uniform charges.

A worked example

A carer works 25 hours at visits in a week at £12.80 an hour and spends 6 hours driving between visits, which is not paid. Their pay is £320 for 31 hours that count: an effective rate of £10.32 an hour. That is £2.39 below £12.71, a shortfall of £74.01 that week, or about £3,850 over a year at the same pattern.

Paying the 6 hours of travel at £12.71 would bring the carer to £396.26 for 31 hours, £12.78 an hour, just above the minimum.

Minimum wage rates

Worker	From 1 April 2026	From 1 April 2027
21 and over (National Living Wage)	£12.71	£13.21
18 to 20	£10.85	£11.27
Under 18	£8.00	£8.31
Apprentice (under 19, or 19 and over in the first year)	£8.00	£8.31

The April 2027 rates were announced at the Budget on 28 October 2026 (GOV.UK: LPC recommendations take the National Living Wage to £13.21).

What happens if pay falls short

Underpaid workers are owed arrears worked out at the current rate. Employers can face a penalty of 200% of the underpayment, at least £100 and up to £20,000 per worker, halved if paid within 14 days. Cases with arrears of £500 or more are considered for public naming, and not paying the minimum wage is a criminal offence. Employers who find a problem themselves can declare it to HMRC; GOV.UK says that, other than in exceptional cases, declared and accepted arrears do not lead to naming or financial penalties.

How to stay on the right side

1. Record actual travel time between visits, not planned times.
2. Work out each carer's effective hourly rate for every pay period, including travel and required waiting.
3. Pay a top-up where anyone falls short, in the same period.

Our free home care minimum wage calculator does the sum for one carer and one pay period. Care App does it automatically for every carer, every pay period, using road travel times between visits from the rota, and flags anyone who needs a top-up.

This is general guidance, not legal advice. Sources: GOV.UK minimum wage rates; Calculating the minimum wage: working hours; Minimum wage for different types of work; HMRC NMWM08300; Fair Work Agency enforcement statement. For a specific case, contact Acas on 0300 123 1100.