LRD guides and handbook May 2019

Law at Work 2019 - the trade union guide to employment law

Chapter 4

Mobile workers travelling to and from first and last assignment 



[ch 4: page 100]

Mobile workers (those whose job involves travelling from place to place instead of being based in a specific location) must be paid an average hourly rate of at least the NMW for any reference period that includes time spent travelling to and from the first and last appointment of the day (Federacion de Servicios Privados del sindicato Comisiones obreras v Tyco Integrated Security SL [2015] EUECJ C-266/14).




The Tyco case concerned “working time” rights, rather than National Minimum Wage law (see Working Time: Mobile Workers, page 122). Even so, this ruling has implications for pay negotiations concerning travel time for low-paid mobile hourly-paid workers. This is because their average hourly rate in any pay reference period must not fall below the NMW, once travel time has been added to the working day.