Working Time Records

Field Staff and Drivers

This is not legal advice, and driving time in particular is governed by sector rules that sit on top of everything here. For an additional implementation-oriented example, see this page.

Mobile work is where a central record is impractical, where the boundary questions are genuinely contested, and where getting them wrong costs money in both directions. For additional workplace and technology context, see European Parliament.

Reviewed August 9, 2026.

The four boundary questions

One. When does the working day start? At the first customer, or when leaving home? For an employee travelling from home directly to a client, this is a real question with case law behind it, and the answer changes the recorded day by an hour or more each way.

Two. Is travel between jobs working time? Generally treated differently from commuting, and it is the second-largest item after the first.

Three. What about waiting? On-site waiting, waiting for access, waiting for a delivery. Whether it counts depends on how constrained the person is, which is a fact question.

And four. On-call and standby. A separate regime with its own rules and its own case law.

Decide these in advance, write them down, and apply them consistently. The inconsistency is what an auditor or a tribunal notices — the same journey recorded as working time in March and not in June is a problem the answer itself would not have been.

Sector rules on top

Driving times are separately regulated, with tachograph requirements and their own enforcement. Where they apply they are the stricter regime and satisfying them generally satisfies the general duty for the driving portion.

But not for the rest of the day. A driver's non-driving working time is still working time under the general duty, and a record covering only driving is incomplete.

Construction, healthcare and aviation each have their own layers, and none replaces the general obligation.

What works practically

Recording on a device the person already carries, because anything requiring a return to base gets reconstructed at the end of the week.

Simple entries. Start, end, breaks, and a per-job split only if the business needs it — the duty does not.

Offline capability. A site with no signal is common, and a system that cannot record offline produces gaps precisely where the work is.

And a same-day habit tied to something that already happens — leaving a site, finishing a job.

What not to do

Location tracking as a proxy for hours. Not required by the duty, and it substitutes a machine's view for a record of work. It also converts a compliance system into a monitoring one, with everything that follows.

Geofenced automatic clock-in, for the same reason plus a practical one: it records arrival at a place, not the start of work, and the gap is systematic.

And inferring hours from job completion timestamps. It is a reconstruction, and reconstructions are weak on the objective limb.

The rule that saves the most argument

Write the boundary answers into the contract or the policy, before the first dispute.

Travel from home, travel between jobs, waiting, standby. Four sentences. They are the questions that generate claims for unpaid time, and having answered them in advance is worth more than any feature of any system.

The short version