— Journeys in between appointments during the working day

The issue of journeys between jobs during the working day is not dealt with in the Tyco ruling. This is because, in the case at hand, these periods were already counted as part of the daily working hours calculated by the employer (166). However, given this ruling and depending on the exact facts of the case on which a ruling would be requested, the Commission considers that journeys in between jobs during the working day would also qualify as working time. This would be the case if the following conditions were met: if the journeys concerned constitute a necessary means of providing the services to customers and they must therefore be regarded as periods during which the workers carry out their activity or duties; if the workers concerned are at the employer’s disposal during that time, meaning that they act on instructions of the employer and they cannot use their time freely to pursue their own interests; if the time spent travelling forms an integral part of the workers’ work and the place of work of such workers cannot therefore be reduced to the premises of their employer’s customers.

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Source: EUR-Lex (Cellar) · retrieved 2026-09-25 · Text as adopted (Official Journal); later amendments are not incorporated in this text.