Paying only face-to-face time and ignoring inter-call travel
<a href="https://www.gov.uk/guidance/calculating-the-minimum-wage/working-hours-for-which-the-minimum-wage-must-be-paid">Travel between client visits is working time for NMW purposes</a>. Rota systems that pay only for contact time and nothing for inter-call journeys create unlawful pay shortfalls. This is the single most common source of NMW underpayment in domiciliary care and a specific HMRC audit focus.