ECJ: Travel times are working time – what companies must now implement

EuGH Urteil Fahrtzeiten sind Arbeitszeiten ZMI GmbH
With the ruling of October 9, 2025 (Ref. C-110/24 ), the European Court of Justice (ECJ) has made a decision on the classification of travel and travel times as working time that is extremely relevant for companies in practice. The decision particularly affects companies with mobile activities, changing work locations or collective transportation of employees. HR decision-makers and managing directors are now faced with the question of which times must be recorded as working time in future – and what organizational and legal consequences this will have.  

Background to the ECJ ruling

The ruling was based on a case in which employees were obliged to go to a meeting point specified by the employer in order to be transported from there together in a company vehicle to changing work locations. The ECJ had to clarify whether the time spent on these mandatory journeys is to be regarded as working time within the meaning of the Working Time Directive 2003/88/EC. Even if no active work is performed during the journey.  

Key statement of the ECJ

The European Court of Justice (ECJ) clarified in its ruling: Travel and travel times between a meeting point specified by the employer and the actual place of work are considered working time if participation is mandatory and the time is in the predominant interest of the employer. The decisive factor is not whether work is carried out during the journey, but whether the employee is available to the employer and cannot freely dispose of their time.  

Working hours vs. remuneration

Important for companies: The ECJ ruling primarily concerns the classification under working time law, not automatically the obligation to pay remuneration. Nevertheless, the classification as working time has a significant impact on:
  • The maximum daily and weekly working hours,
  • the statutory rest periods,
  • Working time accounts and
  • the obligations regarding occupational health and safety.
National regulations, for example on remuneration, remain applicable in principle, but must take into account the health protection requirements under European law.  

Which companies are particularly affected?

The ruling is particularly relevant for companies with:
  • Field service or service teams,
  • Construction and assembly work,
  • Care and social services,
  • Technical customer service and
  • regular collective transportation in the company vehicle.
Wherever employers specify the time, place and type of journey, there is an increased risk that these times will be regarded as full working time in future.  

Practical consequences for human resources

Working time recording

In future, digital time recording systems must also be able to correctly record mandatory travel and travel times. This applies in particular to start and end points outside traditional business premises.

Working time models and duty rosters

Longer travel times can lead to the maximum permitted working times being reached more quickly. Duty rosters and deployment times should therefore be reviewed and adjusted if necessary.

Health and liability risks

If travel times are not taken into account, there is not only a risk of violating working time legislation, but also increased liability risks in the area of occupational health and safety and duty of care.  

Recommendations for companies

  • Analysis of all mandatory travel and collection times
  • Review of existing working time models
  • Adjustment of employment contracts and works agreements
  • Training for managers and dispatchers
  • Consistent documentation for legally compliant working time recording
 

Conclusion and summary

In its ruling of 09.10.2025 (Case C-110/24), the European Court of Justice further clarifies the concept of working time and strengthens the health protection of employees. In future, travel and travel times will always be considered working time if they are specified by the employer and the employee cannot freely dispose of their time. For companies, this means
  • More responsibility in organizing working hours
  • Higher demands on planning and documentation
  • Greater importance of health protection and rest periods
At the same time, the ruling offers the opportunity to modernize existing processes, create transparency and reduce working time risks in the long term. Companies that classify travel and travel times in a legally compliant manner at an early stage, adapt their working time models and sensitize managers not only ensure compliance, but also strengthen the trust and satisfaction of their employees.

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