Work-related travel beyond a worker's normal workplace counts as working time according to a ruling by the European Free Trade Association (EFTA) Court in Thorbjorn Selstad Thue v Norway. This could include journeys to and from home to carry out special assignments, even when those journeys fall outside normal working hours.
This decision goes further than the ECJ's ruling in Tyco (which concerned travel time for peripatetic workers), since it covers workers with a habitual or normal workplace. It casts doubt on the correctness of the current UK government guidance that work-related travel outside of normal working hours would not normally count as working time. However, EFTA decisions are not strictly binding on EU member states (the EFTA Court only interprets EU legislation applicable to Iceland, Liechtenstein and Norway as a result of their participation in the European Economic Area).
If the EFTA decision is correct, it would not necessarily mean that work-related travel must be paid, only that it would need to counted as working time when calculating average weekly hours and daily/weekly rest entitlements. Nor would it change the position for a worker's daily commute: travel to and from a worker's habitual workplace does not count as working time.