Maryland Enacts Earned Wage Access Law

On May 28, Maryland Governor Wes Moore signed House Bill 1294 into law, establishing a comprehensive regulatory framework for Earned Wage Access (EWA) providers operating in the state. Effective October 1, the new law provides for licensing of both employer-integrated and consumer-directed EWA providers under the Maryland Consumer Loan Law, while also introducing a host of new consumer protection requirements.

The law is a response to prior regulatory guidance that restricted EWA services in the state and prompted many providers to exit the market. Like previous bills passed by other states, the bill codifies permissible EWA practices by formally defining employer-integrated and consumer-directed models (previously discussed here), clarifying that these services are not loans if providers do not charge interest and comply with specific statutory conditions. It also creates a special licensing framework that enables complaint providers to legally reenter the