Maryland Earned Wage Access Law: What Employers Should Know

Maryland has become one of the latest states to regulate Earned Wage Access (EWA), also known as on-demand pay. In 2025, the Maryland legislature passed House Bill 1294, establishing clear standards for how EWA providers can operate in the state beginning October 1, 2025. In addition, Governor Wes Moore enacted further EWA provisions on April 28, 2026 under Senate Bill 94.

The law gives Maryland employers and workers greater confidence in using EWA programs that help employees access their earned wages safely and transparently.

Which bill regulates earned wage access in Maryland?

House Bill 1294 adds Subtitle 15 to the Maryland Consumer Loan Law and regulates both employer-integrated and direct-to-consumer EWA models. It requires providers to be licensed, disclose fees clearly, and comply with certain privacy and information security laws.

The law also clarifies that EWA advances are loans for the purposes of Maryland law.

What are the main requirements for EWA providers?

Key provisions include:

• Licensing and annual reporting to the Maryland Office of Financial Regulation

• A no-cost option for employees to access their earned wages

• Fee caps of $5 for transactions up to $75 and $7.50 for higher amounts

• Prohibition of tips

• No use of credit reports or debt collection practices

• Reimbursement for overdraft or NSF fees caused by the provider

• No sharing of fees with employers

• No interest or late fees

What does this mean for employers with employees in Maryland?

The law provides greater clarity for Maryland employers to confidently offer EWA benefits. Partnering with a licensed EWA provider enables employees to manage cash flow between paychecks while maintaining full transparency and consumer protection.

Which other states regulate earned wage access?

Maryland joins Arkansas, California, Connecticut, Indiana, Kansas, Louisiana, Missouri, Nevada, South Carolina, Utah, and Wisconsin in passing EWA legislation. 

What about the states that have yet to adopt a regulatory framework for EWA? A model that may be able to operate nationwide is one structured as no-cost debt. 

The takeaway

For employers, Maryland's earned wage access law adds regulations and requirements that help create a safe space for financial wellness benefits designed to empower employees and strengthen retention.

_{This guide is for informational purposes only. Chime does not provide financial, legal, or tax advice. You should check with your legal, financial, or tax advisor for advice specific to your situation.}