The year 2025 marked a significant turning point for the earned wage access (EWA) industry, characterized by new regulatory developments and increased market activity. The Consumer Financial Protection Bureau (CFPB) issued guidance, while six states enacted regulations, effectively doubling the number of states that govern on-demand pay. These changes reflect a growing recognition of EWA as both a financial tool for employees and a viable product for employers.
As the popularity of earned wage access continues to rise, various stakeholders have entered the conversation around its regulation. State attorneys general have also become involved, demonstrating the widespread interest in establishing a framework for on-demand pay. According to Carlin McCrory, an associate at Troutman Pepper and Locke, “We’re seeing more and more states adopt EWA regulation that’s both direct to consumer and employer integrated; generally, most states are covering both models.”
Earlier in the year, approximately 25 states had proposed legislation concerning EWA, although not all were enacted. McCrory anticipates a similar surge in legislative activity in the spring of 2026, when many state legislatures reconvene. “We’ll see a host of new bills to analyze and see what passes,” she noted.
The growing acceptance of EWA is attributed to its dual role as a cash-smoothing tool and an attractive employee benefit. This increase in demand has not only attracted new entrants into the EWA market but has also spurred existing providers to expand their offerings. The heightened interest from investors is evident, with a notable $200 million in bonds backed by fees from DailyPay customers being purchased recently.
As the regulatory landscape evolves, businesses and consumers alike are likely to feel the impact of these changes. The ongoing developments in EWA regulations will shape how employers integrate on-demand pay into their compensation structures, potentially transforming employee financial wellness in the process.
The 2025 developments in earned wage access regulation signal a growing trend that is expected to continue into 2026, with more states likely to finalize their own guidelines. Stakeholders are closely monitoring these changes, as they could lead to a more standardized approach for EWA across the United States.
In summary, the year 2025 has proven to be pivotal for earned wage access, marked by regulatory advancements and increased investment. As the industry matures, the implications for both workers and employers will become clearer, shaping the future of compensation practices in the process.