2025 was a big year for earned wage access | PaymentsSource

• Key insights: 2025 was a year marked by new guidance from the CFPB, six new state regulations, product and market expansion from existing EWA providers, and buy-in from investors. 
• What’s at stake: Earned wage access is a burgeoning industry that has spurred controversy between groups usually in alignment on policy. 
• Forward look: Expect more states to finalize EWA regulations in 2026.  

The growing popularity of earned wage access is attracting regulators with a slew of new rules. 

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The year was marked with six new state regulations, effectively doubling the number of states that govern on-demand pay. Even state attorneys general threw their hat in the ring. And the CFPB finally weighed in nearly a year after the change of administration. 

“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,” Carlin McCrory, an associate at Troutman Pepper and Locke, told American Banker. 

“Earlier this year, when we looked at the proposed legislation, it was somewhere around 25 states had proposed, and not all of those enacted the legislation,” McCrory said. “I’m expecting something similar come springtime this year when the legislative sessions are active. We’ll see a host of new bills to analyze and see what passes.” 

Those regulations came as on-demand pay gained popularity as both a cash-smoothing tool and employee benefit offer, spurring new entrants to the market. That new-found popularity also encouraged existing providers to offer new products and services. 

It also caught the attention of investors, who bought $200 million of bonds backed by fees charged to DailyPay’s customers. 

Catch up on American Banker’s coverage of earned wage access below.