# Maryland — State Earned Wage Access (EWA) Regulatory Frameworks — Classification, Fee Caps, and Licensing Requirements

For Maryland, statute citation is Md. Commercial Law §§ 12-1501 through 12-1507 (Ch. 847, HB 1294, 2025); effective date is October 1, 2025; product classification is earned wage access is a loan subject to the Maryland Consumer Loan Law; not money transmission; licensing requirement is consumer loan license required under Title 11, Subtitle 2 of the Financial Institutions Article; fee caps is $5.00 for any advance of proceeds equal to or less than $75.00; $7.50 for any advance of proceeds greater than $75.00, recorded from its source on 2026-08-18.

- **state:** Maryland _(verified: appears in the quote below)_
- **statute citation:** Md. Commercial Law §§ 12-1501 through 12-1507 (Ch. 847, HB 1294, 2025) _(our reading, not quoted from the source)_
- **effective date:** October 1, 2025
- **product classification:** earned wage access is a loan subject to the Maryland Consumer Loan Law; not money transmission _(verified: appears in the quote below)_
- **licensing requirement:** consumer loan license required under Title 11, Subtitle 2 of the Financial Institutions Article
- **fee caps:** $5.00 for any advance of proceeds equal to or less than $75.00; $7.50 for any advance of proceeds greater than $75.00
- **free option required:** yes — provider shall offer a reasonable option to obtain earned wage access at no cost

## What the source says

> subjecting certain earned wage access products to the Maryland Consumer Loan Law and other provisions that regulate entities that provide consumer credit, revolving credit, and closed end credit

## Source

- https://mgaleg.maryland.gov/2025RS/chapters_noln/Ch_847_hb1294T.pdf

Last verified: 2026-08-18. Review by: 2027-02-14.
Part of [State Earned Wage Access (EWA) Regulatory Frameworks — Classification, Fee Caps, and Licensing Requirements](https://referencesource.org/state-earned-wage-access-regulations/).