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nid 92405
May 05, 2026
ataylor@vixio.com
Maryland
Industry Advisories - Office of the Commissioner of Financial Regulation
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1925 charsMaryland's Office of Financial Regulation Issues Advisory on Earned Wage Access Provider Reporting Requirements
On May 5, 2026, the Office of Financial Regulation (OFR) issued an advisory to all Earned Wage Access Providers regarding their annual reporting obligations under Commercial Law Article, §12-1506. The advisory specifies the information and data the Commissioner requires for the initial reporting period ending June 30, 2026.
The reporting requirement implements House Bill 1294 (2025). On April 3, 2026, OFR published proposed regulations at COMAR 09.03.10.06 to establish the framework for annual reporting. The advisory clarifies baseline reporting items and additional information required for the 2026 reporting year, including: total number of consumers served; total transactions; repeat consumers; average transactions per consumer; consumer demographic information; default rates; total revenue; and processing fees collected. Providers must also report on no-cost option utilization, tip data (if applicable), and advance size distribution. Consumer demographic information includes geographic distribution by Maryland county or zip code, whether earned wage access is consumer-directed or employer-integrated, and industries or occupational categories served. All reported data must reflect activity involving Maryland consumers only. The advisory defines key terms including "repeat consumer," "average number of transactions per consumer," "revenue," and "processing fees" to ensure consistent reporting methodology.
Earned Wage Access Providers must submit reports electronically to OFR on or before July 1, 2026, covering the period from October 1, 2025, through April 30, 2026. Providers may submit via a secure link or contact Clifford Charland, Assistant Commissioner for Financial Services, Licensing & Supervision, at 410-230-6167 or [email protected] for submission assistance. OFR anticipates issuing final regulations shortly following the closure of the comment period on proposed COMAR 09.03.10.06.
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2174 charsMaryland Office of Financial Regulation Issues Advisory and Annual Reporting Requirements for Earned Wage Access Providers
On May 5, 2026, the Maryland Office of Financial Regulation (OFR) issued an advisory to all earned wage access providers operating in the state, notifying them of their obligation to submit an annual report. The advisory follows the enactment of House Bill 1294 (2025) and proposed regulations at COMAR 09.03.10.06 , which implement annual reporting requirements under Maryland's Commercial Law Code, §12‑1506 . The initial report covers the period from October 1, 2025, through April 30, 2026, and is due July 1, 2026.
The advisory details the following reporting requirements for providers:
Baseline reporting items: Providers must report total number of consumers served, total transactions, number of repeat consumers, average transactions per consumer, default rates, total revenue, and total processing fees collected.
No‑cost option utilization: Providers must disclose how often consumers choose no‑cost options versus fee‑based options, the percentage of no‑cost transactions, a description of each no‑cost option (including delivery method and average wait time), and the average wait time for fee‑based options.
Tip data: If providers solicit or receive tips or donations, they must report total tip amounts, number and percentage of transactions with tips, average tip per transaction, and a distribution of tip amounts in $1 increments.
Advance size distribution: Reports must include the number and dollar amount of advances of $75 or less and over $75, the average advance size, data on consumers who receive more than one advance within a single payroll period, and total fees collected from those consumers.
Consumer demographic information: To the extent collected, providers must report geographic distribution by Maryland county or zip code, whether the consumer uses a consumer‑directed or employer‑integrated model, and the industries or occupational categories served.
The advisory requires all earned wage access providers to submit their completed annual report to the OFR electronically by July 1, 2026. Providers may submit their reporting materials via a secure link or contact Clifford Charland for assistance with the submission process.