U.S. States Step Up Oversight of EWA and BNPL Services

Earned wage access, or EWA, lets workers draw wages before payday, while buy now, pay later services split purchases into installments. The rapid adoption of these products, alongside stablecoins and other payment tools, has outpaced uniform regulation. As the Trump administration reduces the Consumer Financial Protection Bureau’s oversight role, states are assuming greater responsibility for consumer safeguards, raising the prospect of divergent licensing and compliance obligations across the country.

Payments Dive reported on March 18, 2025, that lawmakers in at least 16 states had introduced EWA legislation, while 34 states had yet to act. Utah’s legislature passed a registration-focused measure that month, whereas California treated some EWA products as loans subject to lending laws. New York moved to oversee BNPL financing, and New York and Wyoming advanced stablecoin frameworks. Ballard Spahr formed a state attorneys general consumer response team in February as corporate clients braced for more fragmented enforcement.