On May 6, Indiana Governor Mike Braun signed House Enrolled Act No. 1125 into law, making Indiana the latest state to enact a statutory framework for regulating earned wage access (EWA) products. The Indiana Earned Wage Access Act, which takes effect January 1, 2026, requires most EWA providers to obtain a license from the Indiana Department of Financial Institutions and comply with operational, disclosure, and consumer protection requirements.

The Act distinguishes between “employer-integrated” and “consumer-directed” EWA models. Employer-integrated models rely on income, attendance, or other employment data supplied directly by the employer. Consumer-directed models, by contrast, are based on a provider’s reasonable determination of a consumer’s earnings using information reported by the consumer. 

The Act also clarifies that services offered in accordance with the new framework are not considered loans or credit under Indiana law. Other key provisions include: 

Putting It Into Practice: With Indiana’s enactment of HEA 1125, eight states have now adopted EWA-specific laws (previously discussed herehere, and here). Indiana’s framework reflects a growing recognition that EWA products are not loans. As more states enact laws governing EWA products, providers should remain attentive to new legislative and regulatory developments that may impact their compliance obligations.

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