A Win for Workers: New 2025 CFPB Advisory Opinion Confirms EWA is Not a Loan

Payactiv applauds the federal Consumer Financial Protection Bureau (CFPB) on the release of a new Advisory Opinion affirming earned wage access (EWA) is not credit under the federal Truth in Lending Act (TILA).

This Advisory Opinion marks a pivotal milestone for Payactiv, employers, and workers alike. 

In 2013, Payactiv pioneered the EWA category to give customers access to their own, already earned wages. In doing so, we made employers an integral part of the solution. 

From the start, Payactiv designed EWA to be fundamentally different from traditional credit products. Payactiv’s employer-integrated EWA model is built on verified payroll data and payroll settlement. Our service includes strong consumer protections and intentionally avoids the hallmarks of lending, such as interest, recourse, credit checks, or credit reporting. Workers are simply accessing wages they have already earned, when they need them.

Today, the CFPB’s Advisory Opinion validates the industry we created and affirms what we have always known: EWA is not a loan.

This Advisory Opinion provides meaningful regulatory clarity for the EWA industry and reinforces the distinction between employer-integrated, consumer-friendly EWA and other financial products like payday loans that can trap consumers in cycles of debt.

On behalf of our Human Capital Management and employer partners – as well as the millions of workers who use Payactiv – we commend the CFPB for its thoughtful approach in upholding the consumer-friendly features that make EWA a preferred tool for managing everyday expenses, avoiding late fees, and reducing reliance on payday lending and other high-cost options.

We look forward to continuing to work with policymakers and champions on Capitol Hill as federal legislative efforts on EWA move forward.