Cash advance app rules in Maryland

Fees

• A delivery or expedited-delivery fee may not exceed $5.00 for an advance of $75.00 or less, or $7.50 for an advance over $75.00 (Com. Law 12-1505).
• A provider may not receive interest from a consumer (12-1504(6)). For this subtitle, "interest" does not include a fee imposed by a licensed EWA provider (12-1501(I)).
• Whenever it offers EWA for a fee or asks for a tip, the provider must offer at least one reasonable no-cost option and clearly explain how to choose it (12-1503(A)(3), (4)).
• "Loan" includes earned wage access, and a consumer-directed EWA loan is subject to the Consumer Loan Law subtitle whether or not elected (12-1501(J); 12-319).

Tips

• Any default tip must be set at zero (12-1503(A)(9)).
• Immediately before each transaction, the provider must disclose that tips are optional and voluntary and do not go to any specific employee or individual (12-1503(A)(9)).
• The service contract must say that tips are voluntary and that the amount and frequency of advances do not depend on tips (12-1503(A)(9)).
• The provider may not condition access to EWA on paying a tip, or share fees or tips with the employer (12-1504(1), (2)).

Other rules

• No late fees, interest or penalties for non-payment; no reporting non-payment to credit bureaus; no using credit reports to qualify consumers (12-1504).
• No lawsuits, third-party collection or sale of debts to collect (12-1504(7)).
• The provider must reimburse overdraft or NSF fees caused by its repayment attempts within 5 business days, except in cases of fraud (12-1503(A)(11), (B)).
• Providers must file an annual report with OFR by July 1, starting in 2026 (12-1506). OFR adopted COMAR 09.03.10.06 for these reports, effective July 20, 2026.
• Chapter 847 (HB 1294) was "Enacted under Article II, § 17(c) of the Maryland Constitution, May 25, 2025."

Who is licensed or registered

The state publishes an official list.

We have not been able to check this list yet (it sits behind a verification step we don’t automate). Search it yourself at the link above.

Lists change. Check the regulator’s current list before you rely on it.

Enforcement and official actions

• 2026-05-05 Maryland Office of Financial Regulation, guidance. Advisory telling EWA providers what to report for Oct. 1, 2025 to April 30, 2026, including no-cost option use, tip data and the number of advances per pay period. Official document
• 2026-07-24 Maryland Office of Financial Regulation, order. Notice of final action: amendments to COMAR 09.03.10 setting EWA reporting requirements took effect July 20, 2026. Official document

A complaint or lawsuit contains allegations; it is not a finding unless a court or agency says so.

What we could not confirm

• Which apps hold a Maryland consumer loan license: NMLS Consumer Access was not queried because it requires a CAPTCHA.
• How 12-319 (consumer-directed EWA subject to the Consumer Loan Law subtitle) and 12-1502(C) (licensed EWA providers exempt from other lending law subtitles) fit together: both are quoted as written, and no OFR interpretation was found.
• Baltimore City v. MoneyLion (D. Md.), listed in the page plan, was not checked here.