Has an EWA law
Cash advance app rules in California
California requires providers of "income-based advances" (earned wage access) to register with the DFPI under the California Consumer Financial Protection Law, effective Feb. 15, 2025.
From official sources, checked 2026-10-18.
- Status
- Has an EWA law
- In effect since
- 2025-02-15
- License or registration
- Registration is required
Fees
- DFPI says registrants must report "charges", including subscription fees, expedited funds fees and account transfer fees, as gross income in annual reports due by March 15, starting in 2026.
- In its 2021 EWA data findings, published 2023, DFPI reported: "The average annual APR was 334% for tip companies and 331% for the non-tip companies." It counted tips in the APR and left subscription-fee companies out of the APR calculation.
Tips
- DFPI says optional tips are "charges" and must be reported as gross income from income-based advances.
- DFPI's 2021 data: tip-based companies received tips on 73% of transactions, with an average tip of $4.09 when a tip was given.
Other rules
- DFPI defines an income-based advance as an advance on accrued but unpaid income, collected in a single payment within 34 days. The provider must warrant that it has no legal or contractual claim against the consumer and will not use debt collection for non-repayment (10 CCR 1004, as summarized on the DFPI page).
- DFPI says registration covers both direct-to-consumer and employer-integrated EWA that meets the definition.
- Holders of a California Financing Law or CDDTL license that offer income-based advances under that license are exempt from CCFPL registration but must still file the CCFPL annual report.
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.
What we could not confirm
- Which apps are registered with DFPI for income-based advances: not checked (see providerList note).
- Whether the CCFPL regulations set any fee or tip limits for income-based advances: the full regulation text (10 CCR 1004 and related sections) was not reviewed.
- Exact publication date of the 2021 EWA Data Findings: the report says only "Analysis completed Q1 2023".
- The 2021 DailyPay MOU and the Feb. 11, 2022 DFPI Commissioner opinion mentioned in other sources were not checked.
Short on cash in California? Cheaper options, including 211 and credit union loans capped at 28% APR.
Sources
- DFPI: Income-Based Advances
- DFPI: 2021 Earned Wage Access Data Findings
- DFPI: PRO 01-21 final regulation text
Checked 2026-10-18. Not legal advice.