To amend section 1321.21 and to enact sections 1320.01, 1320.02, 1320.03, 1320.04, 1320.05, 1320.06, 1320.07, 1320.08, 1320.09, and 1320.10 of the Revised Code to regulate the provision of earned wage access services.
HB152 creates a new regulatory framework in Ohio for “earned wage access services,” which are services that let workers access wages they have already earned before their normal payday. The bill defines key terms such as provider, consumer, earned but unpaid income, and fees, and it requires companies offering these services in the state to obtain a certificate of registration from the Division of Financial Institutions. It also sets application requirements, background checks for key officers, annual renewal fees, minimum net worth and asset standards, and recordkeeping and reporting obligations.
The bill also imposes consumer-protection rules on providers. These include clear fee disclosures, a requirement to offer at least one no-cost option, the right for consumers to cancel without penalty, limits on how tips or donations may be solicited, and restrictions on collections practices. Providers may not use credit scores to determine eligibility, charge interest or late fees, report nonpayment to credit bureaus or debt collectors, or treat these services as loans, credit, money transmission, or interest-bearing transactions. The superintendent is given authority to examine records, investigate violations, suspend or revoke registrations, issue fines, and adopt rules to administer the chapter.
If enacted, HB152 would add a new chapter to the Revised Code governing earned wage access services and would amend section 1321.21 to route fees, charges, penalties, and forfeitures into the consumer finance fund. It would place these services under the oversight of the Division of Financial Institutions, create a registration regime for providers, and exempt compliant providers from treatment under certain existing lending, debt collection, and money transmission laws. The bill would directly affect earned wage access companies, employers that partner with them, and Ohio consumers who use early wage access products.
Because the bill was introduced without recorded committee testimony or votes in the provided materials, there is no documented floor or committee sentiment to measure. The text itself suggests a policy approach that is generally supportive of allowing earned wage access services to operate, while pairing that permission with significant consumer protections and state oversight. The overall tone is regulatory rather than prohibitive, indicating an effort to legitimize the industry while limiting abusive practices.
The main likely points of contention are the bill’s treatment of fees, tips, and repayment practices, and whether earned wage access should be regulated as a financial product at all. Consumer advocates may focus on disclosures, voluntary tips, no-cost access, and bans on debt collection-style enforcement, while industry stakeholders may be concerned about registration costs, net worth requirements, background checks, and reporting obligations. Another potential issue is the bill’s express declaration that compliant earned wage access is not a loan, credit, or money transmission, which could draw scrutiny from regulators or critics who believe the product functions like short-term credit.