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Earned wage access is being shaped into a global standard, and the practices that define responsible EWA are being written now.
Immediate is participating in an international working group convened by the International Labour Organization to help develop good practices for the responsible delivery of EWA worldwide.
We sat down with Ann Dyer, Product Owner at Immediate, who took part in the working sessions, to talk about what the group agreed on, what it ruled out and what Immediate brought to the table as the U.S. provider.
The ILO is the United Nations agency that sets international labor standards, and EWA has grown large enough to warrant that attention.
"It was exciting to hear not only what other countries are doing today, but how they have worked through some of the same challenges we have," Ann says. "It was also interesting to see how much we align, from a product perspective all the way to what should be considered a core practice."
For Ann, the scope of the work is what stands out. "You aren't just standardizing EWA as a business. You are shaping what EWA could be and the impact it has from an employee standpoint."
"Immediate offers EWA at a scalable level in the U.S., and the ILO was looking for a provider that could represent the U.S. market and help fill that gap for emerging EWA leaders," Ann says.
Core practices are the baseline a provider must meet today. Emerging practices are where the industry is headed.
"Core is the minimum set of guidance a provider must meet right now," Ann explains.
"Emerging is guidance a provider should strive to add to their EWA product, but that isn't ready to be mandatory yet."
Automated data feeds from payroll systems is a clear example of the second category. In the U.S., it is already the norm.
"Payroll systems with API or file sharing is standard infrastructure for most payroll providers in the U.S.," Ann says. "That is one thing mature markets have today that developing markets will hopefully grow into."
It requires consent, visible eligibility, transparent fees, and a clear record of every transaction.
Worker-centric product design is the kind of phrase any provider would claim. The working group defined what it means in practice. According to Ann, a compliant experience does four things:
None of these are complicated to build. The point of the framework is that they are not optional.
Two practices were moved into the avoiding column: employer revenue sharing on fees, and paying workers in vouchers or coupons.
The first surprised Ann, though not because of where it landed.
"I was a bit taken aback that this was still in discussion as it goes against FLSA standards in the States and it’s also something Immediate has never believed in." she says. "But we were on a call with providers from very different countries and very different business cases. I was pleased to see it marked as an avoiding practice. Employers should not have revenue generation on EWA fees."
The second was offering vouchers and coupons in place of accessible wages. "That is something we do not do, and it was also moved to an avoiding practice."
You fix the rules and leave the mechanism open.
The framework is designed to apply across countries, business models and delivery approaches without prescribing a single EWA model. Ann describes the logic simply.
"The framework is a set of rules, not a description of how it works. Consent, transparency, employers staying out of economics. Those are the rules. How each rule is fulfilled depends on what is available in that market."
She points to payroll data as an example. A market where the payroll system supports only manual upload still satisfies the rule that EWA data originates in the payroll system. The file is uploaded by hand rather than delivered through an API or SFTP. The standard holds. The mechanism adapts.
Experience from one of the world’s most established EWA markets, along with a working model for responsible access controls that can be configured rather than imposed.
In the United States, EWA has moved well beyond an emerging concept. By 2022, more than 7 million workers were using employer-partnered EWA, accessing approximately $22 billion through 190 million transactions. That equates to an average of 27 transactions per user during the year, demonstrating how routinely EWA has become part of the financial lives of many American workers. Reuters reported these findings from CFPB market data.
The regulatory landscape has also continued to mature. At least seven states have enacted legislation specifically governing EWA providers, including Nevada, Missouri, Wisconsin, Kansas, South Carolina, Arkansas, and Utah. These frameworks establish expectations around areas such as registration, disclosures, consumer choice, fee transparency, privacy, and non-recourse access while recognizing qualifying EWA models as distinct from traditional lending.
This combination of scale, operating experience, and evolving regulation gives U.S. providers practical insight into what makes EWA responsible. Access alone is not enough. Program design, including the percentage of wages available, frequency of access, fee structure, recovery method, and payroll integration, determines whether EWA supports an employee’s financial wellbeing.
“Immediate focuses on responsible EWA,” Ann says. “We have access controls and guardrails built into our system, and there is room to adjust them within reason. Companies can configure their guardrails from the company group level all the way down to the individual user level, always with the employee’s interest in mind. That is not something I recall other providers describing in the same way.”
That flexibility matters well beyond program design. It provides a practical example of how responsible principles can be translated into operating controls while still allowing employers to respond to the needs of different workforces.
Configurable guardrails are what allow a single platform to meet different regulatory requirements.
Compliance came up repeatedly across the sessions, because every participant is solving for a different regulatory environment.
"Every market has to work out how its own country handles compliance," Ann says. "The ILO was very interested in how U.S. providers are doing this and staying ahead of regulation."
The output of this working group will not change how any individual provider operates overnight. What it establishes is what a worker should be able to expect from EWA regardless of which country they are paid in or which provider their employer selected.
For a product category still writing its own rules, international labor standards is a meaningful step forward!
Learn more about our ILO partnership here.
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