The recent publication of the Woolard Review marks a turning point for Employer Salary Advance Schemes (ESAS), the payment innovation sometimes known as ‘Earned Wage Access’ or ‘On-Demand Pay’. The Woolard Review is the latest report by the Financial Conduct Authority (FCA) into ‘change and innovation in the unsecured credit market’ and focusses exclusively on Buy Now Pay Later (BNPL) and Earned Wage Access services. In the report, the FCA states that Salary Advance schemes:

As the maturity of providers increases, this endorsement by the FCA moves Earned Wage Access from the periphery to the mainstream of technical innovation in payments. For employers, it is a case of ‘when’ not ‘if’ to consider introducing Earned Wage Access to staff and the debate now centres around the most responsible way to deploy it. New ethical challenges always accompany technological innovation. In assessing the benefits outlined above, the Woolard Review concluded that it had seen no evidence of crystallisation or widespread consumer detriment from Earned Wage Access. It did, however, identify a number of risks associated with its use. These included the risk of persistent use compounding the problem of short-fall at month end, fees making the service more expensive than alternatives and the ongoing question of who should bear the responsibility for individuals who find themselves in financial difficulty. This article outlines the key criteria employers should look for when looking for an ESAS provider.

1.  Earned Wage Access should always be part of a holistic programme

Like other forms of health, financial health is a long-term habit, not a destination. Its attainment requires individuals to develop the correct skills, knowledge and attitudes whilst being able to access relevant digital financial products and services.

Earned Wage Access can be a valuable stop-gap to short term financial needs but is not a standalone solution to financial wellbeing .

Employers should look to offer a holistic suite of services that include budgeting tools, financial education and, above all, savings. They should be wary of those who make bold claims about establishing new habits with point solutions in record time. There are no shortcuts to long-term health.

2. Earned Wage Access providers should not be solely reliant on income from advances

An important corollary to number one is to ensure that the commercial interests of the Earned Wage Access provider and the financial health of the end user are aligned. Perhaps surprisingly, this isn’t always the case.

If the Earned Wage Access provider’s sole source of income is fees associated with use of the service, it is inevitable they will come under pressure from shareholders to optimise usage. This drive is at odds with a responsible approach to implementation and will ultimately make ESAS part of the problem rather than part of the solution.

Employers should look for providers whose commercial model generates sustainable income from overall engagement with a suite of services that improve a users’ long-term financial health, not just fees from advances.

3. Beware of free

The FCA explicitly criticised Earned Wage Access providers willing to offer salary advances services at no charge as long as the employer also takes certain other commercial services with the operator, for example, factoring invoices, that have little to no impact on the overall goal.

This brazen attempt to lock in employers will be at odds with their mission to improve the financial health and wellbeing of their staff and should be a cause for concern.

4.  Earned Wage Access providers should adhere to a Safe Use Policy

The FCA encourages Earned Wage Access providers and major employers to draw up a code of best practice for salary advances and, where firms are regulated for part of their activity by the FCA, the FCA should look to formally recognise the code.

With no extant industry code as yet, employers should look for partners with clearly defined policies for both the ‘Safe Use’ of Earned Wage Access and mission statements that go beyond commercial gain and shareholder value.

5.  Earned Wage Access providers should work with employers

Employers should look for service controls (or ‘safeguards’) that can be configured by the employer and adjusted over time.

Safeguards should be set for frequency of use, percentage of salary that can be advanced and an upper cap for total monthly amount.

6. A responsible approach to the vulnerable

Any assessment of Earned Wage Access must take into account the shortcomings of the status quo.

The continuing success of PayDay Loan providers indicates persistent demand for low value borrowing to offset short-term expenses. Research indicates that part of the appeal of PayDay Loans is their confidentiality and the fact that transactions are conducted in a non-judgemental context.

To this end, it is crucial to respect the dignity of end users and recognise the importance of maintaining confidentiality to alleviate recourse to PayDay Loans.

At the same time, providers should use automated monitoring tools to identify early signals of financial difficulty and proactively reach out to individuals of concern.

In certain circumstances they may choose to limit access to the service but, in the interests of user confidentiality, only share this information with employers in exceptional circumstances.

Conclusion

Pay is foundational to the relationship between employers and employees. It is unsurprising, therefore, that any change to its delivery is viewed with caution. Excessive hubris by some providers of Earned Wage Access has undermined the pace of its adoption in the UK.

Despite the recognised benefits, providers must be sensitive to the concerns of employers in respect to the introduction of this service to their staff.

The far-reaching effects of Covid-19 have strengthened the case for greater pay flexibility and most employers now acknowledge the benefits of making changes.

The Woolard Review should give reassurance to employers that Earned Wage Access is a beneficial innovation in payments, as long as it is implemented responsibly.