Joseph Campagna

Joseph Campagna

Joseph Campagna, SPHR, SHRM-SCP is president and owner of My Virtual HR Director, a human resources outsourcing company serving small and medium sized businesses nationwide. My Virtual HR Director provides an executive level HR advisor to companies that can’t afford or can’t justify hiring a fulltime HR professional on staff. With thirty years of experience dedicated to the HR profession, Mr. Campagna has honed his skills as an expert in compliance, talent management and employee relations. Bringing human capital management experience from start-ups, IT and biotechnology companies, employee leasing, and fortune 100 behemoths Mr. Campagna has filled his tool belt through generalist work, executive positions, and consulting opportunities with companies such as ADP, Merrill Lynch, and Johnson & Johnson. As Vice President of HR for biotech company Hemo Concepts, as well as the head of HR for the global IT solutions company, the Galaxy Group, Mr. Campagna created rich and successful organizational development and employee engagement programs. Having worked with a diverse group of companies and clients in a broad spectrum of industries and environments, he brings a unique HR philosophy to every organization he works with. “HR is not the picnic department,” he says “but instead bears the full responsibility and the unlimited potential for a highly productive and efficient workforce. If HR systems are successful, the organization’s revenue should be increased.” From mergers and acquisitions, to IPO’s, to new product development, to divestiture Mr. Campagna has a true business background to support his HR Architecture. Mr. Campagna is certified as a senior professional through both the Human Resources Certification Institute (HRCI) and the Society for Human Resource Management (SHRM). The HRCI designation of Senior Professional in Human Resources (SPHR) is an experienced-based examination certification. The SHRM certification is a competency based examination certification. Each is a premier designation in the world of HR and recognized by the Society for Human Resource Management of which Joe is a national member and former chapter president. Mr. Campagna brings decades of helping small and medium sized businesses create HR structures such as employee handbooks, performance systems, talent management, training programs, and employee engagement. He knows how to deliver business results through HR aligned objectives. Nearly 30 years of expertise and HR executive authority combined with a group health insurance license and certifications from the Society for Human Resource management and the Human Resources Certification Institute have given Joseph Campagna the guru status that has earned him leadership roles, board of director roles, and speaking engagements related to human resources.

On Posted on by Joseph Campagna to Educational, HR Consulting, Outsourced Payroll

Pay Card Laws by State: All 50 States Reference Guide

My Virtual HR Director provides outsourced payroll through our Managed Payroll Service.

Wondering if you can pay employees with a pay card? Is your payroll pay card program compliant? Review our 50-state map and legal table below outlining wage payment laws, employee consent requirements, and payroll card regulations.

Key findings at a glance:

  • 12 states + D.C. have no state-specific pay card law (federal Regulation E governs)
  • ~37 states have explicit pay card regulations — the vast majority require voluntary employee consent
  • Only Kansas allows employers to mandate pay cards outright
  • Maryland and Virginia allow limited forced usage (e.g., if an employee doesn't designate a direct deposit bank)
  • Nearly all states with laws require at least one free withdrawal per pay period

Our payroll specialists and HR Experts guide employers through the risky web of payroll compliance so that they don't have to worry about payroll compliance.  FOR A FULL ANALYSIS OF DEBIT CARDS AND WHTHER YTHEY ARE RIGHT FOR YOUR ORGANIZATION, VISIT OUR BLOG POST ABOUT PAYCARDS.

Payroll Debit Cards —

Commonly referred to as pay cards — are a lawful wage payment method in many states, but the legal framework varies significantly across jurisdictions. Some states have enacted express statutes or regulations governing payroll cards. Others remain silent, requiring employers to rely on general wage payment laws and federal Electronic Fund Transfer Act (EFTA) rules.

This 50-state table and compliance map are designed to help employers, CFOs, HR leaders, and payroll administrators quickly identify:

  • Whether a state has explicit legal authority addressing payroll pay cards
  • Whether pay cards may be required or must remain voluntary
  • The specific statutory or regulatory citation governing payroll card programs
  • The general wage payment statute that applies when no express pay card law exists

This resource serves as a compliance research tool — not as a substitute for legal advice — and is intended to support employers evaluating whether payroll pay cards are appropriate within their organization’s payroll risk framework.

50-State Pay Card Law Matrix

A comprehensive, easy-reference table for employers on payroll card (pay card) regulations, mandatory use rules, and implementation requirements across all 50 U.S. states.

     

    ⚠️ Legal Disclaimer: This table is provided for informational purposes only and does not constitute legal advice. Laws change frequently — always verify with your state's Department of Labor or consult a qualified employment attorney before implementing a pay card program.
    ✔ Allowed ✘ Not Explicitly Allowed / Restricted ◑ Allowed With Conditions — No State-Specific Law (Federal Rules Apply)
    State Pay Cards Allowed? Employer Can Require? Key Employer Requirements Statute / Source
    Alabama — No State Law No No state-specific pay card law. Federal EFTA/Regulation E applies. Employers must offer at least one alternative payment method; cannot force pay cards. Federal Reg E ↗
    Alaska — No State Law No No state-specific pay card law. Federal rules apply. Must provide an alternative payment option. AK Dept of Labor ↗
    Arizona ◑ Allowed With Conditions Limited
    • Must obtain employee consent or employee enrolls in direct deposit without designating a bank
    • One free withdrawal per pay period
    • Written or electronic pay stub required
    • Written fee disclosure required
    		 A.R.S. § 23-351 ↗
    Arkansas — No State Law No No state-specific pay card law. Federal EFTA/Regulation E applies. AR Dept of Labor ↗
    California ◑ Allowed With Conditions No
    • Participation must be voluntary (per Labor Commissioner opinion)
    • No fees when employee withdraws wages — card must be convertible to full cash value
    • Must comply with laws governing direct deposit and check payments
    • Employee can opt out at any time
    		 CA Labor Code § 212 ↗
    Colorado ◑ Allowed With Conditions No
    • Employee must be able to choose an alternative payment method (cash, check, or direct deposit)
    • One free withdrawal of full net pay per pay period
    		 CO CDLE Wage Rules ↗
    Connecticut ◑ Allowed With Conditions No
    • Must also offer direct deposit and paper check
    • Voluntary written or electronic consent required
    • Three free withdrawals per pay period
    • Written fee disclosure required
    • No employer costs may be passed to employees
    		 CT Gen. Stat. § 31-71 ↗
    Delaware ◑ Allowed With Conditions No
    • Employee must have one free withdrawal per pay period at a bank or establishment convenient to their workplace
    		 DE Admin. Code § 1324 ↗
    Washington D.C. — No State Law No No specific pay card legislation. Federal EFTA/Regulation E applies. DC Wage-Hour ↗
    Florida ◑ Allowed With Conditions No
    • Employee must be able to withdraw full wages without fees, on demand, at an in-state business
    • Card issuer name/address must appear on the card or issuing materials
    • Employer must have sufficient funds deposited for at least 30 days at time of issuance
    		 FL Stat. § 532.01 ↗
    Georgia ◑ Allowed With Conditions No
    • Written fee disclosure at least 30 days before card is available (or at time of hiring for new employees)
    • Employee may opt out via written request at any time
    		 GA DOL Wage Payment ↗
    Hawaii ◑ Allowed With Conditions No
    • Voluntary written or electronic consent required
    • Employee may opt out at any time
    • Pay stub required
    • Written fee disclosure (minimum 10-point font)
    • Three free withdrawals per pay period
    • Funds on card never expire
    • No overdraft fees
    • Free balance inquiries required
    • One free replacement card per year
    		 HI DLIR Guidance ↗
    Idaho — No State Law No No state-specific pay card law. Federal EFTA/Regulation E applies. ID DOL ↗
    Illinois ◑ Allowed With Conditions No
    • Voluntary written consent required
    • Written fee disclosure required
    • Must offer check or cash as alternative
    • At least one free withdrawal per pay period
    • One free paper pay stub per month
    • Two free phone balance inquiries
    • Inactivity charges cannot start until at least one year of inactivity
    		 820 ILCS 115 (IL Wage Payment Act) ↗
    Indiana — No State Law No No state-specific pay card law. Federal EFTA/Regulation E applies. IN DOL ↗
    Iowa ◑ Allowed With Conditions No
    • Voluntary written consent required
    • Written or electronic pay stub required
    • Employee must be able to withdraw all wages without a fee
    • Free withdrawal quantity depends on card's transaction limit relative to wages owed
    		 Iowa Code § 91A ↗
    Kansas ◑ Allowed With Conditions Yes – Can Require
    • Employer may mandate pay cards
    • Written fee disclosure at least 30 days before program begins
    • No initiation, loading, or participation fees charged to employees
    • One free withdrawal of full wages per pay period
    • Employees are responsible for replacement card fees
    		 K.S.A. § 44-314 ↗
    Kentucky ◑ Allowed With Conditions No
    • Employee can use card at no cost
    • Employee can switch payment method at any time
    • Pay cards expire after two years
    		 KY Labor Cabinet ↗
    Louisiana — No State Law No No state-specific pay card law. Federal EFTA/Regulation E applies. LA Workforce Commission ↗
    Maine ◑ Allowed With Conditions No
    • One free withdrawal per pay period
    • Employee must be offered an alternative payment method
    		 26 M.R.S. § 663 ↗
    Maryland ◑ Allowed With Conditions Limited
    • Employer may mandate choice between direct deposit or pay card (not paper check)
    • Written fee disclosure in at least 12-point font required
    • Employee voluntary consent/authorization required
    		 MD Code, Lab. & Emp. § 3-502 ↗
    Massachusetts — No State Law No No state-specific pay card law. Federal EFTA/Regulation E applies. MA EOLWD ↗
    Michigan ◑ Allowed With Conditions No
    • Voluntary employee consent required
    • One free withdrawal per pay period
    • Unlimited free balance inquiries
    • No employer pay card fees passed to employees
    • Employee may change payment method at any time
    • 21-day advance notice required before any fee/terms changes
    		 MCL § 408.476 ↗
    Minnesota ◑ Allowed With Conditions No
    • Voluntary written consent with fee disclosure required
    • One free withdrawal per pay period
    • One free transaction history per month upon request
    • Pay card must not be linked to any form of credit
    • Employee can change payment method at any time
    		 Minn. Stat. § 177.255 ↗
    Mississippi — No State Law No No state-specific pay card law. Federal EFTA/Regulation E applies. MS Dept. of Employment Security ↗
    Missouri ◑ Allowed With Conditions Limited
    • If employee lacks a checking/savings account or does not provide information for direct deposit, employer may default to pay card
    		 Mo. Rev. Stat. § 290 ↗
    Montana ◑ Allowed With Conditions No
    • Voluntary written or electronic consent required
    • Written fee disclosure required
    • One free withdrawal per pay period
    • Written or electronic pay stub required
    • Employee must have option to receive full wages via check or cash
    • No inactivity fees while a balance remains on the card
    		 MT DLI Wage & Hour ↗
    Nebraska ◑ Allowed With Conditions No
    • Must comply with federal requirements on compulsory electronic fund transfers
    • One free withdrawal per pay period
    • No pay card fees or costs passed to employees
    • Wage statement required each pay period
    		 Neb. Rev. Stat. § 48-1228 ↗
    Nevada ◑ Allowed With Conditions No
    • Voluntary employee consent required
    • One free withdrawal per pay period
    • Written fee disclosure required
    		 NRS § 608 ↗
    New Hampshire ◑ Allowed With Conditions No
    • Voluntary written consent required
    • Written fee disclosure required
    • One free withdrawal per pay period
    • Employee may change payment method at any time
    • Written notice of all payment options required
    • Written notice before any terms change; written re-consent required
    • Employer must replace expiring cards at no cost to employee before expiration
    		 RSA § 275:43 ↗
    New Jersey ◑ Allowed With Conditions No
    • Voluntary written consent required
    • Written fee disclosure required
    • One free withdrawal per pay period
    • Pay stub required
    • Employee may choose a new payment method at any time
    		 NJ P.L. 2016, c.121 ↗
    New Mexico ◑ Allowed With Conditions No
    • No specific pay card statute; general wage law applies
    • Wages must be paid in full with no reduction, deductions, or charges — unless agreed in writing at hiring
    • Voluntary employee consent required for electronic wage payment
    		 NMSA § 50-4-2 ↗
    New York ◑ Allowed With Conditions No
    • Proposed 2017 regulations were struck down; NY DOL relies on general wage payment laws
    • No fees for employees to withdraw wages
    • Written disclosure required
    • Employee must have access to a bank near their workplace for free withdrawals
    • Employee consent required; must be provided alternative payment options
    		 NY Labor Law § 192 ↗
    North Carolina ◑ Allowed With Conditions No
    • Employee must be able to withdraw all wages on payday
    • Payday card usage must be at no cost to the employee
    		 NC DOL Payroll Card Guidance ↗
    North Dakota ◑ Allowed With Conditions No
    • Employee must be given choice between pay card and direct deposit
    • Card must be issued by a federally insured bank or credit union
    • Funds must be FDIC insured
    • Employer must deposit sufficient funds to cover all wages and card fees before payment
    		 N.D. Cent. Code § 34-14 ↗
    Ohio — No State Law No No state-specific pay card law. Federal EFTA/Regulation E applies. OH Wage & Hour ↗
    Oklahoma ◑ Allowed With Conditions No
    • Voluntary employee consent required
    • Written or electronic pay stub required
    • Employee cannot be charged any fee for receiving wages electronically
    		 40 O.S. § 165.3 ↗
    Oregon ◑ Allowed With Conditions No
    • Employee consent required (may be verbal)
    • Employee may opt out verbally or in writing for a different payment method
    • Pay stub required
    • First pay withdrawal in full must be free of fees
    		 ORS § 652.110 ↗
    Pennsylvania ◑ Allowed With Conditions No
    • Cannot mandate pay cards
    • Zero fees associated with the pay card program
    • Free balance checking (electronically or by phone)
    • One free withdrawal of all wages per pay period
    • Written notice and authorization requirements
    • One free replacement card per calendar year
    • Employee may stop using pay card at any time
    		 43 P.S. § 926 ↗
    Rhode Island ◑ Allowed With Conditions No
    • Voluntary employee consent required
    • One free withdrawal per pay period
    • Employee must have a way to check pay card account balance at any time
    		 R.I. Gen. Laws § 28-14-10.1 ↗
    South Carolina — No State Law No No state-specific pay card law. Federal EFTA/Regulation E applies. SC Labor Dept. ↗
    South Dakota — No State Law No No state-specific pay card law. Federal EFTA/Regulation E applies. SD DLR ↗
    Tennessee ◑ Allowed With Conditions No
    • Employee must be able to withdraw or transfer wages from the card
    • One free withdrawal of entire net pay per pay period
    • Option of direct deposit must be offered
    • Written fee disclosure required
    • If employee doesn't designate a direct deposit institution, employer may default to pay card
    		 Tenn. Code § 50-2-103 ↗
    Texas ◑ Allowed With Conditions No
    • Written notice to employee required
    • Must provide employee a form to request an alternate payment method
    • Must obtain necessary employee information to process pay card payments
    		 TX Labor Code § 61 ↗
    Utah ◑ Allowed With Conditions No
    • Employee must be able to withdraw full paycheck without fees
    • Full wages must be on the card by payday
    • Written or electronic pay stub required
    		 Utah Code § 34-28 ↗
    Vermont ◑ Allowed With Conditions No
    • Written consent required after receiving fee disclosure
    • Branded pay cards only (Visa, MC, etc.)
    • At least three free withdrawals per pay period (access to full balance at federally insured institution)
    • No employer card costs passed to employees
    • One free written transaction history per month (upon request); must also offer via email
    • Employee can discontinue at any time
    • One free replacement card per year
    		 21 V.S.A. § 342 ↗
    Virginia ◑ Allowed With Conditions Limited
    • Full written disclosure of all applicable fees required
    • For employees hired after Jan. 1, 2010: if employee fails to designate a direct deposit institution, employer may pay via pay card without consent
    • At least one free withdrawal or transfer per pay period
    		 VA Code § 40.1-29 ↗
    Washington — No State Law No No state-specific pay card law. Federal EFTA/Regulation E applies. WA L&I Wage Rules ↗
    West Virginia ◑ Allowed With Conditions No
    • Written agreement required from both employer and employee
    • Paycard account must be held at a federally insured depository institution
    		 W. Va. Code § 21-5-3 ↗
    Wisconsin ◑ Allowed With Conditions No
    • Employee must consent in writing or be authorized by a collective bargaining agreement
    		 Wis. Stat. § 103.36 ↗
    Wyoming — No State Law No No state-specific pay card law. Federal EFTA/Regulation E applies. WY DWS Labor Standards ↗
    Showing all 51 entries (50 states + D.C.)
    Primary Sources & References Statute links are embedded in each row above. Additional reference sources used for this table include: Patriot Software – Pay Card Laws by State · Fingercheck – All 50 States Paycard Regulations · Federal Reserve – Regulation E · CFPB 2013 Payroll Card Bulletin · State Departments of Labor (linked per row). Last reviewed: February 2025. Laws are subject to change — always verify current statutes.
     

    Where a state has no express payroll-card statute, employers must rely on the general wage payment statute + federal Reg E and treat pay cards as voluntary, with fee-free full-wage access and clear disclosures.

    PAYROLL COMPLIANCE NOTE:

    No matter what your state, the safest compliant approach is:

    1. Make pay cards optional (never a condition of hire or continued employment).
    2. Get written, voluntary consent and provide plain-English disclosures of all fees and access methods.
    3. Ensure employees can access 100% of net wages without cost (at least once per pay period) and can obtain account info/transaction history. (This is explicitly required in several states and is the practical standard everywhere.

    Payroll Compliance Should Be Strategic — Not Reactive

    At My Virtual HR Director, we help employers:

    • Evaluate multi-state payroll compliance risks
    • Audit payroll pay card programs
    • Implement legally compliant wage payment systems
    • Reduce exposure to payroll-related litigation
    • Strengthen internal payroll controls

    Whether you operate in one state or all fifty, we help you structure payroll systems that align with both operational efficiency and regulatory protection.

    👉 Review Your Payroll Risk Exposure Today

    If you are currently using — or considering using — payroll pay cards, schedule a compliance review before rollout.

    Protect your organization. Protect your employees. Protect your payroll system.

    Talk to a Payroll Expert Now

    *This page is not legal, financial, or tax advice and should not be relied upon as such. Consult your attorney for legal advice regarding your own situation or your CPA for tax advice.

    Sources used:

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