FinTech Embedded Payroll Advance Platform — UK HR SaaS

EWA FCA Regulatory Structure: Earned Wage Access FCA classification: EWA structured correctly is not a regulated credit product (no interest, no fixed repayment schedule, employer-facilitated salary advance). FCA EWA guidance (2023): voluntary code of practice — no interest, no fees to employee, repayment via payroll only, advance limit (50% of earned wages, capped at £500). Consumer Duty: even where not technically regulated credit, Consumer Duty applies to any retail financial product. EWA product design: zero fees, zero interest, payroll-only repayment (deducted by employer from next payroll run). HMRC Payroll Integration: HMRC Real Time Information (RTI): payroll deductions must be reported in FPS (Full Payment Submission) on or before payment date. EWA payroll deduction: when employee takes advance, employer records the advance amount as a deduction in next payroll run. API integration: HR SaaS payroll module → EWA deduction → RTI FPS automatic inclusion. HMRC PAYE: advance is not income (not subject to income tax or NI) — it is a salary advance, repaid from gross salary. Tax treatment confirmed with HMRC Technical guidance. Employee Financial Wellbeing Architecture: EWA access control: employee must have worked a minimum of 3 days in current pay period before EWA access enabled. Advance limit: 50% of earned wages to date (calculated from shift/timesheet data), maximum £500 per advance, maximum 2 advances per pay period. Eligibility: employed status verified in HR SaaS (no advances for employees under notice of termination). Financial wellbeing dashboard: YTD advance history, repayment status, budget tracker (optional — not mandatory for EWA access). UK GDPR Employee Financial Data: Employee EWA data: wage data (sensitive employment data), advance amount, repayment status. Legal basis: legitimate interests (employer offering financial wellbeing benefit) or contract performance (payroll administration). Employee consent: opt-in to EWA product explicitly — consent is not mandatory for employment. Data minimisation: only current pay period data processed for EWA — no historical wage data stored in EWA platform (HR SaaS holds payroll history).