Maryland enacted S.B. 261, which amends the Maryland Money Transmission Act to exclude certain agents of a payor providing payroll processing services from the definition of money transmitter. The measure was enacted in 2026 and is scheduled to take effect October 1, 2026.
What changed
The law creates a narrower exclusion from money transmitter coverage for a defined category of payroll processing activity.
Compliance perspective
Payroll processors and firms that rely on agent structures in Maryland should test whether their model fits the new exclusion before assuming licensing is no longer required. Existing licensees should also watch for implementing interpretation and update state surveys before the October effective date.
Key date
Effective date: October 1, 2026.
Need help keeping up with these changes?
Tell us where you operate and what licenses you hold; we'll handle the filings and renewals so changes like this do not catch you off guard.