Nacha Operating Rules Changes for 2026

Each participant in the ACH Network is required to follow the Nacha Operating Rules and be compliant, even when it pertains to Risk.

Effective March 20, 2026 – Phase 1 for Risk Management (part of a larger package) to help reduce the incidence of successful fraud attempts and improve recovery of funds:

• Fraud Monitoring by Originators, Third-Party Service Providers/Third Party Senders and ODFIs; and
• ACH Credit Monitoring by RDFIs
  
  

Effective March 20, 2026 – Standardization of Company Entry Descriptions (also part of Risk Management):

• Standardizing the use of Company Entry Description can help participants in the ACH Network, to identify, monitor, and count the volume of payments for specific purposes; (thus helping to manage ACH Risk)
• The two newly defined Company Entry Descriptions PAYROLL and PURCHASE
   

PLUS -- Effective on June 19, 2026 – Phase 2 for Risk Management is a continued part of a larger Risk Management package (Rules Changes) to help reduce the incidence of successful fraud attempts and improve the recovery of funds. Included in this portion of Risk Management Rule amendments are:

• Fraud Monitoring by Originators, Third-Party Service Providers/Third Party Senders, and ODFIs (for all non-Consumer Originators, TPSPs, and TPSs that did not fall under the requirement threshold for Phase 1); and
• ACH Credit Monitoring by RDFIs (for all RDFIs that did not meet the threshold requirement for Phase 1).

Effective March 20, 2026, two Rule amendments (Fraud Monitoring – Phase 1) – monitoring for Faud (as part of a larger Risk Management package) intended to reduce the incidence of successful fraud attempts and improve the recovery of funds after frauds have occurred. Plus, two additional Rule amendments on Company Entry Descriptions (also part of Risk Management-relating to Fraud) become effective on March 20, 2026, and are also part of a larger Risk Management package. Effective June 19, 2026, two additional Rule amendments (Fraud Monitoring Part 2), also related to monitoring for fraud become effective on June 19, 2026, (as part of a larger Risk Management package) intended again to help reduce the incidence of successful fraud attempts and improve the recovery of funds after frauds have occurred.

To remain in compliance with the Rules, participants in the ACH network need to ensure they are up to date on recent changes and newly approved amendments to the Rules. The Risk Management topics will improve recovery of funds in fraud situations (after the fraud has occurred), there are two phases – Phase 1 outlines everything as part of the Risk management package including the threshold for the first group of participants that need to comply. Phase 2 outlines the participants who did not meet the first threshold – and their obligation to meet these Risk Management Rule amendments. These are a NEED to KNOW! Your ACH Risk process is changing for BOTH the ODFI and RDFI! Register Today to ensure YOUR compliance with the NEWEST UPCOMING (2026) updates to the Nacha Operating Rules!!

Fraud Monitoring – for ODFI, Originators, TPSP, and TPS PLUS Credit Monitoring – for RDFI (Phase 1)

• Describe which participant is affected and what parts of the Rule apply to whom and outline the threshold limits for each.
• Define what’s changing with a “commercially reasonable fraud detection system.”
• Provide details on the next level description of requirements – i.e., “reasonably intended to identify…” (including the requirements that apply “to the extent relevant to the role the entity plays.”)
• Outline how the Rule allows an ODFI to expressly consider steps other participants in origination are taking to monitor for fraud
• List other parts of the Rule relating to monitoring.
• Identify the requirement of an “at least annual” review of processes and procedures.

Standardization of Company Entry Descriptions

• Describe “when” to use the NEW “PAYROLL” and “PURCHASE” as the NEW Company Entry Descriptions
• Identify the IMPACTS and BENEFITS of the participants involved in this change to formatting.

Fraud Monitoring – by Originators, TPSP, and TPS PLUS Credit Monitoring – for RDFI (Phase 2)

• Define which participants are affected and what parts of the Rule apply to whom (the parties who didn’t meet the first threshold)

Examples used throughout the presentation will help identify the “meaning” of these new Nacha Operating Rule amendments.

The Nacha Operating Rules changes are crucial for ensuring compliance, enhancing payment security, and improving the efficiency of ACH transactions. These updates address evolving risks, incorporate technological advancements, and set new standards for fraud prevention and data protection. Understanding these changes is essential for financial institutions, businesses, and payment processors to maintain seamless operations, avoid penalties, and deliver a secure, efficient payment experience.