November 17, 2025—Credit unions must prepare now for Nacha’s sweeping ACH Network Operating Rules changes related to risk management going into effect in March and June 2026. With a two-phase rollout, these amendments demand a proactive upgrade in fraud defenses and risk-based monitoring across all ACH activity.
By implementing fraud monitoring of ACH activity, including ACH credits for RDFIs and risk-based procedures now, credit unions can not only reduce fraud, but also maintain rules compliance and examiner confidence.
These 2026 NACHA changes represent a significant step to strengthen the security and transparency of ACH transactions, requiring attention and action from all ACH Network participants well before the March and June deadlines.
What’s New for 2026?
The 2026 Nacha Operating Rules amendments include the following requirements:
- Documented, risk-based fraud monitoring programs that cover every aspect of ACH origination and receipt, expanding beyond WEB debits to all transaction types. This monitoring will help address credit-push fraud and social engineering scams—like payroll diversion and vendor impersonation—that exploit authorized ACH transfers.
- Formal annual program reviews of all monitoring processes to ensure effectiveness, which should be documented and prepared for examiner scrutiny.
- Standardized Entry Descriptions to improve transaction transparency and fraud detection.
Compliance Timeline: Act Early
The Rules changes arrive in two phases:
- Fraud Monitoring by all ODFIs and non-consumer Originators, TPSPs, and TPSs with ≥6M annual origination volume in 2023
- Monitoring of ACH credits by all RDFIs with ≥10M annual receipt volume in 2023
PHASE 2: June 19, 2026 (practical effective date of June 22 due to Juneteenth holiday):
- Fraud Monitoring extends to all remaining non-Consumer Originators, TPSPs, and TPSs
- Monitoring of ACH credits extends to all remaining RDFIs
Credit unions should begin policy and procedural updates and staff training now to meet these deadlines.
Next Steps for Credit Unions
- Assess ACH Volumes: Confirm where your 2023 origination or receipt numbers place you on the compliance timeline.
- Review Current Fraud Controls: Compare existing controls against Nacha’s risk-based requirements for the 2026 Fraud Monitoring Rule Changes. Strengthen or redesign weak links identified in gap analyses.
- Enhance Staff Training: Invest in education on fraud scenarios, including “false pretenses,” where payments are induced through identity or authority misrepresentation (e.g., business email compromise and payroll scams).
The Big Picture: Benefits and Opportunities
These Rules changes are designed to reduce ACH Network fraud, improve recovery after fraud occurs, and provide higher-quality transactions. By broadening fraud detection responsibilities to more ACH participants and making risk-based monitoring the norm, Nacha gives credit unions the opportunity to build stronger, examiner-ready fraud defenses—and to better serve and protect their members.
Final Takeaway
For credit unions, early, strategic action is essential. These amendments are not only a compliance mandate, they provide a roadmap for reducing fraud risk, fortifying institutional resilience, and demonstrating your commitment to smart, proactive ACH risk management.
As these deadlines draw near, count on EasCorp to keep you informed. Visit our blog and website for the latest news and insights. For full details on these amendments, visit the Nacha website. Please contact us with any questions.
This information is provided for educational purposes only. Please consult your legal and compliance teams for compliance, guidance and support.