The Road to 2026: Preparing for New Rules and New Opportunities

Published on December 9, 2025

AUTHOR

Eric Wester, AAP, AFPP, APRP, NCP
Director of Member Services

As we look ahead to 2026, payments professionals across the industry are preparing for a year marked by significant change, continued innovation, and a renewed focus on operational readiness. While the ACH Network is far from the newest payment rail, the Nacha Operating Rules continue to evolve in meaningful ways to meet today’s payment needs. Several upcoming rule changes remain top of mind as financial institutions assess how to update their processes, procedures, and technologies to remain compliant.

New Fraud Monitoring Requirements
One major area of focus is Nacha’s new fraud monitoring rules. These requirements impact most ACH Network participants, both on the origination side of transactions and for RDFIs receiving ACH credits. The rules have a phased implementation, with different compliance deadlines based on participant transaction volume.

The new rules require Non-Consumer Originators, Third-Party Service Providers, Third-Party Senders, and ODFIs to:

a) “Establish and implement risk-based processes and procedures, relevant to the role it plays in the authorization or Transmission of Entries, that are reasonably intended to identify Entries that are suspected of being unauthorized or authorized under False Pretenses; and

b) at least annually review these processes and procedures and make appropriate updates to address evolving risks.”

Non-Consumer Originators, Third-Party Service Providers, and Third-Party Senders with ACH origination volume of 6 million or more Entries in calendar year 2023, as well as all ODFIs, must be compliant no later than March 20, 2026, while those with lower volume have until June 19, 2026, to be compliant.

The new rules require RDFIs to:

a) “Establish and implement risk-based processes and procedures, relevant to the role the RDFI plays in connection with the receipt of credit Entries, that are reasonably intended to identify credit Entries that are suspected of being unauthorized or authorized under False Pretenses, including processes and procedures for responding when credit Entries are identified as potentially unauthorized or authorized under False Pretenses; and

b) at least annually review these processes and procedures and make appropriate updates to address evolving risks.”

RDFIs with annual ACH receipt volume of 10 million or greater Entries in calendar year 2023 must be compliant no later than March 20, 2026, while those with lower volume have until June 19, 2026, to be compliant.

Interested in learning more about Nacha’s upcoming fraud monitoring rules?

UMACHA recently hosted webinars on RDFI ACH Credit Monitoring and ACH Origination Fraud Monitoring that dive into what financial institutions need to know.

If you want to stay ahead of these changes and better understand their impact, consider purchasing these sessions from our on-demand library where you can get an immediate download.

Mandatory Company Entry Descriptions
Another noteworthy change is the introduction of mandatory Company Entry Descriptions for specific transaction types:

PAYROLL: Credits for the payment of wages, salaries, or similar compensation must include the word PAYROLL within the first seven positions of the Company Entry Description field.
PURCHASE: Debits authorized by a consumer Receiver for online purchases of goods (including recurring purchases first authorized online) must include the word PURCHASE in the first eight positions of the Company Entry Description field.

While these updates may seem straightforward, they carry operational impacts that require attention across treasury, operations, and compliance teams.

Accelerated Funds Availability
Amid the attention on these near-term rule changes, it is important not to overlook another key update taking effect on September 18, 2026. The rule change will eliminate the 5:00 p.m. local time receipt condition when determining funds availability requirements for non-Same Day ACH credits.

No later than September 18, 2026, funds availability for all non–Same Day ACH credits will be required by 9:00 a.m. in the RDFI’s local time on Settlement Date. This acceleration could have operational implications that institutions should begin planning for now to ensure readiness.

The Growing Role of Instant Payments
Instant payments also remain an essential part of the conversation as adoption continues to mature. Both FedNow and the RTP Network are seeing sustained growth, although sending activity is still developing across much of the industry.

FedNow: In Q3 2025, more than 2.5 million payments totaling over $307 billion were settled, representing quarterly growth of 17.6% in volume and 25.0% in value. More than 1,500 financial institutions now participate in the FedNow Service, either in a receive-only or a send-and-receive capacity.
RTP Network: Operating at a larger scale, RTP is averaging 1+ million payments daily and more than $4 billion settled per day. More than 1,000 financial institutions now participate in the RTP Network, either in a receive-only or a send-and-receive capacity.

Many financial institutions are actively evaluating or refining their instant payment strategies, considering how enabling send capabilities may offer a strategic advantage in an increasingly competitive market.

Industry Milestone: ISO 20022 Migration
Amid all the changes and planning, it is important to celebrate industry achievements. On July 14, 2025, Federal Reserve Financial Services (FRFS), together with financial institutions nationwide, successfully implemented the ISO 20022 message format for the Fedwire Funds Service in a single-day migration.

This milestone not only standardizes messaging across systems but also enhances the richness of data available to customers and increases opportunities for innovation.

The industry’s broad embrace of ISO 20022 is a remarkable representation of how collaborative efforts can advance payments.

Looking Ahead
As we move toward 2026, the payments landscape continues to evolve quickly. With new rule changes, the growing influence of instant payments, and major modernization milestones, there is much for payments professionals to plan for and be proud of. UMACHA will continue to support our members as they navigate these developments and prepare for the future. Remember, you can contact us at info@umacha.org or by phone at (800) 348-3692 any time you need support – it’s all part of your member benefits!

Stay connected with Eric Wester and UMACHA on LinkedIn!