Stay Ahead of ACH Fraud: Preparing for New Monitoring Rules

Starting in March 2026, Nacha is introducing new fraud monitoring requirements that will impact originators, third-party service providers (TPSPs), third-party senders (TPSs), and ODFIs with high ACH origination volumes. As a treasury management or cash management professional, understanding these changes early will help your business stay compliant.

What’s changing?

• Phase 1 (Effective March 20, 2026): Applies to ODFIs and non-consumer originators, TPSPs, and TPSs with six million or more ACH originations in 2023.
• Phase 2 (Effective June 19, 2026): Expands to all remaining non-consumer originators, TPSPs, and TPSs.

What’s required?

• Entities must establish risk-based processes and procedures to identify ACH entries initiated due to fraud.
• Processes should be tailored to the entity’s role in the ACH network and reviewed annually.
• ODFIs can consider fraud monitoring steps already implemented by other participants (e.g., originators and TPSPs) when designing their own procedures.

Fraud scenarios to address

The rules highlight false pretenses, including fraud involving:

• Business email compromise (BEC)
• Vendor impersonation
• Payroll impersonation
• Account takeover schemes

These scenarios focus on payments induced by misrepresentation but don’t cover scams involving fake goods or services.

How should you prepare?

1. Evaluate current processes: If your business already monitors fraud in WEB debits or micro-entries, you may be ahead of the curve. However, you should assess whether your current systems can handle expanded fraud detection responsibilities for other transaction types.
2. Collaborate with us: We may reach out to discuss compliance requirements or request proof of your fraud monitoring procedures. Be proactive in asking questions and seeking guidance to ensure your systems align with the new rules.
3. Begin planning now: The effective date may seem far off, but preparing early can help avoid last-minute compliance challenges.
4. Stay informed: These rules are part of a broader initiative to reduce fraud and improve ACH transaction quality. We’ll continue to provide information on additional rules changes or clarifications.

Anticipated benefits

• Enhanced fraud prevention: Expanding monitoring responsibilities across more ACH participants improves detection of fraudulent activity, especially in credit-push payments.
• Improved transaction quality: Risk-based monitoring reduces fraud attempts, leading to a cleaner ACH network and better outcomes for all participants.