NACHA ACH Rule Updates
ACH payment requirements continue to evolve. Your INB Treasury Management partner can help you learn about key changes to ACH payments so you can be prepared for what’s next.
Here you’ll also find high-level information and guidance on the responsibilities of ACH Third-Party Senders under the NACHA Operating Rules.
Our Treasury support team is available to answer your questions about ACH rules. Contact us at 217-747-8636 or by email at INBTreasuryServices@inb.com.
2026 ACH Rule Changes
Company Entry Descriptions
Effective March 20, 2026
These rule changes establish requirements for the content of the Entry Description field for specific types of transactions. These changes are part of a comprehensive approach to reduce fraud risks in the ACH network.
- PPD credits for the payment of wages, salaries, and similar compensation must use the value of PAYROLL in the Entry Description field for a batch containing those transactions.
- WEB debits for the online purchases of goods, including recurring purchases first authorized online, must use the value of PURCHASE in the Entry Description field for a batch containing those transactions.
- These are “no later than” dates, Originators may begin using the descriptions as soon as practical.
Visit NACHA for company entry description details
Risk Management Fraud Monitoring Phase 1
Effective March 20, 2026
These rules changes will be implemented in two phases and are part of a comprehensive approach to reduce fraud risks in the ACH network to improve the chances of recovery when fraud has occurred. They require certain ACH participants to establish and implement risk-based processes and procedures reasonably intended to identify ACH Entries initiated due to fraud.
- Phase 1 applies to all originators, third-party senders, and third-party service providers that originated more than 6 million ACH transactions in 2023.
- Phase 1 also applies to all banks that received over 10 million ACH transactions in 2023.
Visit NACHA for Phase 1 details
Risk Management Fraud Monitoring Phase 2
Effective June 22, 2026
These rules changes will be implemented in two phases and are part of a comprehensive approach to reduce fraud risks in the ACH network to improve the chances of recovery when fraud has occurred. They require certain ACH participants to establish and implement risk-based processes and procedures reasonably intended to identify ACH Entries initiated due to fraud.
- Phase 2 applies to all originators, third party senders, and third-party service providers that did not meet the threshold for Phase 1, as well as all banks that receive ACH transactions that did not meet the threshold for Phase 1 (effective March 20, 2026).
Visit NACHA for Phase 2 details
Funds Availability Requirements for Non-Same Day ACH Credit Entries
Effective September 18, 2026
This requires the receiving bank (RDFI) to make funds available for non-Same Day ACH items by 9:00 AM (local time for the RDFI).
Visit NACHA for Funds Availability rule change
Definition of International ACH Entries (IAT)
Effective September 18, 2026
The definition of IAT entries is being updated to allow originators to make an easier determination if an item needs to be sent using the IAT Standard Entry Class Code and format. IAT transactions carry 7 mandatory addenda records with additional information regarding the sender and receiver of the IAT transaction.
Visit NACHA for IAT rule change
2027 ACH Rule Changes
Registration of IAT Contacts in the ACH Contact Registry
Effective January 1, 2027
This Rule will require a Participating DFI to register their IAT-handling contact with either:
- The name, title, email address, and phone number for at least one primary and one secondary contact person for the area of responsibility; or
- Department contact information that includes an email address and a working telephone number.
Phone numbers and email addresses must be those that are monitored and answered during normal business hours for financial institution inquiries.
Visit NACHA for Registration of IAT Contacts in the ACH Contact Registry
International ACH Transactions (IAT)
Effective March 19, 2027
This rule change comprises two amendments:
- Optional Date of Birth Field for IAT Entries: This rule will designate an optional field for the known Date of Birth (DoB) of a natural person sender and/or receiver of an IAT Entry.
- Non-Bank Foreign Financial Agencies in IAT Entries: This rule expands several field descriptions that identify the Originating and Receiving DFIs in an IAT Entry to recognize the possibility that the financial agency outside the U.S. is a non-traditional account-holding institution or organization.
Visit NACHA for International ACH Transactions
2028 ACH Rule Changes
New Reason Return Code for Sanctions Compliance Obligations
Effective March 17, 2028
Currently, Return Reason Code R16 is defined for use as “Account Frozen/Entry Returned Per OFAC Instruction.”
The meanings of these two reasons are only linked at the highest level because they may deal with potential legal actions. This rule will create a new return reason code (R90) to support an RDFI’s decision to return an entry in compliance with sanctions obligations.
R16 will revert to its original title “Account Frozen” and be described as “Access to the account is restricted due to specific action taken by the RDFI or by legal action.”
R90 (Entry Returned Due to RDFI’s Sanctions Compliance Obligations) will be added to the return reason code table.
Note: This rule change adds a new Reason Return Code (R90) and changes the title for another (R16). These changes could require changes in your back-office systems, processes and procedures.
Visit NACHA for New Reason Return Code for Sanctions Compliance Obligations
NACHA-Approved Authorization Forms
INB ACH Originators can access NACHA-approved authorization forms below for use in initiating ACH transactions. These forms are designed to help ensure compliance with NACHA rules and support secure, efficient payment processing.
Please download and use the appropriate form(s) as needed.
Corporate ACH Credit-Debit Authorization
Consumer ACH Debit Authorization
Consumer ACH Credit Authorization
ACH Third-Party Sender Reference Guide
The guidance below provides high-level information on the responsibilities of ACH Third-Party Senders under the NACHA Operating Rules and does not provide legal advice. Please consult with your internal risk and legal resources for guidance to fully comply with the responsibilities and requirements of a Third-Party Sender.
About ACH Third-Party Senders
ACH Third-Party Senders:
- Initiate ACH transactions on behalf of an originator or another Third-Party Sender when there is not an origination agreement directly between the originator and the Originating Depository Financial Institution (ODFI).
- Have many of the same responsibilities as an Originating Depository Financial Institution (ODFI) under the NACHA Operating Rules and Guidelines (NACHA Rules).
Your agreement with U.S. Bank allows us to conduct a review to ensure your compliance with the NACHA Rules. Non-compliance could result in a termination of service.
Resources for ACH Third-Party Senders
As an ACH Third-Party Sender, you have specific responsibilities and requirements under the NACHA Operating Rules. We’ve consolidated information and resources to assist with your fulfillment of these requirements.
NACHA video: What is a Third-Party Sender?
NACHA'S explanation of Third-Party Sender roles and responsibilities
NACHA'S Third-Party Sender identification tool
ACH Third-Party Senders:
- Initiate ACH transactions on behalf of an originator or another Third-Party Sender when there is not an origination agreement directly between the originator and the Originating Depository Financial Institution (ODFI).
- Have many of the same responsibilities as an Originating Depository Financial Institution (ODFI) under the Nacha Operating Rules and Guidelines (NACHA Rules).
Your agreement with INB allows us to conduct a review to ensure your compliance with the NACHA Rules. Non-compliance could result in a termination of service.
NACHA Operating Rules
The NACHA rules govern the proper use of the ACH network and a new rule book is published each January. For those of you that use our ACH service, you have agreed to comply with all applicable ACH rules in the creation and transmission of ACH transaction files.
To gain free access to the rule book, please register on the NACHA website as a basic user at https://www.nachaoperatingrulesonline.org/login and follow the steps below. Note: Logins from previous years (2024 and earlier) are no longer valid.
- Click on “Create a New Account” to register and create a new account.
- Enter your email address two times and click continue:
- Complete the online form. Be sure to click the box next to Check this box if you do not have a Subscription Code. You will receive access to only the Basic Access.
- Click the box next to I agree to the Terms of Use.
- Click the REDEEM button.
- You will receive this message.
- Click the CLICK HERE TO LOG IN button.
- The email from digital@omnipress.com will contain a link to access the NACHA Operating Rules website. If you have previously set up your login to the NACHA Operating Rules, your digital@omnipress.com email will advise you to use your current password. If this is your first time enrolling, follow the instructions in step 3 of the email to set up your password.
- Enter your email and password and click Login.
- If you’ve forgotten your password, click Forgot Password? below the login box and follow the onscreen prompts.
- From the next screen, click on RESOURCES at the top of the page to access the Basic Edition of the NACHA Operating Rules.
- Full versions of the current year’s NACHA Operating Rules & Guidelines are available for purchase. Click on the green highlighted link shown on the landing page above.