As ACH volumes continue to surge, fraudsters have become more sophisticated, particularly in exploiting credit‑push payments. In response, Nacha has introduced new Risk Management Rules, with phases taking effect in March and June 2026. These Rules require all ACH participants, including Originators, ODFIs, RDFIs, Third‑Party Service Providers and Third-Party Senders, to implement risk‑based processes and procedures designed to detect and prevent fraudulent ACH activity. It is critical that every participant in the ACH transaction has appropriate controls in place to mitigate ACH payment fraud.  

Although the Rules provide flexibility for industry adoption, they also raise practical questions: What do these processes look like, and how should organizations prepare?  

Nacha Consulting has been working with clients to address these questions, and here’s a glimpse into how industry participants are adopting the new requirements through process development, documented procedures, technology, and Originator training. 

Building Risk‑Based Processes and Procedures 

Nacha’s risk management Rules intentionally avoid prescribing a single method, giving organizations room to tailor controls to their operations. At a minimum, risk‑based processes should: 

• Identify atypical payment requests, account changes, or transaction patterns. 

• Document steps for investigating suspected fraud and escalating issues internally. 

• Establish recovery procedures if fraudulent entries are initiated. 

Industry guidance emphasizes that these processes should address all applicable ACH entry types, not just WEB debits, which were historically the focus of account validation requirements to address receiving account issues.   

Many organizations are forming cross‑functional working groups (executives, finance, fraud, risk management, operations and legal) to design consistent fraud response protocols and frameworks.  

Leveraging Technology for Monitoring and Detection 

With the new Nacha Rules, monitoring should no longer be limited to reactive approaches and tools. Instead, organizations must implement procedures “reasonably intended to identify” fraudulent entries, using a proactive approach supported, as appropriate, by technology designed for scalable, faster responses. 

Particularly, financial institutions are increasingly adopting: 

• Anomaly detection tools that establish activity baselines and flag deviations. 

• ODFI and RDFI monitoring solutions, anomaly notifications, and Risk Origination Monitoring Services from providers such as the ACH Operators, which help institutions assess originator behavior and identify suspicious credits.  

• Business analytics reports and alerts that support transaction identification and flagging.   

Strengthening Originator Training and Expectations 

Even the best technology cannot prevent fraud if Originators are unaware of their expanded responsibilities. We have worked with institutions developing training programs covering topics such as: 

• Recognizing social engineering tactics that lead to authorized‑fraud scenarios. 

• Verifying account change requests through independent channels. 

• Understanding obligations to maintain risk‑based processes and document their adherence. 

Because the Nacha Rules apply to all corporate end users, regardless of size, education is critical. Many organizations are incorporating ACH fraud training into annual compliance refreshers or building dedicated modules for staff involved in treasury payment processing functions.   

The 2026 Nacha Risk Management Rules mark a significant shift toward all parties playing a role in recognizing fraud. It’s not just about compliance; it's about risk management, and organizations that proactively build adaptable processes, adopt technology‑driven monitoring and invest in Originator training will be able to meet Nacha requirements and materially reduce their exposure to today’s fast‑moving ACH fraud threats. 

Does your organization need help navigating and preparing for the new Nacha Rules? Nacha Consulting has a proven track record of working with clients to ensure operational readiness and compliance with Nacha Rules, establish robust risk management frameworks and provide alignment with industry best practices.  

Click here to set up a free 15-minute consultation and learn more about how Nacha Consulting can help guide your organization to meet your Nacha Rules requirements through well-managed risk-based processes.