On Monday, Nov. 10, Nacha announced it is seeking public comments on the proposed change to the Nacha Operating Rules that would increase the per-transaction dollar limit for Same Day ACH payments from $1 million to $10 million. Corporate end users are often the ultimate decision-makers when it comes to the method of making payments, and their feedback is critical for ensuring the ACH Network meets their payment needs. 

The request for comment invites input from all corporate end users that use the ACH Network, including businesses and nonprofits, banks and credit unions of all sizes, government agencies, third parties, payment processors, fintechs and solution providers. 

Same Day ACH payments are ACH transactions that are settled, and funds are available within the same business day, if sent to the designated financial institution during the three allotted time frames. Same Day ACH was implemented in 2016 for credits, and in 2017, debits were added. Since the initial Same Day ACH implementation, there have been continued enhancements that have expanded the use cases and volume of Same Day ACH transactions. 

Although most ACH transactions are valued at $1 million or less, the existing cap limits users from fully realizing Same Day ACH use for high-value payments, such as business-to-business payments, insurance claims, tax claims, payroll funding, disbursements, cash concentration, or as a part of business continuity and resiliency planning.  

The request for comment period provides an opportunity for all users in the ACH Network to advocate for themselves as part of the rules development process for the Nacha Operating Rules. The deadline for responses is Dec. 18, 2025. 

Potential Considerations:  

• Would the increase in the same-day transaction type assist in the organization's day-to-day payment needs? 

• How would increasing the Same Day ACH transaction limit to $10 million affect the organization operationally? Would this change have an effect on the organization’s liquidity position? 

• Would the organization be able to realize new use cases, or expand current use cases, with the option to have $10 million Same Day ACH transaction limit? 

• Will an increase to a $10 million Same Day ACH transaction limit assist with current client demands or winning new client business? 

• Nacha encourages all participants to respond, including corporate end users, to fully understand the impact and potential benefits. An increase within the Same Day ACH limit advances Nacha’s overall mission to ensure the ACH Network continues to serve all participants that utilize the ACH Network as part of their payment operations.  

Potential Action Items:  

• Discuss the proposal internally to decide how this dollar increase may or may not affect the business.  

• Internal groups may include departments, including the following functions: Accounting/Finance, Treasury, Risk, Fraud, Liquidity, and Operations. 

• If the organization is not familiar with the relevant financial institution’s Same Day ACH product offering, an external conversation with the financial institution's contact is recommended. 

• Assign a designated internal group or individual to complete the Nacha RFC Survey (LINK HERE).  

All Nacha proposed rules are open for public comment via a Request for Comment. Nacha encourages responses from ACH Network participants and interested parties.   

All survey responses and comments are anonymized before being tabulated and reviewed. 

Terms to know: 

Same Day ACH: ACH transactions, when sent within the three designated Same Day ACH windows, settle within the same business day. The transaction funds must be made available during the same business day. Funds availability requirements are based on the timing of when the transaction is sent during the business day. Please discuss with your financial institution to learn about their designated Same Day ACH product offerings.  

Financial Institution: The bank, bankers’ bank, community bank, credit union, or corporate credit union, that a corporate end user utilizes for monetary transmission such as ACH transactions, wire transfers, check image, and instant rail payments.   

Nacha: The national ACH association that develops rules and governs the ACH Network.   

If your organization has additional questions relevant to this Same Day ACH transaction limit increase for Nacha please contact: [email protected].