With New Rules Next Year, Originators Need to Get Ready Now

With less than a year to go before new Nacha Rules take effect in March 2026, the time is now for financial institutions to be talking to their Originators about making sure they’re compliant on day one—or, even better, well in advance. One of the nation’s largest banks came to Nacha’s Smarter Faster Payments Remote Connect 2025 to share some of what it’s doing to make that happen. It starts with the knowledge that one size does not fit all.
“We recognize there are differences in rules knowledge, so we target our communications specifically to the type of entity and how they use ACH,” said Beth Anne Hastings, Senior Vice President, Treasury Management, PNC Bank.
Clients using PNC’s payment portal find “a message on the main sign-in page about the upcoming ACH Rule changes, and they need to pay attention,” Hastings told the session “Get Your Originators Compliant—and Keep Them That Way.”
PNC is going a step further by refining the messages by use case. For example, one Rule change establishes a new standard description for PPD Credits for paying wages, with a requirement that the Company Entry Description field contain the description PAYROLL.
“If the client is using a template to do payroll, we’re looking at the contents of the template they created,” said Hastings. If the bank finds what looks like PPD credits to consumers for wages, the client gets an additional alert message when they go into that template function reminding them that the template contents may need updating.
In many cases, making changes requires the involvement of multiple departments at an Originator. Hastings said PNC has that covered by ensuring its communications provide enough information for their client contact to be able to share that information readily with their technology resources, with their payroll administrator or with their ERP systems lead. PNC is also offering to test files for clients.
Brian Sweeney, Business Program Manager at Paychex, a large ACH Originator, said staying on top of Nacha Rules changes is crucial. Paychex does that in several ways.
“We always attend the Nacha quarterly reviews,” said Sweeney. “Those are very helpful for us.”
“All of our bank partners do a great job giving us information. We do have quarterly discussions with each bank partner and the Rules are always a section that we go over,” said Sweeney. Paychex also works with the Wespay, Epcor and The Clearing House Payments Associations to stay updated.
Rebecca Wagner, Senior Compliance Analyst at Paychex, said whenever Nacha issues a Request for Comment, Paychex is sure to answer, and she encouraged other Originators to participate as Nacha definitely reviews the feedback.
“Ensure you’re engaged, whether you fill out the request yourself, or go to your Payments Association and provide feedback, ‘This is going to work, it’s great; this is not going to work, this needs to be pushed out a little more,’” said Wagner. “Sometimes we respond, ‘This is OK, but we can’t do it for another year.’”
Along with PAYROLL another Company Entry Description coming next year is PURCHASE. Debbie Barr, Nacha Associate Managing Director, ACH Network Rules, noted the Rule covering these is effective March 20, 2026, but that’s a “no later than” date—as in there’s no need to wait.
“The sooner you can put it in,” said Barr, “the better.”