As we forge our path into 2025, it can be helpful to take a moment to reflect on recent developments and also consider new, emerging trends. For this edition of Notes from the Field, we are focusing on two main topics: AI and Nacha Rules updates.  

AI is quickly integrating into payments 

Looking at the year ahead, one trend that is set to continue is artificial intelligence (AI), which is transforming almost everything around us. AI is impacting people and behavior resulting in front-end user applications and back-end processing systems as well as innovative software solutions being created. Businesses need to pay attention to these trends. Strategies for proper AI usage and implementation should be carefully crafted, focusing on benefits, efficiency and data security.  

AI's impact on financial services and payments is also being realized with modern technologies focused on capitalizing on the benefits, work use policies coming into play, and providers seeking to find ways to capitalize on the AI boom. The McKinsey Global Institute (MGI) estimates that "across the global banking sector, gen AI could add between $200 billion and $340 billion in value annually, or 2.8 to 4.7 percent of total industry revenues, largely through increased productivity.” 

Nacha Consulting predicts that the AI boom will continue well into and beyond 2025 but with notable maturity in how organizations react and adapt to the technology. This maturity cycle includes more strategic decision-making, worker usage optimization and continued streamlining of operations processes. Companies should start looking into these key areas soon.  

2025 is the year to prepare for Upcoming Nacha Rule updates 

Last year, Nacha passed a series of new rules with staggered effective dates designed to make effective changes in governance and operation. Many of these rules were designed to address and respond to the Nacha published Risk Management Framework speaking to credit-push fraud trends impacting ACH. 

Key factors of these rule changes become effective in a phased approach starting in March 2026 and ending in June 2026.  

• The first is fraud monitoring by parties involved in ACH Origination. The basics of the rule changes are that Originators, Third-Party Service Providers and Third-Party Senders, and Originating Depository Financial Institutions (ODFIs) will implement risk-based processes that are designed to reasonably identify ACH Entries that were initiated fraudulently.  

• The second is a rule change regarding ACH credit Entry monitoring by Receiving Depository Financial Institutions (RDFIs). With this rule change, risk-based processes and procedures must be designed to identify credit Entries that have been initiated due to fraud.  

Just how should industry participants go about complying with these rule requirements? Well, when thinking about fraud monitoring on the origination side, it is about ensuring that appropriate measures are taken to validate the transactions being processed and reducing potential instances of fraud attempts through established baselines used to identify atypical activity. A review of systems, onboarding practices, monitoring activity and security controls is a great starting point for identifying and addressing new rule impact.   

For RDFIs considering how to comply with credit Entry monitoring processing approaches, this is about bridging potential gaps between BSA/AML and ACH Operations and facilitating information sharing between the distinct groups. Key questions for RDFIs to ask include: What systems are already in play and what other solutions may be out there? How are transaction triggers managed and are they proactive or reactive? Should new reports be built? Are there new procedures needed?  

Taking a proactive approach in planning for rules changes is critical for success and will avoid having to rush last minute to come into compliance.  Learn more about these upcoming rules by visiting  Nacha Operating Rules - New Rules | Nacha. 

Do you need help with implementing the ACH Rules changes? Are you looking for guidance with leveraging AI in your payment operations? If so, Nacha Consulting is here to help. Stay tuned for future Notes from the Field blogs where we dive into other factors impacting and shaping payments. 

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