Request for Comment – Increasing the Same Day ACH Dollar Limit to $10 Million
Nacha is seeking comments on raising the per-entry dollar limit for Same Day ACH. This change would increase the limit from $1 million per payment to $10 million per payment.
All ACH Network participants are encouraged to provide their comments on this proposal.
Responses on this RFC are requested by Thursday, December 18, 2025.
Please review the survey questions prior to beginning your response so that you can gather information and comments from all impacted areas of your organization before responding to the questions. You can download the materials on the left side of the page and respond online.
Please use this link to the end-user participant survey if you are employed by or responding on behalf of a small/medium business, corporate, state/local government, charitable or religious organization, or higher education institution (or enrolled student). (surveymonkey link).
Please use this link for all other respondents including financial institutions, Payments Associations and other industry associations, and organizations that offer solutions, products or services to enable or support payments as its primary line of business. (surveymonkey link).
Download materials: Presentation, Proposed Modifications to the Rules, ACH Participant survey.
Details
This proposal would continue to expand the capabilities of Same Day ACH.
Increasing the Same Day ACH dollar limit is expected to improve Same Day ACH use cases and contribute to additional adoption.
- Many specific use cases would be enhanced by increasing the dollar limit.
- Some ACH Originators may need a higher percentage of their ACH payments to be eligible for Same Day ACH in order to justify adopting Same Day ACH.
The March 18, 2022 Same Day ACH dollar limit increase from $100,000 to $1 million had an immediate impact on the use of Same Day ACH.
- From February 2022 to April 2022, the number of Same Day ACH payments increased 30% and the value of those payments increased 118%.
Technical
The proposal would increase the Same Day ACH dollar limit to $10,000,000 per payment.
The increase would apply to all Same Day ACH payments.
- ACH credits and debits.
- Consumer and business payments.
- All eligible SEC Codes (Other dollar limits for ARC, BOC, POP, RCK and XCK entries would still apply.)
Implementing the increase for both debit and credit Same Day ACH Entries would maintain the uniformity of eligibility for Same Day ACH and preserve the utility of same-day reversals (e.g., a reversing debit of an erroneous credit).
Proposed effective date: March 19, 2027.
Impact
Anticipated Benefits
Increasing the dollar limit is anticipated to enhance many Same Day ACH uses cases and contribute to ongoing adoption of Same Day ACH.
Existing use cases would be improved by making a greater percentage of an Originator’s payments eligible for Same Day ACH.
- Business-to-business payments: Businesses, government agencies and other organizations would be able to use Same Day ACH for vendor and supply chain invoices up to $10 million.
- Tax payments: Businesses and organizations could use Same Day ACH for remittance of tax payments to government agencies that are above the current $1 million limit.
- Cash concentration: Businesses and other organizations that concentrate account balances into central accounts could do so using either Same Day ACH credits or debits up to $10 million.
- Payroll funding: While payroll credits are typically not above $1 million, many payrolls are funded using an ACH debit. Using a Same Day ACH debit up to $10 million could increase liquidity and interest earning potential for an employer, or reduce credit risk for a payroll provider.
- Insurance claims: Claim payments can be in excess of $1 million and would benefit from a higher Same Day ACH limit.
- Reversals: The ACH Network offers the ability to reverse erroneous payments under a limited number of circumstances. A higher dollar limit would enable more reversals to be made on a same-day basis, including the reversal of Same Day ACH forward transactions.
A greater number of ACH payments, and especially ACH dollar volume, would be eligible for Same Day ACH.
- The annual value of new ACH dollars that would be eligible for Same Day ACH is estimated to be $7-8 trillion.
Implementing the increase for both debit and credit Same Day ACH Entries would preserve the utility of Reversing Entries and funding use cases.
All Participants
Same Day ACH would correspond to recent dollar limit increases for other account-based payment systems:
- RTP® raised the per payment limit from $1 million to $10 million in June 2025.
- FedNow® announced it will increase from $1 million to $10 million in November 2025.
Parity across relevant payments systems can increase efficiency of operations and reduce confusion for participants, particularly businesses and other organizations that use these systems.
- Consistent dollar limits across multiple payment systems can enhance resiliency.
Anticipated Impacts
All Participants:
A dollar limit increase would result in a larger amount of dollars settling at several times throughout the day – 1:00 pm; 5:00 pm, and 6:00 pm (all in ET).
All ACH participants should understand, analyze and plan for these dollar flows within their organizations.
- What are the potential impacts of higher-dollar Same Day ACH credits settling at these times?
- What are the potential impacts of higher-dollar Same Day ACH debits settling at these times?
ODFIs:
ODFIs would need to determine whether to offer higher dollar limits to Same Day ACH Originators.
- Software updates may be needed for dollar thresholds edits.
RDFIs:
RDFIs should consider implementing tools and resources to identify and prepare for potential incoming late-day large dollar payments.
- FedDetect Anomaly Notification from FedACH® Services can provide large-dollar alerts.
- FedWire is open beyond the third Same Day ACH window, so an RDFI could arrange funding to cover an incoming transaction, if necessary.
ACH Operators:
ACH Operators will need to update functional edits for an increase in the transaction limit for Same Day ACH Entries.
