This year Nacha is implementing the following fraud monitoring rules in two phases: 

• Subsection 2.2.4 Identification of Unauthorized Entries or Entries Authorized Under False Pretenses
• Subsection 3.1.10 Identification of Unauthorized Credit Entries or Credit Entries Authorized Under False Pretenses

The implementation date for Phase 1 is March 20, 2026, for:

• ODFIs 
• Originators, Third-Party Service Providers, and Third-Party Senders with volumes of 6 million items or more in 2023 
• RDFIs with volumes of 10 million items or more in 2023

The implementation date for Phase 2 is June 22, 2026, for everyone else not included in Phase 1.

Download our guidance document from the Fraud Forum to better understand the responsibilities of each participant under these rules and best practices for implementation of the changes (Fraud Forum login required).

Listen to these podcast episodes to learn more:

• Episode 35: What You Need To Know About 2026 Fraud Monitoring Rules with Krystle Bucci, Manager, Payments Education
• Episode 27: Fighting Fraud With the ACH Rules, Part 2 with Stephanie Hottle, Director, Payments Education
• Episode 26: Fighting Fraud With the ACH Rules, Part 1 with Stephanie Hottle, Director, Payments Education

Part of your compliance plan should be conducting an annual risk assessment to review the risk-based processes and procedures that must be established and implemented under these rule changes. Request a proposal from ePayAdvisors and get your 2026 risk assessment scheduled.

Questions? Call the ePayResources Payments Answerline™ at 800-475-0585, Option 1, and our certified experts can help you!