Nacha’s 2026 fraud rule updates represent one of the most significant shifts in ACH oversight in recent years, introducing a formal “risk-based” monitoring requirement across the network.
The long-standing “commercially reasonable” benchmark will be replaced with a more prescriptive expectation that financial institutions (FIs) allocate fraud controls according to their specific risk profiles.
The move comes against a backdrop of billions lost each year to ACH-related fraud and mounting regulatory pressure to address authorised scams more effectively.
Hawk AI, which helps FIs and regulated entities with their AML, screening, fraud and FinCime process, recently explored how to assess if fraud prevention systems are fit for purpose.
The rationale for reform is clear. Existing Nacha rules were developed in an era dominated by pull-based transactions, with a strong focus on preventing unauthorised debit activity and managing return rate thresholds.
While these measures addressed certain forms of fraud, they offered limited protection against credit-based scams, where funds are pushed out of accounts. Modern schemes such as Business Email Compromise (BEC) and payroll diversion have exploited this gap.
In many cases, victims technically authorise payments themselves, having been misled about the legitimacy of the recipient, Hawk said.
The 2026 rollout will occur in two phases. From 20 March 2026, fraud monitoring requirements will apply to all ODFIs, as well as non-consumer originators, TPSPs and TPSs with annual ACH origination volumes of 6 million or more in 2023. Incoming credit fraud monitoring will also apply to RDFIs with annual receipt volumes of 10 million or more.
From 19 June 2026, the scope expands to cover all remaining non-consumer originators, TPSPs and TPSs not included in Phase 1, alongside all other RDFIs.
Not everything is changing, Hawk said. Originators must continue to deploy fraudulent transaction detection systems for WEB debits and Micro-Entries, and account validation obligations remain in place prior to first use or when account details are updated.
However, the regulatory net is widening. Responsibility will extend across the payment chain, and the new risk-based standard replaces ambiguity with a clear requirement for structured monitoring processes. The framework also formally incorporates “false pretences” as a defined category, bringing socially engineered scams explicitly within scope. In addition, participants must conduct an annual formal review of their fraud monitoring procedures, and originators must adopt standardised Company Entry Descriptions such as “PAYROLL” and “PURCHASE” to enhance transparency.
The introduction of “false pretences” is particularly significant. It covers scenarios where identity, authority or account details are misrepresented, including criminals posing as banks or government bodies, fraudulent HR communications prompting account changes, and vendor impersonation schemes.
Institutions must demonstrate that their fraud controls are proportionate to their risk exposure and supported by auditable evidence.
Hawk positions its platform as aligned with Nacha’s updated framework, offering AI-powered fraud monitoring across account takeover (ATO), unauthorised debits, authorised push payment (APP) scams and mule network activity.
By analysing behavioural patterns and transaction anomalies in real time, the system aims to prevent unauthorised transactions at the point of initiation while also identifying socially engineered payments that diverge from established customer profiles.
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