The Nacha Operating Rules provide the framework for every ACH payment, outlining clear guidelines and defining the roles of financial institutions and Network participants. These rules ensure that millions of transactions are processed securely and efficiently each day.
As ACH payment requirements evolve, Capital Bank is here to keep you informed about key updates, so your business stays prepared for what’s next.
Below is a brief summary of recent updates to the Rules, but please note they are subject to change and should not replace the official guidelines.
RISK MANAGEMENT TOPICS - (Fraud Monitoring Phase 1) - These Rule amendments related to monitoring for fraud become effective on March 20, 2026 and are part of a larger Risk Management package intended to reduce the incidence of successful fraud attempts and improve the recovery of funds after frauds have occurred.
RISK MANAGEMENT TOPICS - Company Entry Descriptions - These two Rule amendments on Company Entry Descriptions become effective on March 20, 2026 and are part of a larger Risk Management package intended to reduce the incidence of successful fraud attempts and improve the recovery of funds after frauds have occurred.
MINOR RULES TOPICS - These changes will amend the Nacha Operating Rules to address a variety of minor issues and became effective June 21, 2024.
RISK MANAGEMENT TOPICS - These Rule amendments became effective on Oct 1, 2024 and are part of a larger Risk Management package intended to reduce the incidence of successful fraud attempts and improve the recovery of funds after frauds have occurred
The Micro-Entry Rule defines and standardizes practice and formatting of Micro-Entries, which are used by some ACH Originators as a method of account validation.
INCREASING THE SAME DAY ACH DOLLAR LIMIT
Increasing the dollar limit has been a frequently asked for change by ACH end-users. Most recently, a summer 2020 survey of corporate ACH end-users resulted in recommendations for Same Day ACH:
The dollar limit increase in March 2020 had an immediate impact on the use of Same Day ACH
SUPPLEMENTING DATA SECURITY REQUIREMENTS (PHASE 2)
In response to requests from some covered parties in 2020 for additional time to come into compliance with the Rule requirements, Nacha extended each of the two effective dates by one year; Phase 1 of the Rule, which applies to ACH Originators and Third-Parties with more than 6 million ACH payments annually, became effective on June 30, 2021, and Phase 2 of the Rule, which applies to ACH Originators and Third-Parties with more than 2 million ACH payments annually, became effective on June 30, 2022.
This effective date was affirmed in ACH Operations Bulletin #7-2020. Nacha will not enforce this rule for an additional period of one year from the effective date with respect to covered entities that are working in good faith toward compliance, but that require additional time to implement solutions. This applies to both phases of this rule. Nacha strongly encourages all such covered entities to work towards compliance as soon as possible.
This Rule will define and standardize practices and formatting of Micro-Entries, which are used by some ACH Originators as a method of account validation.
The overarching purpose of these Rules is to further clarify the roles and responsibilities of Third-Party Senders (TPS) in the ACH Network by; Addressing the existing practice of Nested Third-Party Sender relationships, and; Making explicit and clarifying the requirement that a TPS conduct a Risk Assessment. The two Rules became effective September 30, 2022, with a 6-month grace period for certain aspects of each rule.
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