Payments move money faster than ever before. Most Americans rely on Automated Clearing House (ACH) transfers for payroll direct deposits, bill payments, vendor invoices, and government benefits. But the fraudsters have adapted quickly. Scams are being designed to look like authorized payments that look legitimate at first glance.
National Automated Clearinghouse Association (NACHA), the organization that sets the rules for the entire U.S. ACH network — is updating its Operating Rules to require risk-based fraud monitoring starting in 2026. The goal is to catch suspicious activity earlier, stop losses before money disappears, and give all parties involved a better chance to recover funds.
ACH fraud has changed. Criminals use social engineering (fake emails, texts, or calls) to convince employees, vendors, or customers to send money to the “wrong” account. Once the payment posts, funds often move instantly through networks of “mule” accounts and vanish. Traditional monitoring waited until a return code appeared or a customer complained. That’s about to change.
NACHA’s new rules shift the focus to ongoing monitoring and vigilance. Every participant now shares responsibility:
Originators (companies sending payroll or payments)
ODFIs (banks that originate the transfers)
RDFIs (banks that receive the funds)
Third-party service providers
What’s the result? Fewer successful scams, quicker detection, and stronger protection for businesses and everyday people. This will reduce financial losses, protect customer trust, and meet examiner expectations more easily. In short, a safer payment system benefits everyone.
The 2025 AFP Payments Fraud and Control Survey found that 79% of organizations faced payment fraud attempts or actual losses in 2024, with tactics like business email compromise (BEC) and vendor impersonation remaining as the critical threats.The trend is on track to increase from the significant risks associated with fraudsters using generative AI to create higher quality—and therefore more effective—fraudulent emails.
The New Rules
The NACHA updates introduce a new fraud category called “False Pretenses.” This covers any situation where someone tricks another person into authorizing a payment by lying about their identity, authority, or account ownership. This does not include scams about fake goods or services.
Here’s a clear summary of the core obligations:
- Implement risk-based processes and procedures reasonably designed to identify ACH entries that might be unauthorized or made under false pretenses.
- Monitor both outgoing credits and incoming credits.
- Keep audit-ready documentation of any monitoring processes, controls, and results.
- Review and update your program at least once a year to keep up with the fraudsters.
- Add new labels for company entries: PAYROLL and PURCHASE (this helps the whole network spot patterns faster).
Phased Rollout Planned
NACHA is gradually easing institutions based on transaction volume starting on March 20, 2026 for ODFIs and non-consumer originators/third-party providers and RDFIs. Then on June 19, 2026, the new rules will be applied to all remaining non-consumer originators, providers, and RDFIs.
What Do the Compliance Requirements Look Like?
Example 1: Payroll Diversion Scam
A fraudster tricks an employee into changing their direct-deposit account number. The payroll credit posts normally. Then the money is withdrawn quickly via another transfer or debit card.
Red flags:
- A sudden change to a brand-new bank account
- Rapid movement of funds right after deposit
- Activity that doesn’t match the employee’s usual pattern
Example 2: Mule Account Networks
Stolen funds land in “mule” accounts (often opened by unsuspecting people or criminals). Money then splits and flies out to many other accounts within hours.
Red flags:
- New account receiving unexpected large credits from unrelated sources
- High outbound velocity with little normal spending
- Minimal balance left in the account
In both cases, reasonable monitoring means that teams need to review the anomaly, contact the customer using verified information on file, and document the decision.
The Bottom Line
NACHA’s 2026 fraud monitoring requirements are about modernizing protection for a payment system that millions of Americans count on every day. By moving from “wait and see” to smart, fraud monitoring strategies, banks and businesses can catch more scams early, recover more funds, and keep customer money safer.
The changes are coming soon, but institutions that prepare thoughtfully will turn compliance into a competitive advantage: stronger customer trust and lower fraud losses.
