New expectations are not just about fraud monitoring, they are a wakeup call for credit union leadership to evaluate their entire ACH program including policies procedures, monitoring, and oversight.
As digital payments continue to expand so does the risk of fraud across the ACH network. In response, NACHA introduced a series of 2026 rule amendments focused on strengthening fraud monitoring particularly for ACH credit transactions.
While much of the conversation has focused on fraud detection, the broader implication for credit unions is more significant. These changes highlight the need to reassess the overall effectiveness of ACH programs, including governance policies and procedures.
March was the signal, June is the expectation
The first phase of NACHA rule changes took effect on March 20, 2026. This phase required certain participants, such as ODFIs large Originators and larger RDFIs, to begin implementing risk-based monitoring processes designed to identify fraudulent ACH credit activity.
For many credit unions, March served as a signal that ACH fraud risk is increasing, monitoring expectations are evolving, and existing controls may no longer be sufficient.
However, the June 22, 2026 phase expands those expectations across the broader network. Beginning in June, all applicable participants including smaller credit unions are expected to have monitoring processes in place.
Beyond monitoring: A broader look at your ACH program
While the rule centers on fraud monitoring, it indirectly raises a more important question: Is your ACH program designed to support effective risk management?
Many credit unions have historically viewed ACH as an operational function rather than a risk-driven program. As a result, policies and procedures may be outdated at an overly high level or not reflective of newer services.
Key areas credit unions should reassess
- ACH policies should define roles, responsibilities, and reflect current services.
- Procedures and controls should be clearly documented, consistently followed, and include escalation and business continuity steps.
- Monitoring practices should clearly define what is reviewed, how often, and what happens when issues are identified.
- Products and delivery channels should reflect current risks including online transfers and third-party services.
What NACHA actually requires
NACHA does not require a specific system or vendor but does require credit unions to implement risk‑based processes and procedures designed to identify potentially fraudulent ACH credit transactions. For smaller institutions, manual monitoring remains acceptable as long as it is intentional, repeatable, and well documented. Automation can support these efforts by helping standardize monitoring practices, improve documentation, and detect patterns that may be more difficult to identify manually.
These expectations are intended to reduce fraud, improve detection, increase recovery of funds, and promote more consistent monitoring practices across the ACH network. As June approaches, credit unions should review their ACH policies, evaluate procedures, document monitoring processes, train staff, and identify any gaps that need to be addressed.
Final thoughts
As ACH fraud risks continue to evolve, credit unions are being pushed to move beyond passive awareness and toward active, structured management of ACH risk. NACHA’s 2026 rule changes reinforce that effective risk management is not defined by the tools an institution uses, but by the clarity, consistency, and documentation behind its processes. Credit unions should expect to demonstrate not only that monitoring exists, but that it is intentional, appropriately scaled, and supported by governance, policies, procedures, and staff understanding.
While approaches may differ based on size and complexity, the expectation remains the same. Credit union leadership should be able to articulate how ACH credit risk is identified, monitored, and addressed in practice. With the June deadline approaching, now is the time to assess whether your ACH program can clearly and confidently stand up to that scrutiny.
