Navigating Nacha's 2026 Rule Changes: How Q2 Can Help

In an effort to reduce fraud, Nacha is tightening the rules in 2026 for ACH transactions, especially credit-push scams in which criminals trick legitimate account holders into authorizing payments under false pretenses.

These new requirements represent one of the most significant fraud prevention shifts in recent years. They will impact businesses, payment processers and financial institutions. 

Q2 is uniquely positioned to help financial institutions prepare, with a multi-layered fraud prevention strategy that combines monitoring, anomaly detection, reporting, and identity verification.

What the 2026 rules require

In March 2026, Nacha will begin phasing in new fraud monitoring expectations for ACH participants. The intent is to strengthen the industry’s ability to detect and respond to suspicious or deceptive activity earlier in the payment lifecycle.

These updates do not require every ACH transaction to be monitored individually or mandate the use of any specific technology. Instead, Nacha expects participants to implement documented, risk-based processes that reflect their size, transaction volume, and risk exposure.

Here’s how that applies across the ACH network:

• Origination depository financial institutions (ODFIs) and originators/third-party senders (TPSs)/third-party service providers (TPSPs) should establish processes to identify and respond to unusual or potentially fraudulent activity, such as first-time receivers, abnormal transaction amounts, or unexpected patterns.
• Receiving depository financial institutions (RDFIs) should maintain policies and procedures to identify and escalate potentially unauthorized or suspicious entries based on risk.
• All participants should regularly review and update their monitoring programs to ensure they remain effective and aligned with evolving fraud trends.
  Nacha’s goal is to move from reactive fraud handling to a proactive, risk-based approach. It’s an effort to improve fraud visibility without imposing one-size-fits-all technology mandates.

Understanding “false pretenses” and emerging fraud types

One of the most notable updates in Nacha’s 2026 rules is the expanded definition of fraud, which now include payments made under false pretenses. These are situations in which a legitimate sender is deceived into authorizing a transaction.

Examples of false pretenses include:

• Business Email Compromise (BEC): When a fraudster impersonates a trusted vendor, partner, or executive to divert payments
• Vendor or payroll redirection scams: When fraudulent actors convince organizations to change payment instructions

These examples illustrate Nacha’s broadened view of fraud risk, but they are not new rule categories or separate compliance mandates. Institutions are expected to incorporate these risk types into their broader fraud management programs through documented, risk-based procedures.

Q2’s fraud prevention solutions,  including behavioral analytics, anomaly detection, and transaction monitoring, help financial institutions identify patterns that may indicate deception or false-pretense activity before losses occur.

Who must comply and by when

 Why these changes matter

Proactive fraud detection: This moves the ACH network toward continuous, risk-based monitoring.

Enhanced recovery potential: Earlier detection increases the likelihood of intercepting fraudulent transactions.

Higher industry standards: This establishes a uniform baseline for fraud prevention expectations across all ACH participants.

How Q2 is helping financial institutions prepare

Q2’s comprehensive fraud monitoring framework is already designed to align with Nacha’s evolving requirements and support institutions in developing their own documented risk-based procedures. Here’s how:

ODFI capabilities

• Centrix ACH Processing and Risk Management (PIQs) provides ACH whitelisting, monitoring of return ratios, and planned anomaly detection to identify abnormal origination patterns
• Q2 Behavioral Analytics (Sentinel) and Q2 Access Control (Patrol) provide real-time monitoring to detect anomalies or suspicious login activity before initiation. Q2 Sentinel evaluates ACH transactions via Recipient Monitoring. This functionality uses machine learning to identify new recipients and provide an opportunity for the institution to intervene if the transaction looks suspicious

RDFI capabilities

• Centrix Positive Pay (ETMS) validates incoming ACH entries against defined rules to prevent unauthorized transactions
• Centrix ACH Processing and Risk Management (PIQS) enhancements detect mismatches between recipient and account holder names, flags SEC code inconsistencies, and monitors transaction velocity

Cross-network security layers

• Multifactor authentication (MFA) across all Q2 platforms, including online and mobile banking
• Event-driven validation with Q2 Access Control (Patrol) uses behavioral analytics to confirm user identities during high-risk actions

Together, these capabilities give institutions flexible tools to support Nacha’s evolving fraud monitoring expectations without prescribing a specific technology path.

Action steps for financial institutions

Here’s what your institution needs to do to make sure you’re prepared for the upcoming Nacha changes.

1. Determine applicability
   Assess whether your ACH volume triggers Phase 1 thresholds (6M originated, 10M received).
2. Review fraud monitoring procedures
   Ensure your policies cover both unauthorized and false-pretense scenarios.
3. Document governance
   Define roles and responsibilities across compliance, operations, and fraud teams.
4. Plan annual reviews
   Maintain a documented process for updating fraud controls.
5. Leverage technology
   Evaluate vendor solutions, like Q2’s suite, to close monitoring or anomaly detection gaps.

Conclusion

As Nacha’s 2026 rules take effect, financial institutions face heightened expectations for proactive, risk-based fraud monitoring.

Q2 is ready to help with layered fraud prevention, behavioral analytics, and monitoring capabilities institutions need to meet Nacha’s standards and strengthen customer trust and security.

Click here to learn more about Q2’s suite of fraud solutions.

If you’re a current Q2 customer, register here to join our Nov. 21 Innovation Series webinar, in which we discuss how Centrix ACH Processing and Risk Management (PIQS) can help you stay ahead of the Nacha rule changes.