Risk management implementation for ODFIs and RDFIs enters its final phase in June, and NACHA continues to enhance the ACH Network. Between late last year and early this year, NACHA introduced several rule changes scheduled to take effect between September 2026 and March 2028.
Highlights include updated funds-availability requirements for non-Same Day credit entries, multiple changes that modernize IAT (International ACH Transaction) processing, higher dollar limits for Same Day ACH, and a new return reason code for sanctions-related blocks.
Over the next 18 months, NACHA’s updates are designed to modernize the Network and align it with today’s faster payments environment. The first change takes effect September 18, 2026, and requires RDFIs to make credit entries available no later than 9:00 a.m. local time on the Settlement Date when the credit is received after 5:00 p.m. the prior business day. This removes the prior flexibility that allowed some non–Same Day credits received after 5:00 p.m. to be posted later in the Settlement Date.
The impact is expected to be minor for most financial institutions, since many already meet this standard. As a best practice, your credit union should review internal posting schedules, processes, and procedures to confirm ACH credits are available by 9:00 a.m. local time on the Settlement Date.
Starting September 18, 2026, the definition of an IAT transaction will clarify that it involves a U.S. ACH Network component of international payments, where funds originate, transit, or are delivered via financial agencies outside the U.S. Entities providing accounts, issuing payment instruments, or transferring funds for third parties qualify as financial agencies. An IAT Entry cannot be a Same Day Entry.
ODFIs must update agreements, procedures, and training, and RDFIs will benefit from improved identification and exception handling.
A second update requires participating financial institutions to register IAT-handling contacts — either two individuals or one department — with current email and phone details by January 1, 2027. Institutions must review registry entries annually and update contact info within 45 days of staffing changes.
On March 19, 2027, NACHA will add optional date-of-birth fields to IAT records and update descriptions to support non-bank foreign financial organizations. These adjustments aim to reduce errors and speed up exception processing for international payments.
Starting September 17, 2027, the maximum size of a Same Day ACH payment increases from $1 million to $10 million per payment. This means more high-value payments can use Same Day ACH, as long as they meet the standard Same Day eligibility rules (for example, IAT is still not eligible for Same Day). Your credit union should review internal and customer limits, file validations, and payment workflows that assume the $1 million cap. If you offer Same Day ACH, consider which customer scenarios might benefit most from the higher $10 million limit.
The final rule change takes effect March 17, 2028, when NACHA adds a new return reason code: R90. This code is used when an RDFI returns an entry to meet sanctions-related obligations. NACHA will also adjust the wording for R16 so it applies only to “Account Frozen,” keeping R90 as the clear indicator for sanctions-related returns. The benefit is clearer return messaging so sending parties can more quickly understand why a payment was returned.
Here’s a quick checklist to help you get ready for the changes:
NACHA is rolling out these updates gradually so you have plenty of time to prepare. With a little planning, most institutions can make the transition smoothly and without much disruption.
Now is a great opportunity to double-check your posting schedules, make sure your team is up-to-speed on IAT identification and contact details, confirm your file formats are ready, and review your Same Day ACH and return-code processes. By taking these steps, you’ll help your teams and your members enjoy a seamless shift as the new rules come into play.
Have questions or want to know more? Contact us at compliancesupport@viclarityus.com.
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