11.4 The Nacha Rules Effective-Date Calendar: 2026 Through 2028
Key Takeaways
- Effective March 20, 2026: fraud monitoring by ODFIs, Phase 1 fraud monitoring by large Originators/TPSPs/TPSs, Phase 1 ACH credit monitoring by large RDFIs, and the new PAYROLL and PURCHASE Company Entry Descriptions.
- Effective June 2026 (Nacha's current summary lists June 22, 2026): Phase 2 fraud monitoring for all other Originators, TPSPs and TPSs, and Phase 2 ACH credit monitoring for all other RDFIs.
- Effective September 18, 2026: the 5:00 p.m. receipt condition disappears, so RDFIs must make ALL non-Same Day ACH credits available by 9:00 a.m. RDFI local time on the Settlement Date; the definition of IAT Entries is also clarified that day.
- Effective January 1, 2027: registration of IAT contacts in the ACH Contact Registry and the currently accepted characters rule; on September 17, 2027 the Same Day ACH per-transaction limit rises to $10 million.
- Effective March 17, 2028: a new Return Reason Code R90 for sanctions compliance obligations.
11.4 The Nacha Rules Effective-Date Calendar: 2026 Through 2028
Why a calendar section exists: the AAP exam tests the Rules in force during the test window. The October 2026 window sits after four separate 2026 effective dates and before three more. Knowing which side of the line a rule falls on is worth real marks — and knowing a rule is coming protects you from a distractor that describes a not-yet-effective requirement as current.
1. The Calendar at a Glance
+---------------------------------------------------------------------------------------------------------+
| EFFECTIVE DATE | RULE AMENDMENT | STATUS FOR OCT 2026 |
+----------------------+----------------------------------------------------------+------------------------+
| March 20, 2026 | Fraud Monitoring by ODFIs | IN FORCE |
| | Fraud Monitoring Phase 1 (large Orig./TPSP/TPS) | IN FORCE |
| | ACH Credit Monitoring Phase 1 (large RDFIs) | IN FORCE |
| | New Company Entry Descriptions: PAYROLL and PURCHASE | IN FORCE |
+----------------------+----------------------------------------------------------+------------------------+
| June 2026 | Fraud Monitoring Phase 2 (all other Orig./TPSP/TPS) | IN FORCE |
| (summary: June 22) | ACH Credit Monitoring Phase 2 (all other RDFIs) | IN FORCE |
+----------------------+----------------------------------------------------------+------------------------+
| July 24, 2026 | Addition of U.S. Treasury to the ACH Contact Registry | IN FORCE |
+----------------------+----------------------------------------------------------+------------------------+
| September 18, 2026 | Funds Availability for Non-Same Day Credit Entries | Days before the window|
| | Definition of IAT Entries | Days before the window|
+----------------------+----------------------------------------------------------+------------------------+
| January 1, 2027 | Registration of IAT Contacts in the ACH Contact Registry| NOT YET EFFECTIVE |
| | Currently Accepted Characters in the ACH Network | NOT YET EFFECTIVE |
+----------------------+----------------------------------------------------------+------------------------+
| March 19, 2027 | Optional Date of Birth Field for IAT Entries | NOT YET EFFECTIVE |
| | Non-Bank Foreign Financial Agencies in IAT Entries | NOT YET EFFECTIVE |
+----------------------+----------------------------------------------------------+------------------------+
| September 17, 2027 | Same Day ACH Dollar Limit increases to $10 Million | NOT YET EFFECTIVE |
+----------------------+----------------------------------------------------------+------------------------+
| March 17, 2028 | New Return Reason Code R90 for Sanctions Compliance | NOT YET EFFECTIVE |
+---------------------------------------------------------------------------------------------------------+
2. March 20, 2026 — The Risk Management Package Lands
Three of the four items are covered in depth in Sections 9.5 and 9.6. The fourth is a formatting change with outsized exam value.
Standard Company Entry Descriptions: PAYROLL and PURCHASE
The Company Entry Description field is a maximum of 10 characters in the Company/Batch Header Record, and in most cases the Originator chooses the value ("Gas bill", "INS PREM", "SOC SEC"). For certain payment types the Rules mandate a specific description. Effective March 20, 2026, two more became mandatory:
| Description | Required for | Purpose |
|---|---|---|
PAYROLL | PPD credits for payment of wages, salaries and similar compensation | Gives RDFIs that monitor inbound credits better information about new or multiple payroll payments landing in one account — aimed squarely at payroll redirection fraud, and it supports RDFI logic on whether to provide or suppress early funds availability |
PURCHASE | E-commerce purchase transactions | Lets RDFIs and other participants identify e-commerce purchases for monitoring and risk mitigation on higher-risk transaction types |
These join the existing mandated descriptions such as REVERSAL, RECLAIM and RETRY PYMT. The field's requirements are detailed in Subpart 3.2.2 (Glossary of Data Elements) in Appendix Three of the Rules.
Connect the dots: PAYROLL and PURCHASE are risk rules wearing formatting clothes. They exist so that the RDFI credit monitoring required by the same package has usable data to monitor on.
3. September 18, 2026 — Funds Availability Tightens
This one changes a number candidates have memorized for years, and it lands days before the October 2026 test window opens.
Before: an RDFI had to make a non-Same Day ACH credit available by 9:00 a.m. RDFI local time on the Settlement Date only if the credit was made available to the RDFI by *5:00 p.m. local time on the banking day before settlement.
From September 18, 2026: the 5:00 p.m. receipt condition is eliminated. Subsection 3.3.1.1 (Availability of Credits That Are Not Same Day Entries) now reads that for a credit Entry that is not a Same Day Entry, the RDFI must make the amount available to the Receiver for withdrawal no later than 9:00 a.m. (RDFI's local time) on the Settlement Date — full stop.
Practical impact: credits delivered to the RDFI after 5:00 p.m. the prior banking day, including those arriving in the 6:00 a.m. ET ACH Operator file, must now be posted and available by 9:00 a.m. local time. Nacha's stated benefit is earlier availability for payroll, benefits, cashouts, refunds and invoice payments. A related minor rule creates an exception to accommodate time-zone differences for financial institutions located east of the Atlantic Time Zone and west of the International Date Line.
Same Day ACH availability is untouched: Same Day credits remain available by the end of the RDFI's processing day on the settlement day, with the window-specific 1:30 p.m. and 5:00 p.m. RDFI local-time milestones for the first two windows.
4. Ahead of the 2026 Window
- January 1, 2027 — IAT contacts in the ACH Contact Registry. Every Participating DFI must register an IAT-handling contact, either named primary and secondary individuals with title, email and phone, or department contact information with a working email address and telephone number. This aligns IAT with the existing mandatory ACH Operations and Fraud/Risk Management categories.
- January 1, 2027 — Currently accepted characters. Codifies the character set the Network actually accepts.
- March 19, 2027 — IAT enhancements. An optional Date of Birth field, and accommodation for non-bank foreign financial agencies in IAT Entries.
- September 17, 2027 — Same Day ACH to $10 million. The per-transaction limit rises from the current $1,000,000 (in force since March 18, 2022) to $10,000,000. On the October 2026 exam the correct Same Day ACH limit is still $1,000,000.
- March 17, 2028 — Return Reason Code R90. A new return reason code for sanctions compliance obligations, giving RDFIs a purpose-built code; during the October 2026 exam window, R16 is used when OFAC instructs an RDFI to return an Entry.
Exam discipline: when a question asks for a current value, answer with what is in force during the test window.
$1,000,000for Same Day ACH, not$10 million. R90 does not exist yet. IAT contact registration is not yet mandatory. Distractors are built from exactly these near-miss future values.
Effective September 18, 2026, when must an RDFI make a non-Same Day ACH credit Entry available to the Receiver for withdrawal?
Which Company Entry Description did the Nacha Rules make mandatory effective March 20, 2026 for PPD credits paying wages and salaries?
A candidate sitting the AAP exam in October 2026 is asked for the per-transaction dollar limit for a Same Day ACH Entry. What is the correct answer?
Which pairing of a 2026-2028 rule change with its effective date is correct?