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Report

// Nacha Phase 2 Compliance Guide

New ACH compliance rules take effect June 22. Is your AP workflow ready?

A guide to what's changing, what's at stake, and what to do before the deadline

Key findings
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Manual two-person approval is no longer sufficient. Nacha now requires automated, risk-based fraud monitoring across your full payment volume.

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Nacha assessed $361,250 in fines across 145 enforcement actions in 2024, and 88% of Nacha fines hit small financial institutions.

insights

Both spreadsheets and many popular AP systems fall short of meeting new Nacha requirements.

Summary

Most businesses that send ACH payments don't realize they're in scope for Nacha's new compliance mandates. Phase 1 covered the largest banks and enterprises. Phase 2 removes the volume threshold entirely: if your business sends even one ACH payment per month, you need documented fraud monitoring, account verification before payment, and standardized transaction descriptions by June 22, 2026.

Non-compliance has real costs: penalties are on the rise and there is no publicly announced grace period.

What you'll learn

Find out whether your business is in scope, what the three new mandates actually require, and where your AP workflow likely falls short with a 16-point compliance checklist.

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