Nacha's Fraud Monitoring Phase 2 is now in effect as of June 19, 2026.

The primary difference between Phase 1 (effective March 20, 2026) and Phase 2 is that all volume thresholds have been removed. As a result, all participants are now subject to the fraud monitoring requirements, regardless of origination volume. RDFIs, ODFIs, Originators, Third-Party Service Providers, and Third-Party Senders are all impacted and are required to establish and implement risk-based processes and procedures meant to reasonably identify Entries that are unauthorized or authorized under False Pretenses.

Download our guidance document from the Fraud Forum to better understand the responsibilities of each participant under these rules and best practices for implementation of the changes (Fraud Forum login required).

Join in the discussion and access supporting resources about this Rule and its impacts in ePayResources' Originator Education Community, a space for corporate ACH Originators and the ODFIs, Third-Party Senders, and Third-Party Processors that support them to network and to stay informed and compliant with the Nacha Operating Rules (login required).

If you have questions about the Fraud Monitoring Rules, please call the Payments Answerline™ at 800-475-0585, Option 1.