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2025 Year in Review from a Nacha Rule Making Standpoint

December 18, 2025 by
Carlos Ortiz
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I just can't or don't want to believe we are coming up on the end of 2025.  This has been a very turbulent year for the world in many ways, and it has been no different in the world of payments.  We had the conversion from the Fed Wire to ISO20022 and both FedNow and RTP have raised dollar limits on their respective networks.  The conversations are getting louder around stablecoins but none of that should let us forget what is happening with the ACH Network.   We have major changes coming in March of 2026 related to ACH Credit Push Fraud but while we prepare for that several other things are taken place in the Network.  They are as follows (order does not indicate significance):



  • Recent passage of ballots related to IAT Transactions which will require FIs to have a specific IAT contact in the Registry, clarified definition of what makes an entry an IAT (should reduce the volume) and ultimately a return code R-90 in 2027 for OFAC hits.  There will also be an option addenda record for birth date to better help identify participants for review. Nacha Members Approve Rules to Enhance International ACH Transactions | Nacha


That is not all that happened in payments in 2025.  The Federal Reserve has approved a proposal to expand the hours of the National Settlement Service.  As of now, that has no impact on ACH but stay tuned and for you Wire Transfer enthusiasts that change will occur in either 2028 or 2029.  Stay tuned in as NEACH will prepare you for that and keep you posted on how that will impact the ACH Network.  Judging by how fast this year went that will be right around the corner!


I purposefully didn't want to get into all the fraud that occurred in the payment networks this year because I feel sometimes that is drowning out some of the great work and advancements that are happening.  To remain true to this being a 2025 recap, I will let you know the Federal Reserve did close on a RFC that asked the industry what can be done better to help fight payments fraud.  Regulatory Agencies Seek Comment to Address Fraud | Federal Reserve Financial Services.  The comment period has closed, and the Federal Reserve is working on the next phase of addressing responses and then working with industry and networks to implement changes to address this massive problem.


Let me know if you think I missed anything or would like to discuss any or all of the above.  


Thank you for your continued support of NEACH Payments Group!

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