Nacha 2026 fraud monitoring rules

Nacha compliance doesn't have to be expensive with Coffr.

Nacha now requires every business that originates ACH payments to have a process for catching fraudulent payments, including payments sent to impostors. Coffr gives you a proven control for that process, and an immutable audit trail to prove it.

Get your free Nacha readiness review

What Nacha says you need to do

  • Who's covered: every business that originates ACH payments, plus third-party service providers and senders, regardless of payment volume.[1]
  • What's required: "risk-based processes and procedures reasonably intended to identify Entries that are suspected of being unauthorized or authorized under False Pretenses."[1]
  • How often: review those processes at least once a year and update them for new risks.[1]
  • What "False Pretenses" means: a payment someone gets by misrepresenting
    • (a) their identity,
    • (b) their authority to act for another person or business, or
    • (c) ownership of the account being paid.[1]
    Nacha says this covers business email compromise and vendor or payroll impersonation.[1]
  • Where Nacha points Originators: procedures to protect against account takeover "could include change controls regarding payment information and instructions for vendor and payroll payments."[2]
  • Who can provide the controls: Nacha doesn't require a specific tool.[2] Controls can be built internally, provided by your bank, or come from third-party solution providers.[3]

You don't need an expensive platform. You need a control that works and proof that it works.

Impostor payments are the fraud Nacha is targeting

  • 74% of U.S. organizations were targeted by business email compromise in 2025.[4]
  • Business email compromise losses reported to the FBI reached $3.0 billion in 2025.[5]
  • The usual playbook: a fraudster poses as a vendor and swaps in their own bank account, and your team pays it.

Most fraud tools watch for suspicious behavior. Coffr removes the opening.

  • Coffr focuses on eliminating the ability to silently alter a verified relationship.
  • First, Coffr verifies a business, its authorized representative and its bank account. It then generates a cryptographic trust record that binds them together as a single relationship.
  • That relationship is anchored to an immutable ledger, creating a permanent, tamper-evident chain of proof.
  • The result isn't just a verified account. It's a verified relationship that can't be modified without a new verification event.

An audit trail no one can rewrite.

Every verification and change to the relationship is recorded on an immutable ledger that no single company controls, including Coffr. When your bank or auditor asks how you knew a recipient was legitimate, you show them the record. You don't have to rebuild the story from email.

Your Nacha program, with Coffr built in

StepWhoWhat happens
1. Assess your riskYou, with Coffr's helpIdentify which payments carry the most risk: new vendors, bank changes, payroll.
2. Invite the recipientYouSend your vendor or recipient a Coffr request.
3. VerifyCoffrVerifies the business, its authorized representative and its bank account.
4. Bind and anchorCoffrCreates the trust record and anchors it to the immutable ledger.
5. Pay with confidenceYouApprove and send the payment through your bank as usual.
6. Prove itYou, with Coffr recordsHand your bank and auditors the audit trail, and use it for your annual review.
Nacha saysCoffr
Identity: (a)Verified
Authority to act for another: (b)Verified
Account ownership: (c)Verified
Change controls on payment instructionsChanges require a new verification
Documented, reviewable processImmutable audit trail

Built to fit, not to overhaul

  • No enterprise platform to buy.
  • No system to build. Your payments still run through your existing bank.
  • Built-in documentation. Your audit trail builds itself as you work.

See where you stand in 30 minutes

Book a free Nacha readiness review. We'll walk through your vendor and payroll payment process, show where the False Pretenses risk sits, and show how Coffr closes it, with the audit trail to back it up.

Book my readiness review

Nacha compliance doesn't have to be expensive. Ask us how.

Frequently asked questions

Nacha requires each organization to run its own risk-based process.[1] Coffr is the control at the heart of that process, plus the proof.

No. Nacha's rules don't require a specific tool or vendor.[2] Preferred Partner is a paid marketing program, not a certification.[6]

Yes. It applies to every non-consumer Originator, regardless of volume.[1]

Disclosures

  1. Coffr, LLC carries insurance for its own benefit. That insurance does not cover you, your payments or your funds, and Coffr does not guarantee any payment. Coffr does not hold or transmit customer funds. See the Terms of Service.
  2. "Verified" means the identity, business and bank account checks shown passed on the date shown. A verification confirms who you're paying at that time. It doesn't guarantee that a payment will reach the intended recipient.
  3. Coffr records a cryptographic fingerprint of each verification on a public ledger run by independent organizations. Fingerprints contain no names, bank account numbers or tax IDs, and they can't be changed or deleted.
  4. Sources: ACH volume, Nacha 2025 ACH Network volume; online crime losses, FBI IC3 2025 Internet Crime Report.