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 reviewWhat 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]
- 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
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
| Step | Who | What happens |
|---|---|---|
| 1. Assess your risk | You, with Coffr's help | Identify which payments carry the most risk: new vendors, bank changes, payroll. |
| 2. Invite the recipient | You | Send your vendor or recipient a Coffr request. |
| 3. Verify | Coffr | Verifies the business, its authorized representative and its bank account. |
| 4. Bind and anchor | Coffr | Creates the trust record and anchors it to the immutable ledger. |
| 5. Pay with confidence | You | Approve and send the payment through your bank as usual. |
| 6. Prove it | You, with Coffr records | Hand your bank and auditors the audit trail, and use it for your annual review. |
| Nacha says | Coffr |
|---|---|
| Identity: (a) | Verified |
| Authority to act for another: (b) | Verified |
| Account ownership: (c) | Verified |
| Change controls on payment instructions | Changes require a new verification |
| Documented, reviewable process | Immutable 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.
Nacha compliance doesn't have to be expensive. Ask us how.