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EPCOR is in a unique position to give you a glimpse into top ACH compliance issues given the volume of ACH audits and risk assessments we conduct each year, coupled with our direct membership with Nacha. Not only can we see where our members might be stumbling, but Nacha also shares aggregate data and themes with us to help us help you improve your ACH practices.

Upon reviewing the 2025 data, we have identified the most problematic issues that have resulted in enforcement actions and fines. The message is clear: non-compliance has a cost, and that cost is rising to deter poor practices. Here are the top compliance hotspots your institution needs to be watching.

Key Areas Driving ACH Violations

An analysis of ACH violations and fines reveals a clear pattern of common operational challenges. Financial institutions should pay close attention to the following areas:

• Registration and Reporting: A significant number of violations stem from failures in registration. This includes not providing required contacts in the Nacha Contact Registry or failing to register Third-Party Senders. Often, the reasons are simple oversights, like not knowing the rules or knowledge gaps created by staff turnover. ODFIs are also being cited for high return rates, including unauthorized returns, administrative returns or overall returns.
• Transaction Authorizations: Issues with authorizations remain a primary concern. This includes processing unauthorized transactions and, critically, failing to provide proof of authorization when requested. A key detail that many overlook is the requirement for the name on the authorization to match the account holder's name for the authorization to be considered valid.
• Operational Follow-Up: Basic operational duties are a frequent source of violations. The top two issues here are the failure to resolve Notifications of Change (NOCs) and the failure to process returns in a timely manner. These are fundamental ACH processes that require diligent oversight.
• Compliance Audits: Failing to provide proof of a required annual ACH Rules compliance audit is a direct path to a violation. This is a foundational requirement that demonstrates an institution's commitment to network integrity.

Expert Recommendations for Staying Ahead

From our vantage point as auditors and consultants, avoiding these fines comes down to building proactive, resilient compliance habits. Here are our recommendations to help you strengthen your operations:

1. Prioritize Registration and Diligence. Make it a priority to confirm that your institution's information in the Nacha Contact Registry is current and that all Third-Party Senders are properly registered. This is low-hanging fruit for compliance and, as Nacha’s data shows, a frequent and avoidable misstep, especially for smaller institutions.
2. Monitor Your Return Rates Proactively. Don't wait for Nacha to call you about high return rates. By monitoring your rates internally, you can identify and address issues with Originators early. If Nacha does reach out, having a pre-existing action plan demonstrates diligence and can help you avoid enforcement escalation.
3. Reinforce Authorization and NOC Procedures. Review your authorization procedures to ensure they are robust and that records are easily retrievable. Stress the importance of resolving all NOCs with your Originators and ensure your team understands the operational and compliance impact of letting them slide.
4. Don't Let Staff Turnover Create Compliance Gaps. The most common reasons given for non-registration are staff turnover or a simple lack of awareness. Create internal documentation and cross-train staff on critical compliance duties to ensure continuity of knowledge.

Staying on top of ACH compliance is an ongoing effort. If any of the issues raised in this article sound familiar, or if you want to ensure your operations are prepared for your next audit, our team is here to help. Reach out to advisoryservices@epcor.org and get your free, no-obligation quote to assess your risk, strengthen controls and ensure your organization stays audit-ready.

Staying informed is a key part of staying compliant. Payment Systems Update offers a deep dive into instant payments expansion, ACH Rules updates and emerging fraud monitoring requirements that directly impact today’s compliance challenges. Take advantage of our early bird pricing and attend in-person this March or join us virtually in April or May!