Same Day ACH Limit Increasing to $10 Million: Key Considerations for Credit Unions

In April 2026, Nacha approved an increase to the Same Day ACH transaction limit from $1 million to $10 million, effective September 17, 2027.  This decision marks one of the most significant changes to the ACH network in recent years. While the change will expand payment capabilities for businesses and consumers, it also raises important considerations related to financial and operational controls—most significantly regarding liquidity management and fraud prevention. 

What's Changing?

The expanded limit applies to both credit and debit transactions across all Same Day ACH settlement windows and applies to both consumer and business payments.

According to Nacha, the increase is designed to support growing demand for faster payments and better align ACH capabilities with modern payment solutions such as RTP® and FedNow®.

Why It Matters

For many credit unions, the higher transaction limit may lead to increased use of Same Day ACH for:

• Commercial and treasury management transactions

• Payroll processing

• Vendor and supplier payments

• Liquidity transfers

• High-value member transactions

  
  

With additional activity, the increase may create opportunities for credit unions to better support business members and expand treasury management services.

However, as transaction values increase, so does the potential impact of processing errors, fraud attempts, unauthorized activity, and operational disruptions. A single control failure could carry greater financial consequences than under the current limit.

Key Risk Areas to Evaluate

Credit union management should begin assessing whether existing controls are prepared for a higher-dollar payment environment. Areas to review include:

1. Liquidity Management

Larger Same Day ACH transactions may create increased settlement funding requirements and greater demands on liquidity planning.

2. ACH Exposure Limits

Current member limits and risk profiles may need to be revisited to ensure they align with the institution's risk appetite and business strategy.

3. Fraud Monitoring

Transaction monitoring systems should be evaluated to determine whether they can effectively identify unusual or high-dollar ACH activity.

4. Operational Controls

Policies, procedures, exception handling processes, and segregation of duties should be reviewed to ensure they remain effective as transaction values increase.

5. Vendor Readiness

Credit unions should engage with core processors, ACH providers, and technology partners to understand their implementation plans and readiness timelines.

Same Day ACH Readiness Checklist

As the implementation date approaches, management teams should evaluate whether their institution is prepared for a higher-dollar Same Day ACH environment:

Preparing for 2027

While September 2027 may seem distant, significant payment-related changes often require updates to risk assessments, exposure limits, vendor configurations, policies, staff training, and board reporting. Institutions that begin planning early will have more time to identify and address potential gaps.

How Griffin & Furman Can Help

The increase in Same Day ACH limit provides a valuable opportunity for credit unions to evaluate their ACH risk management framework before the rule takes effect.

Through ACH Audits and ACH Risk Assessments, Griffin & Furman helps credit unions assess transaction monitoring controls, exposure limits, liquidity management practices, and overall operational readiness.

Contact our credit union specialists to discuss how your institution can prepare for the transition to a $10 million Same Day ACH environment.