ACH Rules Change Sept. 18: What Subscription Businesses Need to Know

ach nacha payment processing recurring payments Sep 16, 2026

Changes to the rules governing ACH payments take effect Friday, September 18, and one could affect subscription businesses that accept ACH payments from customer bank accounts.

If those payment flows involve accounts or financial institutions outside the United States, the way some transactions are classified may change.

Nacha, the organization that sets the operating rules for the U.S. ACH system, is revising the definition of an International ACH Transaction, or IAT. A separate change affects when banks and credit unions must make certain ACH credits available.

For subscription businesses using ACH, the international transaction change is the one to watch most closely.

International ACH Transactions Get a Clearer Definition

Beginning September 18, Nacha is changing the IAT definition to make it clearer when an ACH payment should be classified as international. The change does not create a new type of international payment. It clarifies when the existing IAT designation applies.

Under the revised definition, an IAT is the U.S. ACH Network portion of a payment that originates with, passes through or is delivered to an account at a financial institution outside the United States. It can also cover payments received from or delivered through certain facilities of a financial institution outside the country.

Some payments may be classified differently as a result. If a payment moves from domestic to IAT, your bank or payment provider may need updated agreements, additional due diligence or more information about the person or business receiving the payment.

For subscription operators, the practical question is simple:

Does this change how any of our current ACH payments are classified or handled?

If your ACH payment flow involves an account or financial institution outside the United States, ask your bank or payment provider whether the revised IAT definition changes how those payments should be classified.

International ACH is a small share of the overall network, but more than 120 million of these payments moved through the system in 2025.

Some ACH Credits Will Be Available Earlier

Another September 18 change affects when recipients can access non-Same Day ACH credits.

Receiving financial institutions generally will have to make those funds available by 9 a.m. local time on the settlement date. The current rule includes a condition based on whether the institution received the payment by 5 p.m. on the previous banking day. That condition is going away.

Many financial institutions already make these funds available by that time, according to Nacha. Others may need to change their processes. There is also an exception for certain institutions affected by time-zone differences.

For most subscription businesses, this is a bank-side change rather than a new merchant requirement. It can still affect when a customer or business partner receives an ACH credit, including a refund.

Recurring Payments Are Part of ACH’s Scale

The ACH Network processed 35.2 billion payments worth $93 trillion in 2025. Nacha also recorded 4.86 billion prearranged consumer ACH payments last year. That category includes recurring obligations such as mortgage, loan and utility payments.

We do not have a clean number showing how many subscription payments run through ACH. But the data shows how established bank-account payments have become for recurring payments in the United States.

For global subscription businesses, the role of bank-account payments may be even more familiar. ACH is specific to the United States. Other countries use their own direct-debit systems. In the euro area, direct debit accounted for 60% of consumer subscription payments by number in 2024, compared with 20% for cards, according to the European Central Bank.

Insider Take

If your subscription business uses ACH, the immediate issue is whether the September 18 IAT change affects any of your existing payment flows.

You do not need to become an ACH expert. But if those payments involve accounts or financial institutions outside the United States, ask your bank or payment provider whether the revised definition changes how they are handled.

There is a broader payments lesson here, too. Card payments and bank-account payments do not operate under the same rules. Authorization, failures and what happens when a payment goes wrong can differ depending on the payment method.

Related Member Resources

ACH changes can sit several layers below the customer payment experience. These resources help operators understand how a payment moves through the system and ask better questions about who is responsible when payment rules or classifications change.

Is Your Payment Stack Supporting Your Subscription Business? 15 Questions to Ask
This 15-question assessment helps you look across the companies and internal teams involved in your payment operation and understand who owns what. For a rule change like this, it gives you a practical way to identify who should be checking the impact and what questions to ask your bank or payment provider.
How a Subscription Payment Works: From Checkout to the Bank
This plain-English guide explains what happens between checkout and the business bank account, including the different companies involved along the way. It gives operators a clearer foundation for understanding where payment rules can affect the flow and which payment partner may need to answer the next question.