Guidance: $25,000 Per-Transaction Limit
Published: January 5, 2016
Same Day ACH guidance related to the $25,000 per transaction for Same Day ACH transactions.
$25,000 Per-Transaction Limit Guidance
The limit on large-dollar transactions (those ACH Entries over $25,000) applies to individual transactions; i.e., a single Same-Day ACH transaction could not be for more than $25,000. There is no similar limit on the aggregate value of a batch of Same-Day ACH transactions. Entries submitted in a same-day processing window that are over $25,000 will not be rejected by the ACH Operator, but will be processed for next-day settlement in the next available processing window.
Transactions may not be restructured to evade the $25,000 limit. For example, if a business has a loan payment of $50,000 due, that payment would not be eligible for Same-Day ACH and should not be divided and sent as multiple same-day Entries in order to avoid the per-transaction dollar limit. However, if a business is paying multiple invoices from the same supplier that each amount to $25,000 or less, each invoice could be paid using a distinct Same-Day ACH transaction. Originators should be educated to avoid attempts at structuring Entries in order to evade the per-transaction dollar limit. Since evasion can be a very fact specific inquiry, NACHA will consider evasion issues on a case-by-case basis.
The information contained within this document is an informal interpretation intended to provide general guidance by NACHA staff in interpreting the NACHA Operating Rules. The interpretation is not an official position of NACHA and is not binding on NACHA staff, the NACHA Board or any ACH Rules Enforcement Panel. All applications of the NACHA Operating Rules are subject to facts and circumstances of the specific case. Readers of this document should obtain their own legal advice regarding their obligations under the NACHA Operating Rules or applicable legal requirements.