ACH can look clean, cheap, and simple from the outside, but the real risk lives in authorization quality, fraud monitoring, return exposure, transaction context, and operational controls. The 2026 Nacha rule changes make it clear that ISVs, platforms, payment companies, payroll providers, and embedded finance teams cannot treat ACH as a low-cost payment feature without a real risk strategy behind it.

The May 2026 Executive Order signals a more fintech-friendly regulatory posture, but that does not mean ISVs, PayFacs, and payments companies can walk closer to the source with messy controls, decorative AML policies, and risk programs held together by vibes. If you want deeper bank relationships, direct access, or a more ambitious payments strategy, your compliance, governance, security, and operational evidence need to be ready for real scrutiny.