The ACH (Automated Clearing House) Network plays a crucial role in facilitating the transfer of funds between bank accounts in the United States, enabling transactions ranging from payroll deposits to bill payments.
As more businesses leverage ACH for online transactions, compliance with the NACHA Web Debit Rule becomes increasingly essential.
In this post, we’ll explain what the rule is, why it exists, and what your business needs to do to stay compliant with real-world examples of compliant and non-compliant practices.
What Is the NACHA Web Debit Rule?
The Web Debit Rule refers to NACHA’s requirements for any ACH debit entry that is authorized over the internet or a mobile device. These are known as Web entries, and they apply when:
- A consumer authorizes a one-time or recurring debit from their bank account
- The authorization is given over the web, a mobile app, or any other internet-enabled channel
The Purpose:
This rule exists to reduce fraud and errors in online transactions by requiring additional account validation before initiating a web debit.
Key Requirements of the WEB Debit Rule
NACHA mandates that originators of Web debits must:
- Use a “commercially reasonable” method to validate the account number being used to debit funds
- Validate that the account is open and able to receive ACH debits
- Authenticate the identity of the customer
Since March 19, 2021, NACHA has required that account validation be performed as part of a commercially reasonable fraud detection system for all new web debit entries, not just first-time payments.
What Is “Commercially Reasonable” Validation?
This can include:
- Use of a validation service (like Plaid or MX) that confirms account status
- Use of prenotification entries (pre-notes) before processing actual debits
- Use of micro-deposit verification (sending two small deposits for the customer to confirm)
- Database verification that uses the history of prior successful payments to the same account
Note: Merely checking that an account number is formatted correctly or exists in a known bank routing table is not sufficient under the rule.
Does NACHA Web Debit Rule carry over to RTP and FedNow?
No, the NACHA Web Debit Rule does not directly apply to RTP (Real-Time Payments) or FedNow transactions, because it is a NACHA-specific rule, and RTP/FedNow operate on different payment rails entirely.
However, there are some essential overlapping themes and best practices to be aware of:
Why It Doesn’t Apply (Yet):
- ACH Debits are pull payments, where the receiver initiates the transaction and pulls funds from the sender’s account. That inherently carries a higher fraud risk
- , thus the validation requirement.
- RTP and FedNow are push-only systems, where the sender authorizes and initiates the payment. Because of this structure, there's less inherent risk to the recipient of funds, so the need for NACHA-style account validation is not as urgent from a regulatory standpoint.
Best Practices Still Apply
Even though it’s not required today, many RTP/FedNow processors and sponsor banks do still expect:
- Identity verification (KYC/KYB)
- Bank account ownership verification
- Fraud risk mitigation procedures
Especially if you're building a product that will offer both ACH debits and instant payments, it’s smart to apply the highest common standard across the board.
TL;DR
- NACHA Web Debit Rule does NOT apply to RTP or FedNow
- But you should still validate accounts and authenticate users
- Sila’s platform addresses these concerns with built-in support for both ACH and instant payment rails, all behind a single API.
Compliant vs. Non-Compliant Examples
Compliant Use Cases
- SaaS Subscription Payment
- A user signs up for a monthly subscription and enters their bank details.
- The company uses a third-party provider like Plaid to verify that the account is valid and accepts ACH debits.
- The system also authenticates the user's identity through two-factor authentication.
- Compliant with NACHA Web Debit Rule.
- eCommerce One-Time Purchase
- At checkout, the user selects “Pay with Bank Account.”
- The business uses micro-deposits to validate the account and requires confirmation before processing the debit.
- Compliant.
- Fintech App Linking External Account
- The app initiates a one-time Web debit to fund a digital wallet.
- Account verification is performed through an account aggregator API like Plaid, and the user is authenticated via SMS.
- Compliant.
Non-Compliant Use Cases
- Assuming a Valid Account Based on Past Success
- A company processes a new Web debit based on a prior successful transaction, but has never verified if the account is open or accepting debits today.
- Not compliant. NACHA requires ongoing validation, not just a one-time validation.
- Relying Only on Routing Number & Format Validation
- The company verifies that the bank routing number is valid and that the account number contains the correct number of digits.
- Not compliant. Format verification is not sufficient.
- Skipping Validation for Mobile Payments
- A customer makes a mobile purchase using a bank account, but no account validation or user authentication is performed.
- Not compliant. Mobile-originated transactions are covered under the WEB rule.
Why This Matters for Your Business
Non-compliance with NACHA rules can lead to:
- Fines and audits
- Returned transactions
- Increased fraud exposure
- Loss of sponsor bank support
However, there’s good news: compliance is achievable, especially when you partner with a fintech platform that already has these guardrails in place.
How Sila Helps with Web Debit Rule Compliance
Sila’s platform helps fintechs and software companies build powerful payment experiences without compromising on compliance. Here’s how:
- Built-in support for identity verification (KYC/KYB)
- Integration with leading account verification partners
- Real-time feedback for ACH return codes
By using Sila, your team can focus on building your product while we help ensure your ACH processes align with NACHA’s rules.
The NACHA Web Debit Rule isn’t optional, and compliance isn’t just about avoiding penalties. It’s about protecting your business and your users.
By validating accounts, authenticating users, and ensuring your processes meet modern security standards, you can build trust and reduce your risk exposure.
If you need help navigating these requirements, we’re here to assist you.