Welcome to the December 2025 Innovating Payments Executive Summary. On the federal front, Rep. Warren Davidson (R-OH) introduced the Bitcoin for America Act, which would allow Americans, including the unbanked, to pay federal taxes in Bitcoin and direct all such payments into the Strategic Bitcoin Reserve. Also on the regulatory side, federal bank regulatory agencies seek public comment on proposed changes to the community bank leverage ratio framework. The proposal, if passed, would reduce the bank leverage ratio requirement to 8% from the current 9%.
Looking ahead, Deloitte and Forrester weighed in with 2026 predictions, identifying trends and insights to help payments leaders position themselves for success. “The payments industry is evolving — just not as quickly as the headlines might suggest,” Forrester concludes. “Leaders who plan and act now will be prepared for the broader transformation coming in 2027 and beyond.”
In the ACH space, Nacha announced it is seeking public comments on a proposed change to the Nacha Operating Rules that would increase the per-transaction dollar limit for Same Day ACH payments from $1 million to $10 million. Comments are due to close on December 18, 2025.
Finally, the Bank Policy Institute (BPI), the American Bankers Association, Consumer Bankers Association, Financial Services Forum, and The Clearing House Association responded to a U.S. Department of the Treasury Advance Notice of Proposed Rulemaking regarding its implementation of the Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS) Act. The letter of response requests that Treasury develop regulations that preserve the benefits of payment stablecoins for their intended use in payments and settlements, without introducing undue risks for consumers, stablecoin holders or users, competition, credit access, illicit finance, or financial stability.
Links to their comments, along with other industry submissions, are available below.
Read on to learn more.
Top Stories
Rep. Warren Davidson Introduces the Bitcoin for America Act
On Thursday, Nov. 20, Rep. Warren Davidson (R-OH) introduced the Bitcoin for America Act to allow Americans, including the unbanked, to pay federal taxes in Bitcoin and direct all such payments into the Strategic Bitcoin Reserve, according to a news release. “This measure will strengthen long-term national financial resilience and position the U.S. at the forefront of global digital asset leadership.”
“The Bitcoin for America Act marks an important step toward modernizing our financial systems and embracing the innovation that millions of Americans already use every day,” Rep. Warren Davidson said in the release. “This bill will give the American people more choice in paying their taxes, as well as give our government a stronger financial foundation. The Bitcoin for America Act will position our country to lead—not follow—as the world navigates the future of sound money and digital innovation.”
You can read the full Bitcoin for America Act here.
Agencies Invite Comment on Proposal to Enhance Community Banks’ Ability to Serve their Communities While Maintaining Strong Capital Requirements
The federal bank regulatory agencies (Federal Deposit Insurance Corporation, Federal Reserve Board, and Office of the Comptroller of the Currency) invite public comment on a proposal that would implement changes to the community bank leverage ratio framework in line with statutory authority, according to a joint news release.
The proposal would reduce the community bank leverage ratio requirement to 8% from the current 9%. It would also extend the grace period from two quarters to four quarters for a community bank that chooses to participate in the framework and falls out of compliance, giving it more time to regain compliance.
According to the agencies, implementing these changes would reduce regulatory burdens and give community banks more flexibility and options in managing their capital. The proposal shows a better understanding of the unique business models, risk profiles, and operational realities of community banks. These tailored updates are an important step toward addressing the specific needs of community banks in today's financial environment.
Comments on the proposal are due 60 days after publication in the Federal Register.
Additional information is available below:
2026 Predictions
Shaping the Future of Payments (Deloitte)
“By 2026, the payments industry will be shaped by regulation, advanced technology, and rising expectations,” says Deloitte in a recent article highlighting its new report, Shaping the Future of Payments—Trends and Insights for 2026. “Regulation is no longer just about compliance—it is driving innovation and differentiation.”
The report identifies five trends shaping the future of payments, along with a few suggestions to help position leaders for the future:
- Trend 1: Regulation meets innovation: Stablecoin enables seamless global payments.
- Trend 2: Mandates in motion: Speed is the new standard.
- Trend 3: Beyond compliance: Turning data standards into competitive advantage.
- Trend 4: Autonomous payments: Agentic AI is reshaping the role of humans in finance.
- Trend 5: AI vs. AI: AI-powered fraud meets real-time defenses.
According to the article, leaders in the next phase should:
- Retire legacy systems, and transition to modern platforms that support real-time payments and ISO 20022 data standards. Ensure solutions are designed for interoperability and built to scale.
- Focus on improving customer experience. Use technology, enriched data, and AI to minimize friction and tailor services to meet the needs of both business and consumer clients.
- Adopt adaptive, AI-powered risk frameworks: Implement dynamic, real-time fraud and identity solutions that leverage explainable AI and zero-trust principles to balance security and usability.
- And more.
You can download the full report here.
Payments Innovation Takes Root, But Don’t Expect Overnight Change, says Forrester
Forrester, too, is weighing in with its predictions for the New Year. According to the global market research firm, the industry should “expect steady, fundamental shifts rather than headline-grabbing disruption.”
Specifically:
- B2B will embrace AI agent-led payments — B2C, not so much.
- Stablecoins will stay niche.
- Biometrics will get a makeover.
- And more.
“The payments industry is evolving — just not as quickly as the headlines might suggest,” the company concludes. “Leaders who plan and act now will be prepared for the broader transformation coming in 2027 and beyond.”
To learn more, you can read the full article here. The full report is also available for purchase.
Nacha
Nacha Seeks Input on Proposal to Raise the Same Day ACH Transaction Limit to $10 Million
“On Monday, Nov. 10, Nacha announced it is seeking public comments on the proposed change to the Nacha Operating Rules that would increase the per-transaction dollar limit for Same Day ACH payments from $1 million to $10 million,” according to a blog post written by Olivia Marciel, Senior Director of ACH Education and Corporate Outreach at Nacha.
The request for comment invites input from all users of the ACH Network, including businesses, nonprofits, banks, credit unions of all sizes, government agencies, third parties, payment processors, FinTech firms, and solution providers.
The deadline for responses is December 18, 2025.
To read the Request for Comment in full, click here.
Miscellaneous
Banks Submit Recommendations on Treasury’s Implementation of the GENIUS Act
The Bank Policy Institute (BPI), the American Bankers Association, Consumer Bankers Association, Financial Services Forum, and The Clearing House Association responded to a U.S. Department of the Treasury Advance Notice of Proposed Rulemaking regarding its implementation of the Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS) Act, according to a news release. The letter of response requests that Treasury develop regulations that preserve the benefits of payment stablecoins for their intended use in payments and settlements, without introducing undue risks for consumers, stablecoin holders or users, competition, credit access, illicit finance, or financial stability.
The associations made several initial recommendations in their letter, some of which are listed below:
- Implement Congress’s intent to prohibit stablecoins from paying interest or yield. Congress broadly prohibited the payment of interest or yield by stablecoin issuers in GENIUS. That prohibition should be extended to digital asset service providers, such as exchanges and affiliates.
- Prevent regulatory arbitrage. Same activity, same regulation. Treasury should consider federal, state, and foreign payment stablecoin regulatory regimes so that stablecoin issuers are held to the same rules required of any other financial institution engaged in equivalent activities.
- Enforce strict illicit finance safeguards. Combatting illicit finance requires common, strictly enforced standards. Treasury should hold all entities engaged in the same activities to the same standards, including stablecoin issuers, digital asset services providers, and banks.
- And more.
To access a copy of the associations’ response, please click here. Additional document comments are available here.
NEACH
As 2025 draws to a close, NEACH thanks you, our members, for empowering us to be your voice in New England’s payments industry. Together, we have influenced payments developments that have created opportunities and meaningful change.
Looking ahead, we’re excited to continue as your strategic partner—helping you achieve your business goals with tailored training, personalized support, and innovative news and insights. Learn more about what to expect in the coming year by joining us on December 16 for the NEACH webinar, “What’s Next in Payments.”
NEACH - New England Automated Clearing House Association is a neutral, member-focused advocate. Our role is to give you the intelligence, context, and connections you need to make informed strategic decisions. We bring together industry leaders, policymakers, and innovators so you can evaluate innovation through the lens of your institution’s mission and market strategy. For more information, visit neach.org.
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AUTHOR: Joe Casali, AAP, AFPP, APRP
Executive Vice President
As the EVP of Payments Innovation for NEACH, Joe focuses on exploring innovative solutions and technologies that will help position members for success, both now and in the future. Connect with Joe to read more of his blogs, articles, and posts.
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