The Clearing House's RTP network reaches its full compliance deadline for On-Behalf-Of payment rules on April 16, 2026. The OBO framework took effect June 16, 2025, requiring all participants to implement transparency controls when processing payments initiated by one party on behalf of another.
Under the rules, payment messages must identify the actual payer and payee by legal name. Participants cannot alter details to obscure identities, route cross-border payments as domestic, or involve undisclosed intermediaries.
Financial institutions must vet all entities initiating OBO payments and maintain dedicated internal controls. The Clearing House retains the right to require third-party compliance audits for any participant sending OBO payments.