Effective dating
Which version of the rule applied at that moment?
Rules, prices and facts change, and regulated industries have to answer for the past. Effective dating is how a system knows which version applied on a given day, so you can recalculate, explain or defend an old decision.
What it is
Every rule, rate and fact carries the dates it was valid, and every calculation uses the version that was true when the event happened, not when you run it. Corrections that reach back in time ("retro" changes) are routine, not edge cases.
If your system only knows the current value, it can't answer the questions auditors, customers and courts actually ask.
Where you'll see it
| Industry | Where the date matters |
|---|---|
| Payroll | Retro pay after a backdated raise; a tax rate that changed mid-year |
| Telco | Fee changes; was this sender approved when the message went out? |
| Insurance | Policy amendments that apply from a past date |
| Payments | Fee schedule changes; network rules with announced effective dates |
| Healthcare | Coverage that started or ended in the middle of treatment |
Questions to ask in week one
- Which values change over time, and do we keep the history?
- When something is corrected after the fact, do we recalculate the past?
- Do we record both when something happened and when we learned about it?
- Which upcoming rule changes already have an effective date?
- Can we reproduce a calculation exactly as it ran on a past date?
The trap
Overwriting values in place because "we only care about now". The first backdated correction, audit or dispute proves otherwise. Two dates beat one: when it was true, and when we recorded it.
In the Field Guides
B2B payments: order to cash
A sale's cost and rights depend on the day each thing happened. Prices change between PO and shipment, promotions carry date ranges that deductions cite months later, limits change mid-order, and Visa US interchange changes each April and October.
| Change | Effective | Status (Oct 2026) |
|---|---|---|
| Canada: criminal interest rate 35% APR; business advances over $10,000 capped at 48% up to $500,000 | January 1, 2025 | Live |
| US bankruptcy amounts reset ($8,575 minimum to sue a business over a preference) | April 1, 2025 | Live |
| ASU 2025-05 credit-loss expedient | Years beginning after December 15, 2025 | Live for calendar-2026 year-ends |
| Visa interchange: enhanced-data "Product 3" rates; Level II gone except fuel | April 18, 2026 | Live |
| CFPB Section 1071 rule revised; still excludes trade credit and factoring | Effective June 30, 2026; compliance January 1, 2028 | Live |
| Federal Prompt Payment interest 4.75% | July 1 to December 31, 2026 | Live; resets every six months |
| ACH credits (not same-day) available by 9 a.m. | September 18, 2026 | Live |
| Canada: paper remittances no longer exchanged between banks for bill payments | December 1, 2026 | Upcoming |
| Canada: Real-Time Rail, first participants | Q4 2026 | Upcoming |
| Same Day ACH limit $1M → $10M | September 17, 2027 | Upcoming |
| Canada: paper PADs no longer exchangeable | December 1, 2028 | Upcoming |
| Visa and Mastercard merchant settlement | Preliminary approval June 2026 | Final approval pending |
Sources: Bennett Jones, Cooley, RSM, Visa, Mayer Brown, Nacha on funds availability and Same Day ACH, Fiscal Service, Payments Canada on bill payments and RTR.
Store the price, promotion, terms, fee schedule and card product that applied to each order, invoice and payment at the time, not a pointer to today's version. Deduction fights turn on which version applied.
Ask an expert: how far back do retailers' post-audit deductions reach, and can you rebuild the price or promotion in force on the ship date?
B2B payments: procure to pay
A payment's cost, tax treatment and rights depend on the day it moved. Terms can start their clock at the invoice date, receipt of the invoice, receipt of goods or month end, depending on the contract. Bank details have an effective date too: many buyers hold payments to recently changed details. 1099 thresholds follow the payment date, not the invoice date.
| Change | Effective | Status (Oct 2026) |
|---|---|---|
| Fedwire moves to ISO 20022 | July 14, 2025 | Live |
| Rebate schedule amended in one state cooperative card contract | October 1, 2025 | Live; rebates change by contract amendment |
| FedNow network limit $1M → $10M | November 2025 | Live |
| Lynx fully on ISO 20022 | November 22, 2025 | Live |
| 1099-NEC and most 1099-MISC thresholds $600 → $2,000 | Payments after December 31, 2025 | Live; indexed to inflation from 2027 |
| 1099-K back to more than $20,000 and 200 transactions | Proposed regulations January 8, 2026 | Law live; regulations proposed |
| Nacha fraud monitoring, phases 1 and 2 | March 20 and June 22, 2026 | Live |
| Visa US interchange table | April 18, 2026 | Live; Visa updates in April and October |
| First-Class stamp 78¢ → 82¢ | July 12, 2026 | Filed by USPS |
| Prompt Payment interest 4.75% | July 1 to December 31, 2026 | Live; resets every six months |
| Non-same-day ACH credits available by 9 a.m. | September 18, 2026 | Live |
| Canada: Real-Time Rail, first participants | Q4 2026 | Upcoming |
| Same Day ACH limit $1M → $10M | September 17, 2027 | Upcoming |
| Nacha R90 return code for sanctions | March 17, 2028 | Upcoming |
| Visa and Mastercard merchant settlement | Preliminary approval June 9, 2026 | Final approval pending |
Sources: IRS (12/2026) and IR-2026-03, Fiscal Service, Nacha on fraud monitoring and funds availability, FRB Services, USPS, Payments Canada; the card contract and Visa's settlement filing are listed in Sources.
Store the terms, tolerance, tax threshold and bank details that applied when each invoice was approved and each payment released, not a pointer to today's version.
Ask an expert: how do ERPs handle a supplier that crosses $2,000 in December 2026 after a mid-year bank change: whose TIN, and which threshold?
B2B payments: spend management
Every rate in an expense has an effective date, and the IRS mileage rate has two. It rose from 72.5¢ to 76¢ a mile on July 1, 2026, citing fuel prices, the first mid-year change since 2022. The 76¢ applies only if the miles were driven and the allowance paid on or after July 1: a June trip reimbursed in July stays at 72.5¢. The IRS per diem year starts October 1; through December, an employer on the high-low method keeps that method and uses old or new rates consistently for everyone.
| Change | Effective | Status (Oct 2026) |
|---|---|---|
| Canada: small-merchant interchange cuts, consumer credit only | October 19, 2024, for five years | Live; commercial cards not covered |
| Visa validates Level 3 data | October 17, 2025 | Live |
| No deduction for employer-convenience meals | Amounts after December 31, 2025 | Live |
| CRA kilometre allowance $0.73 / $0.67 | January 1, 2026 | Live; 2027 rates due in January |
| Nacha: wage credits must say "PAYROLL" | March 20, 2026 | Live |
| Visa US interchange table | April 18, 2026 | Live; updates in April and October |
| IRS business mileage 72.5¢ → 76¢ | July 1, 2026 | Live; 2027 rate due mid-December |
| IRS high-low per diem $319 / $225 → $329 / $230 | October 1, 2026 | Live |
| GSA standard per diem $181 ($113 lodging, $68 meals and incidentals) | October 1, 2026 | Live |
| NJC travel meals $123.20 plus $25 incidentals a day | October 1, 2026 | Live |
| Visa and Mastercard merchant settlement | Preliminary approval June 9, 2026 | Final approval pending |
| CFPB Section 1071 small-business data | Compliance January 1, 2028 | Revised rule live; card coverage to confirm |
Sources: Announcement 2026-11, Notice 2026-60, Rev. Proc. 2019-48, GSA, NJC, Nacha, Finance Canada, CFPB; Visa entries in Sources.
Key every rate to the expense date and the jurisdiction, and US mileage to the payment date too; store the rate you applied, not a pointer to today's table.
Ask an expert: when a rate changes mid-period, do customers re-rate claims that were submitted but not yet paid?
Telco: numbers and senders
The price of a message depends on the day it was sent, and sometimes on which carrier memo you read.
| Change | Effective | Status (Oct 2026) |
|---|---|---|
| T-Mobile 10DLC SMS fee $0.0030 → $0.0045 | January 2026 (sources cite the 15th, 19th and 29th) | Live |
| AT&T SMS fee $0.0030 → $0.0035, both directions; MMS (picture message) $0.0075 → $0.0090 | April 1, 2026 | Live |
| Verizon SMS fee $0.0045, sent messages only | May 1, 2026 | Live |
| Verizon 10DLC and toll-free SMS fee $0.0050 | October 1, 2026 | Reported by one aggregator |
| WhatsApp charges for service replies and in-window utility templates | October 1, 2026 | Live |
| FCC "revoke-all" opt-out rule | Waived to January 31, 2027 | Rewrite scheduled for an FCC vote on Sept 30, 2026; outcome unconfirmed |
| Auth+ for all brands except sole proprietors | January 21, 2027 | Provider-reported |
Sources: AT&T change notice and carrier fee table (both secondary), Meta, FCC DA 26-12, Troutman Pepper Locke.
Meta runs a cleaner calendar: WhatsApp prices change only on January 1, April 1, July 1 or October 1, with at least a month's notice for a rate change and six for a model change. A template is charged at the category it holds when sent (Meta pricing).
The FCC splits dates in two. A rule can be "effective" while compliance waits for OMB (the White House office that approves paperwork burdens) and a Federal Register notice, as the SIM-swap and NG911 rules did. Track the compliance notice, not the vote.
Store two dates on every approval and every fee: when it took effect and when you learned about it. Finance and carriers will both ask what applied when a given message went out.
Ask an expert: when a carrier fee changes mid-month, do you re-rate messages already sent, and who decides which date applied?
Field Guides are learning notes, not legal or compliance advice. Rules and fees change; check the cited primary sources before you act on anything here.