By Jennie Boden and Christopher J. Jones; CreditUnions.com
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Credit unions face a new regulatory obligation in 2026 — one that formalizes succession planning as a baseline expectation, not a best practice.
The National Credit Union Administration’s final succession planning rule (12 CFR Parts 701 and 741, RIN 3133-AF42) went into effect on Jan. 1, 2026. The rule requires both federal credit unions and federally insured, state-chartered credit unions to establish written succession plans.
This article describes the key things credit union leaders need to know to comply with the letter of the new rule. For our thoughts about the opportunity available to credit unions that choose to be more strategic about their compliance efforts, read, “The Opportunity For Credit Unions In NCUA’s New Succession Planning Rule.”
What The New Succession Planning Rule Says
NCUA’s newly effective succession planning rule requires federal and federally insured, state-chartered credit unions to establish a board-approved, written succession plan consistent with their size, complexity, and risk of operations. Credit unions can leverage this NCUA video series for further clarification on what is required.
The agency has also provided a succession planning template for smaller credit unions that we find too limited to be of much strategic value. We offer suggestions in the next section for how to deliver a right-sized plan that stays strategic.
Credit unions with less than $100 million in assets and minority depository institutions of all sizes may also be eligible for assistance in a variety of areas, including succession planning, through NCUA’s Small Credit Union and Minority Depository Institution Support Program.
The rule sets forth that these credit union jobs, or their equivalents, must be included in the written succession plan, at a minimum:
- Members of the board of directors.
- “Management officials” and “assistant management officials,” as those terms are defined in Appendix A of the rule, if provided for in the federal credit union’s bylaws, and, to the extent not already covered, the senior executive officers identified in § 701.14(b)(2).
- Any other personnel the board of directors deems critical given the federal credit union’s size, complexity, or risk of operations. This includes new positions that may be required due to planned changes in operations, supervisory landscape, or corporate structure.