one of the pain points with ACH is its opt in, so you have to maintain records of when someone agreed and keep up with it, along with letting people opt out.
but they're going to use wires to actually transfer the money between financial institutions. if it was check based there will/would be a x937 cash letter trasnferred as well for all the individual accounts that are/were impacted.
I can't find my examples pretty sure its similar to an xml file.
ACH would be more for bill pays from customer to bank, or customer to 3rd party.