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AI agents should be authorized through a clear, bounded mandate that identifies the agent, records what the customer intended, and lets the customer review or revoke that authority. Each payment should leave an audit trail connecting the instruction to the authorization, transaction decision, and outcome. No universal protocol or settled legal rule yet provides this model for every agent payment.
What the September 22 bank paper recommends
Building Trust in Agentic Commerce, published on September 22, 2026, by ASB Bank, Bank of America, Capital One, Commonwealth Bank of Australia, ING, and NatWest, emphasizes preserving evidence across an agent-initiated payment. Reporting on the paper describes a record of what the customer instructed, what authority was granted, evidence of authentication and intent, the transaction decision, and what happened before and after payment.
The banks present their principles as a starting point for industry collaboration, not a binding global standard or finished implementation blueprint. The practical insight is that an ordinary payment approval may show that a transaction was accepted without showing whether the agent bought what the customer meant it to buy. A useful record must make both the delegation and the resulting transaction inspectable.
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What a payment mandate should let the customer control
A mandate is the permission an agent receives to act for a person or business. It should be understandable to the customer and machine-readable to the systems that need to check it. The sources support user-defined limits, but do not prescribe one exhaustive set of fields. Depending on the task, useful boundaries can include:
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- Amount: a per-purchase ceiling, or a cumulative budget for several purchases.
- Merchant or category: where the agent may spend, such as a named merchant or a defined type of purchase.
- Purpose: what the agent is permitted to accomplish, such as booking travel or replenishing an item.
- Payment instrument: which payment method the agent may use.
- Recurrence and duration: whether the authority covers one transaction, repeat purchases, or a set period.
These are design options, not a standard field list. A mandate for one booking may need a different combination of limits from one that permits recurring purchases or payments between software services.
Bind permission to a specific agent and intent
The payment participants need a way to verify which agent acted and which mandate it relied on. The record should preserve the customer’s instruction and any relevant changes to it, rather than treating an agent’s later claim about the instruction as sufficient evidence. EMVCo’s September 1, 2026 draft framework addresses intent that persists across participants and transactions, including recurring purchases, cumulative budgets, and activity after a transaction.
Make authority reviewable and revocable
Customers need a way to see what they delegated, understand whether the permission is still active, and change or withdraw it. Payment participants also need enough information to determine whether an agent’s action fell within the authority in effect at the time. The design challenge is to preserve trustworthy evidence of past instructions while ensuring that changed or withdrawn permission does not silently remain active for future transactions.
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What an audit trail should connect
For a disputed agent-initiated payment, the important question is not only whether a transaction occurred. The evidence should let the relevant parties reconstruct how the instruction became a payment and what followed. A useful audit sequence is:
- Instruction: what the customer asked the agent to do, including any material conditions.
- Authority: which mandate applied, its limits, and whether it was active when the agent acted.
- Agent and authentication evidence: which verifiable agent acted and what evidence supports the customer’s authorization.
- Transaction decision: what transaction the agent proposed and how it was checked against the mandate.
- Outcome: what happened before and after payment, including enough transaction information to investigate a mismatch or dispute.
This sequence is a practical reading of the audit-trail principles reported from the six-bank paper and the intent-management work at EMVCo; it is not a published universal record format.
Before trusting an agent with a payment, a customer or business can ask: Can I see what I delegated? Can the issuer or merchant verify which agent acted and under what limits? Can the record connect my instruction to the purchase that actually occurred? Can I review or withdraw the authority? Can the evidence support a fraud review or dispute?
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How the current protocols and frameworks fit together
There is no single winner because the efforts address different parts of a payment. The Bundesbank’s September 2026 analysis describes a fragmented, evolving landscape. It identifies AP2 as prominent in authorization; Visa’s Trusted Agent Protocol as a means for verified agents to transmit payment data and instructions; and Mastercard Agent Pay as a merchant-facing acceptance and trust framework. It also places ACP, UCP, and x402 in the transaction-execution layer.
EMVCo’s September 1, 2026 draft proposes shared “Intent Services” to register, reference, retrieve, and manage consumer-authorized intent before, during, and after a card transaction. EMVCo described the draft as a foundation for further engagement and possible specification work, not an adopted final specification. Its stated feedback deadline was September 30, 2026.
Mastercard describes its Agent Pay Trust Framework through five pillars: identity, intent, controls, trusted execution, and intelligence. On September 30, 2026, it said its first probability score for identifying transactions likely initiated by an AI agent was rolling out for testing in the United States. That is a company announcement about a test, not evidence of general deployment or independently measured effectiveness.
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Visa distinguishes consumer-facing “macro commerce,” such as booking a flight or managing a subscription, from machine-to-machine “micro commerce,” such as an API call or compute purchase. Visa’s 2026 summary of Visa-Artemis research reports roughly $15.0 million in adjusted volume across 109.6 million x402 transactions since its May 2025 launch, and about $25,000 across roughly 115,000 MPP transactions in the first few weeks after its mid-March 2026 launch. These are Visa-attributed figures, not independently verified totals for the market as a whole.
Compare by function, not by protocol name
When assessing an approach, examine whether it covers the parts of the payment journey that matter to the use case:
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- How the mandate is defined, limited, reviewed, and withdrawn.
- How the agent is identified and authenticated.
- How customer intent is conveyed and retained across participants.
- Whether the approach works across relevant payment participants and rails.
- How evidence supports fraud investigation and dispute handling.
- How it fits the applicable legal and regulatory requirements.
- How much autonomy the agent receives, and whether that is appropriate for the task.
An authorization mechanism, an identity method, an intent record, a merchant-acceptance framework, and a settlement or execution protocol are related but not interchangeable. A system can address one layer without resolving the others.
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What remains unsettled legally and operationally
The legal analysis depends on jurisdiction and on how much freedom the agent has. The Bundesbank’s September 2026 discussion identifies the GDPR, EU AI Act, PSD2, German implementing law, and DORA as relevant to agentic payments in the EU and Germany. It says customer-authorized models may be easier to align with PSD2, while highly autonomous models raise more difficult questions.
Among the questions it identifies are whether a mandate counts as payment authorization under PSD2 Article 64, whether an agent regularly performs an activity such as payment initiation that requires authorization, and whether strong customer authentication requirements or exemptions apply. The Bundesbank also says liability for erroneous or fraudulent agent transactions may not yet be conclusively resolved. These are jurisdiction-specific issues, not a general legal answer for every country or use case.
The Bank of England’s 2026 consultation illustrates the distinction between a proposed scenario and a service customers can use: a person tells an agent to bid on artwork up to £200; the agent wins at £160 and pays from the person’s bank account. The example helps surface questions about limits and authority, but it does not establish that such a service is generally available.
How mature is agent-initiated payment activity?
The official materials available as of October 7, 2026, describe draft work, early-stage activity, and testing—not a settled consumer-payment standard. The Bundesbank characterizes the market as a small share and mostly early-stage but gives no figure. The cited materials do not establish an independent statistic for the current share of consumer payments made by AI agents, or independent evidence that any particular authorization design is effective.
Mastercard projected in 2026 that one in 10 consumers would routinely use agents to make purchases by 2030. That is a forecast attributed to Mastercard, not a measurement of present adoption. Likewise, activity figures for particular protocols should not be read as evidence that a broad consumer market has already adopted agentic payments.
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