AI agents should pay only under a clear, bounded mandate that identifies the agent, records what the customer intended, and lets the customer review or revoke authority. The transaction record should connect the instruction to the payment decision and outcome. The September 22, 2026, six-bank paper makes that audit trail central, but it is a set of principles—not a binding global standard. No single protocol yet provides a settled answer for every agent payment.
What the September 22 bank paper recommends
Building Trust in Agentic Commerce was published on September 22, 2026, by ASB Bank, Bank of America, Capital One, Commonwealth Bank of Australia, ING, and NatWest. The banks presented their principles as a starting point for broader industry collaboration, not a finished implementation blueprint.
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As described in reporting by PYMNTS, the paper emphasizes keeping an auditable record of what a customer instructed an agent to do, what authority was granted, evidence of authentication and intent, the transaction decision, and what happened before and after payment. The important distinction is that a conventional payment approval may show that a transaction was authorized through a payment channel without showing whether the agent bought what the customer actually asked for.
For a later fraud review or dispute, the useful evidence chain is therefore not just “payment approved.” It should connect the customer’s instruction and delegated authority to the agent’s action, the payment decision, and the result.
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What a sound authorization should let people verify
A customer needs a mandate that is understandable to them and machine-readable by the systems that act on it. Payment participants, including an issuer or merchant, need a way to verify which agent acted and whether its proposed transaction fell within that mandate. The cited standards and policy materials support bounded, user-defined authority; they do not prescribe one exhaustive set of mandate fields.
Define the permitted scope
Depending on the task, a mandate can set limits such as a maximum amount, permitted payment instrument, merchant or category, purpose, recurrence, or duration. The point is to specify only the discretion the task needs. A one-off purchase and an ongoing subscription-management task should not silently receive identical authority.
Bind the mandate to an agent and intent
The record should make it possible to determine which verifiable agent acted, what the person asked it to do, and what authority was in force at the time. That link matters when an agent hands work between services or acts across more than one transaction. EMVCo’s draft framework addresses intent that persists across participants and transactions, including recurring purchases, cumulative budgets, and activity after a transaction.
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Keep authority manageable over time
Authorization is not only a one-time approval. A customer should be able to review, change, or withdraw a mandate, and relevant systems need a way to recognize the current state of that authority. The transaction evidence should remain useful for investigation after the purchase, even if the mandate has since changed or ended.
Use these questions to assess a design
- Can the customer tell what they delegated and what limits apply?
- Can a payment participant verify which agent acted and whether it stayed within those limits?
- Can the evidence show both what the agent was instructed to do and what it actually did?
- Can the customer review or withdraw authority, and can the record support a later fraud review or dispute?
Why there is no single agent-payment protocol
The September 2026 analysis from the Deutsche Bundesbank describes a fragmented, evolving landscape. The approaches it identifies operate at different layers: authorization, agent identification and transmission of instructions, merchant acceptance, intent management, and transaction execution. Treating them all as competing versions of one payment protocol obscures what each is designed to do.
| Approach | Role described in the sources | Status or qualification |
|---|---|---|
| Agent Payments Protocol (AP2) | Prominent in the authorization layer in the Bundesbank’s account. | Part of an emerging, fragmented landscape. |
| Visa Trusted Agent Protocol (TAP) | Provides a way for verified agents to transmit payment data and instructions. | Identified by the Bundesbank as a distinct role from authorization. |
| Mastercard Agent Pay | A merchant-facing acceptance and trust framework. | Mastercard describes five pillars: identity, intent, controls, trusted execution, and intelligence. |
| EMVCo Intent Services | A proposed shared way to register, reference, retrieve, and manage consumer-authorized intent before, during, and after a card transaction. | EMVCo’s September 1, 2026, publication is a draft foundation for further engagement and possible specification work, not an adopted final specification. Its stated feedback deadline was September 30, 2026. |
| Agentic Commerce Protocol (ACP), Universal Commerce Protocol (UCP), and x402 | Described by the Bundesbank in the transaction-execution layer. | Execution is a different problem from defining and verifying a customer’s mandate. |
These approaches should be assessed by the problem they address: mandate limits and lifecycle controls; agent identity and authentication; evidence of intent and auditability; interoperability among participants and payment rails; fraud and dispute handling; regulatory fit; and the degree of autonomy permitted. A name or protocol label alone does not establish that all these functions are covered.
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What recent framework announcements do—and do not—show
EMVCo’s September 1, 2026, draft proposes a shared foundation for carrying consumer-authorized intent alongside card-payment information. It is a proposal for further work, not proof that issuers, merchants, and agents already share a deployed intent service.
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1Fix the driver behind crashes, sound loss and screen glitches2Repair Windows errors before they cause bigger problems3Scan for outdated or missing drivers - takes under a minuteMastercard says its Agent Pay Trust Framework rests on identity, intent, controls, trusted execution, and intelligence. On September 30, 2026, it announced that 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 availability or independently measured effectiveness. Mastercard also projected in 2026 that one in 10 consumers would routinely use agents to make purchases by 2030; that figure is a forecast, not an observed adoption rate.
Visa distinguishes “macro commerce,” such as booking a flight or managing a subscription, from “micro commerce,” such as an API call or compute purchase. In a 2026 summary of Visa-Artemis research, Visa reported roughly $15.0 million in adjusted volume across 109.6 million x402 transactions since x402’s May 2025 launch. The same Visa summary reported about $25,000 across roughly 115,000 transactions for MPP during its first few weeks after a mid-March 2026 launch. These are Visa’s reported figures and measurement descriptions, not independently verified totals for the whole market. Transaction counts or settlement volume also do not, by themselves, establish how well a system handles intent, fraud, or disputes.
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Where the legal questions remain open
The Bundesbank’s discussion concerns the European Union and Germany, where it identifies the GDPR, EU AI Act, PSD2, German implementing law, and DORA as relevant to agentic payments. It suggests customer-authorized models may be easier to align with PSD2 than highly autonomous models. That does not settle the legal treatment of any particular arrangement.
For more autonomous agents, questions include whether a mandate qualifies as payment authorization under PSD2 Article 64, whether an agent’s activity amounts to regularly performing a regulated activity such as payment initiation, and whether strong customer authentication is required or an exemption applies. The Bundesbank also says liability for erroneous or fraudulent agent transactions may not yet be conclusively resolved. These are jurisdiction-specific questions, not legal advice; rules and interpretations elsewhere may differ.
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What consumers and businesses can demand now
Because standards, implementation, and legal treatment are still developing, consumers and businesses should evaluate the actual authority and evidence a service offers rather than assume that an “agent payment” label guarantees a common level of protection. Ask for:
- A clear statement of the task and limits the agent is permitted to act within.
- A way to identify the agent and the authority it presented for a transaction.
- A record linking the instruction, authentication or intent evidence, decision, and payment outcome.
- Controls to inspect, amend, and revoke authority, including for recurring or multi-step tasks.
- An explanation of how a disputed, out-of-scope, erroneous, or fraudulent transaction is reviewed.
- Clarity about which participant handles each control and which jurisdiction’s rules apply.
As of the Bundesbank, EMVCo, Mastercard, Visa, and Bank of England materials available by October 7, 2026, the market remains early-stage and fragmented. Those sources do not establish an independent statistic for the current share of consumer payments made by AI agents, or independent effectiveness data for any one authorization design. The practical direction is clearer than the market outcome: bind bounded authority to verifiable identity and recorded intent, then preserve an audit trail from instruction to payment outcome.
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