Elena asks an AI agent to register her for a conference in Amsterdam and arrange the trip for less than €1,500. It books the ticket and hotel, then adds a €299 annual travel subscription because the discount lowers the immediate cost.
The merchant is legitimate and strong customer authentication succeeds. Elena never intended to buy a year-long membership.
Was the payment authorised?
The dispute exposes the central problem in agentic payments. Software can search, negotiate and pay for a user. European law has no clean test for when an agent’s interpretation becomes a purchase the user never approved.
Agentic payments meet a legal system built for human intent
PSD2 treats a transaction as authorised when the payer has consented. Strong customer authentication and dynamic linking bind approval to a specific amount and payee.
Delegation breaks that sequence. The merchant, amount and rail may be unknown when the user instructs an agent. Authentication can prove who granted access without proving that a later purchase stayed within its purpose. Payee verification cannot verify intent.
Payment law speaks in binaries—authorised or unauthorised—while an AI agent works through probabilities and inferred preferences. A better checkout cannot close that gap.
Drawing a boundary between probability and finality
An IMF note by Sonja Davidovic and Hervé Tourpe offers a three-layer model. Intent and orchestration sit in the first layer, where the agent plans. Control and authorisation form the second: identity, mandates, budgets and compliance rules. Settlement remains in the third, where outcomes must be deterministic and final.
Agents are useful because they adapt to situations nobody specified. Payment rails are trusted because valid instructions produce predictable results. Probabilistic judgment must be contained before irreversible execution.
AP2 begins to build that bridge with signed mandates and verifiable credentials. Smart accounts can enforce caps, approved counterparties and approval triggers. Technical enforceability, however, does not make a mandate legally recognisable.
Stablecoins change the economics of machine commerce
The strongest case for stablecoins appears at the smallest end of the market. A card payment might cost around 1.5 per cent plus €0.25. If costs must remain below three per cent of the purchase, the fixed fee implies a minimum ticket above €8; including the percentage fee pushes it towards €17.
On a low-cost blockchain, the fee can fall to a fraction of a cent and a viable ticket to a few cents. That difference determines whether an agent can pay for one article, API call, data point or inference. Agent-to-service commerce needs money small enough for the service sold.
Physical goods present another equation. Cards bring decades of chargeback practice for missing products, misconduct and mistaken purchases. Stablecoin settlement is final by default. Escrow can add reversibility, but somebody must judge the claim, and specialised designs still need broad adoption.
The market may split accordingly: stablecoins for agent-to-service payments, cards for much of agent-to-merchant commerce until interoperable rules for reversibility emerge.
A mandate that can survive a dispute
In “Agentic Payments: When is a Payment (Un)Authorised?”, Nydia Remolina proposes a bounded delegated authorisation test. It starts with a legally recognisable mandate: precise enough to define authority, broad enough to leave the agent useful. “Find good-value products” states a preference; “buy office supplies from approved vendors up to €300 per order” establishes a boundary.
The mandate becomes a machine-readable envelope covering amounts, payees, categories, recurrence, geography, rails, expiry and approval triggers. Runtime conformity tests whether the execution path stayed inside it. Auditable proof records constraints, approvals, tool calls, policy versions and human overrides.
Remolina also proposes that a payment should be presumed unauthorised if the AI provider cannot produce the applicable constraints. The payer-facing PSP would reimburse the customer and seek recourse from the provider. A category of Digital Assistant Payment Services would give that responsibility a regulatory home.
Proof becomes a competitive capability
Banks and PSPs cannot treat agentic payments as a settlement experiment. The payer-facing institution will hear first when a customer challenges a machine-initiated purchase.
Institutions need to map their role, build an evidence chain, choose an approach to “Know Your Agent”, offer mandate dashboards and agree recourse with AI providers. Those terms are easier to negotiate before regulation or market power fixes the losses.
The money can move. The harder task is reconstructing why, under whose authority and within which limits. Europe’s winners in agentic payments may be the institutions that can answer those questions after the fact—not those with the most impressive agent at the point of sale.
Part 1 of BFRR’s agentic payments series with Sonja Davidovic
Part 2 of BFRR’s agentic payments series with Peter Grosskopf
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