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Agentic Commerce

The Agentic Commerce Opportunity and its Regulatory Compliance

By February 16, 2026August 10th, 2026No Comments

At the Mobey Forum in Munich, Andrea De Matteis and Christophe Zehnacker of Mastercard discussed what is required for agentic commerce to scale responsibly.

Key regulatory considerations

Authentication. Cardholder-initiated transactions can be designed to comply with strong customer authentication because the cardholder remains in session and authenticates the transaction. Autonomous agent-initiated transactions require further regulatory alignment, potentially by analogy with merchant-initiated transactions, with the agent’s mandate authenticated using SCA.

Liability and redress. Consumers should have practical remedies for both fraud and agent errors, including mandate breaches or inaccurate outputs. The allocation of liability among the issuer, merchant and agent will require careful consideration.

Transparency. Agents should clearly disclose sponsored results and other merchant incentives that may influence recommendations.

Open questions

  1. How should consumer rights against an agent be made operational in practice?
  2. Will agents favour a limited number of large merchants, increasing market concentration?
  3. How will responsibilities be allocated between agents and merchants?
  4. Will recommendations reflect the customer’s preferences or merchant referral fees?
  5. Which legal and policy tools could encourage access for small and medium-sized merchants?

The presentation is available below.