0 · Why this exists
The agentic-commerce stack has settlement. It does not have identity, authorization, a record that accumulates, or credit. Visa and Mastercard ship agent credentials; Stripe and OpenAI ship the Agentic Commerce Protocol and keep the merchant as merchant of record; Google ships AP2 signed mandates and UCP; x402 has cleared ~150–200M payments but only tens of millions of dollars. Meanwhile regulators are writing the rulebook in real time: the IMF has moved the conversation from Know Your Customer to Know Your Agent, China published a KYA self-regulatory convention, PSD3 will formalise delegated payment initiation, and the EU AI Act's high-risk obligations land 2 Dec 2027 (Reg (EU) 2026/1744 pushed Annex III back from Aug 2 2026).
1 · What the decision model said
Scored with tev1:4b at /v1/systemone. Payload + raw response saved alongside the workspace for reproducibility.
Which market to lead
A1 KYA trust layer — 99.3%
Ceiling + $1M reach
Tier 1 — 89.5%
Squash risk in 24 months
0.42 — less likely than not
Moat a solo founder can defend
Distribution — 94.6%
Hardest UC to copy
UC-5 RECEIPT — 87.5%
Most revenue in 12 months
UC-1 VERIFY — 86.7%
2 · How these were scored
Weighted, out of 100. Same 5-axis pattern as M10 (SAT Prep Agent) so priorities are comparable across ideas.
3 · Who buys it
Dana Okonkwo — Head of Risk & Compliance
Mid-market marketplace or PSP, $50M-$500M processed volume
Buys: The receipt. Needs to prove to a card network, a regulator or an auditor that each agent-initiated action was authorized.
Pays from: Compliance budget + fraud-loss budget
Sam Reyes — Payments Operations Lead
Merchant or billing platform receiving agent-initiated orders
Buys: The API. Wants agent traffic to stop false-positiving in the fraud engine and to stop reaching support.
Pays from: Fraud-loss budget + engineering budget
Yuki Tanaka — Platform engineer, agent company
Shipping an AI agent that buys things for users
Buys: The agent-side SDK. Wants one call that makes their agent defensible to every receiving counterparty.
Pays from: Nothing at first — this is the distribution channel, not the revenue
Alex Moreau — End user whose mandate is enforced
Consumer who told their agent 'buy my groceries up to $200 a week'
Buys: Nothing. Beneficiary. Revocation and step-up exist for them.
Pays from: Nothing — reached via P1/P2 or via the agent platform
Lena Fischer — Dispute analyst
Merchant chargeback / fraud-resolution team
Buys: The evidence pack. This is the person who currently has no answer to give the issuer.
Pays from: Dispute budget. Fastest possible ROI per case won or refunded.
4 · Use-case map
Core use cases, scored out of 100 and assigned a build wave. Wave 1 is the first release; the long optional list follows in section 7.
| ID | Label | Use case | Primary buyer | Score | Build wave |
|---|---|---|---|---|---|
| UC-1 | VERIFY | Verify an incoming agent before the action executes | P2 Payments Ops / P1 Risk | 88 | Wave 1 |
| UC-2 | MANDATE | Check the action against the signed user mandate | P1 Risk / P5 Dispute analyst | 86 | Wave 1 |
| UC-3 | REGISTER | Register, attest, scope, expire and revoke agents | P1 Risk / P2 platform engineering | 80 | Wave 1 |
| UC-4 | STEP-UP | Step-up human confirmation above a threshold | P1 Risk / P4 End user | 78 | Wave 1 |
| UC-5 | RECEIPT | Produce the signed evidence pack | P1 Risk / P5 Dispute analyst / auditor / card network | 84 | Wave 1 |
| UC-6 | DISPUTE | Handle the case where the agent bought the wrong thing | P2 Payments Ops / P5 Dispute analyst / P4 End user | 75 | Wave 2 |
| UC-7 | RISK | Score agent traffic without false-positiving on it | P2 Payments Ops | 74 | Wave 2 |
| UC-8 | CHAIN | Handle delegated agent-to-agent chains | P1 Risk / P3 agent platform engineer | 70 | Wave 2 |
5 · The architecture this forces (the moat)
Morsy's call: the architecture is the moat. The use cases below are not independent features — they are the read-and-write surfaces of a single layered service. Drawn as five layers:
6 · Core use cases
8 core UCs. Each one is a read/write surface on the same core: register → verify → receipt.
Verify an incoming agent before the action executes
One call before money moves: is this a real agent, acting for a real person, allowed to do this? Return allow or deny plus a signed receipt.
Trigger → outcome
Trigger: An agent-initiated order, payment or API call lands on the receiving system
Outcome: Allow or deny decision plus signed receipt, before the money moves
Regulatory anchor
Visa Core Rules §4.1.24.3 (18 Apr 2026): the Agentic Payment Provider must obtain Cardholder consent for the Cardholder-defined payment instruction, clearly state its expiration date, obtain Cardholder acknowledgement that the Cardholder is responsible for the provider's actions, and verify the Cardholder's identity per the Visa Intelligent Commerce specification both before storing a credential and before acting on the payment instruction — retaining that information for the duration of the agreement. EU AI Act Art 12 (automatic event logging) + Art 14 (human oversight) — application deferred to 2 Dec 2027 by Regulation (EU) 2026/1744 (Digital Omnibus on AI, 8 Jul 2026), so this is a 2027-2028 deadline, not a 2026 one.
Competitive note
Beltic is closest (agent visibility + policy engine + intent intelligence, incl. MCP servers) but has no published pricing page and no mandate-citation output. Stripe explicitly does NOT verify agents — its agentic dispute and refund flows work 'without changes'.
Systems touched
- PSP / merchant API
- agent identity source
- mandate store
- policy engine
- receipt log
Integrations this forces
- Card-network agent credentials — Visa Trusted Agent Protocol, Mastercard Agent Pay / Agent Connect, Agent Pay for Machines (announced 10 Jun 2026, no availability date)
- AP2 signed mandates (Google; donated to FIDO Alliance 28 Apr 2026)
- KYA tokens (Skyfire) and Visa Intelligent Commerce purchase-intent mandates
- MCP 2026-07-28 authorization: OAuth 2.1, scope challenge, step-up authorization flow
- ACP / UCP checkout, x402 and MPP settlement envelopes
- Agent registry lookups: ERC-8004, SPIFFE, AAIF projects (agentgateway, Agent Router)
Main flow
verify(agent, principal, mandate, action, amount).allow with the receipt reference, step_up with the escalation channel, or deny with the failing clause — in under 100ms.Acceptance criteria
- Decision returned in under 100ms at p95 for a 99.9% availability target
- Every response carries a receipt id that resolves to an immutable record within 60 seconds
- The failing mandate clause and policy rule are named in every deny and every step-up
- A verify call works with no agent-side integration at all (credential-only path) — this is how a first merchant signs up
- Never returns 'allow' when the mandate is expired, revoked, or the amount exceeds the mandate cap
Edge cases
- Agent presents a valid credential for an unknown agent — deny or step_up, never allow
- Mandate exists but the agent instance is not the one the mandate was issued to — deny
- Clock skew between issuer and verifier makes a mandate look expired — fail closed, with a reason code
- The principal is a business, not a person — same checks, different principal type
- Agent-to-agent: the calling agent is itself a delegate — chain the checks, do not collapse them
- Merchant policy is empty (first day on the platform) — default to step_up above a threshold, not allow
Check the action against the signed user mandate
The exact clause of the user's instruction that authorized this purchase — cited, not inferred.
Trigger → outcome
Trigger: Verify returns a known agent and the action details still need scope evaluation
Outcome: Allow / deny / step-up, with the mandate clause that decided it
Regulatory anchor
Visa Core Rules §4.1.24.3 requires the expiration date of the Cardholder-defined payment instruction to be clearly stated, §4.1.24.4 requires the provider to use ONLY the Cardholder-defined criteria for purchasing, and §4.1.24.9 requires consent plus acknowledgement for Agentic Repeated Transactions. IMF's note pushes Know Your Customer to Know Your Agent with verifiable identities for financial bots linked to legal entities. China Payment & Clearing Association self-regulatory convention (24 Aug 2026) proposes a Know Your Agent hierarchical management system with full-link identity transmission.
Competitive note
t54 ships 'Authorization & Intent' with an intent-explanation challenge and agent-trace delta. Beltic ships a policy engine but no mandate-citation output. No vendor we verified publicly shows the mandate clause cited in the decision.
Systems touched
- mandate store
- policy engine
- action descriptor
- receipt log
Integrations this forces
- AP2 mandate schema and constraints (allowed payee, amount ceiling, recurrence, expiration)
- apruuv / M8 signed-mandate wallet as an upstream mandate source
- Apple and Google wallet consent receipts
- MCP OAuth token introspection and scope intersection
- Visa Intelligent Commerce purchase-intent mandate (decline thresholds)
Main flow
Acceptance criteria
- Every allow/deny names the mandate and the clause id that produced it
- Expiry, cap and recipient restrictions are enforced independently — passing one does not bypass the others
- Recurring mandates are re-evaluated per transaction, not cached as a blanket allow
- A mandate issued by one protocol can be evaluated even if the transaction arrives on another
Edge cases
- Two mandates both cover the action — use the most specific, log both
- Mandate covers the category but not the amount — step_up, not deny
- Mandate is scoped to a subscription and the action is a one-off top-up — clarify
- User revoked the mandate but the agent's credential is still live — deny, and trigger revocation of the credential
- Mandate text is ambiguous ('stuff for the house') — deny on ambiguity, escalate to the human
Register, attest, scope, expire and revoke agents
The agent's identity card: who built it, who runs it, what it may touch, and the switch to stop it.
Trigger → outcome
Trigger: A new agent vendor or a new agent instance appears in traffic
Outcome: The agent on the allow-list with a scope, an attestation, an expiry and a kill switch
Regulatory anchor
Visa Core Rules §4.1.24.1: an Agentic Payment Enabler must enroll in and comply with the Visa Intelligent Commerce program and register with Visa, contract with each Agentic Payment Provider, and hold the right to immediately terminate a provider for good cause, fraudulent activity, or upon Visa request. MAS Singapore 'Safeguards for Agentic Finance at Runtime' (3 Jul 2026) proposes an Agent Identity step before every action.
Competitive note
t54 ships a live graph of agents, owners and workloads and claims to catch identity rotation and environment shifts across sessions. Skyfire ships KYA identity plus an agent history track record. Beltic gives every agent an identity of its own. This is the most contested of the core set — and the least where we would lead.
Systems touched
- agent registry
- attestation store
- allow/deny list
- admin console
- webhook fan-out
Integrations this forces
- Agent-vendor onboarding: contract + scoped credential exchange
- Continuous attestation polling against the agent's declared runtime
- MCP server for agent-side self-registration
- AAIF agentgateway / Agent Router as registry integration points
- ERC-8004 agent registry and SPIFFE identities for federation
Main flow
Acceptance criteria
- Revocation propagates to every connected surface within 60 seconds
- An unregistered agent never gets a straight-through allow
- Scope changes require re-attestation, not just an admin click
- The registry answers 'who can touch this resource right now' in one query
Edge cases
- Same operator runs many agents — one registration, many scoped instances
- Agent rotates its credential mid-session — detect at verify, not at onboarding
- Vendor claims a different scope than the agent actually exercises — flag as drift
- Merchant wants agent X allowed but not agent X's sub-agent Y — scope must express delegation depth
Step-up human confirmation above a threshold
When software is about to do something a human would think twice about, a human says yes — and the yes is recorded.
Trigger → outcome
Trigger: Action exceeds an amount, hits a new recipient, changes contact details, or the mandate is ambiguous
Outcome: Human confirms in person, or the action is dropped — and the confirmation is recorded
Regulatory anchor
EU AI Act Art 14 requires human oversight mechanisms that allow intervention and interruption for high-risk systems (applies from 2 Dec 2027 for Annex III systems, per Regulation (EU) 2026/1744). Visa Core Rules §4.1.24.6 requires Cardholder consent or acknowledgement for limited cancellation/refund policies, delayed charges, estimated amounts and upsells before the transaction completes. PSD3/PSR will force Strong Customer Authentication for autonomous agents (not yet in the Official Journal as of 23 Oct 2026).
Competitive note
Beltic reports 5% of actions routed to step-up against 86% straight-through — the mechanics are shipped. t54 ships a challenge flow. This is table stakes, not a differentiator; we ship it because the receipt is worthless without it.
Systems touched
- step-up orchestrator
- push / SMS / voice channel
- mandate store
- receipt log
Integrations this forces
- apruuv / M8 phone approval surface (iOS, push, Face ID)
- Bank push and card 3-D Secure step-up
- Voice OTP or contact-centre fallback for the no-smartphone case
Main flow
Acceptance criteria
- A step-up without a recorded human decision can never result in an allow
- Timeout always denies and always records
- The principal can see what is being asked for and on which device
- The recorded proof is sufficient to satisfy a dispute, not just an audit
Edge cases
- Principal unreachable (travelling, no signal) — deny, or hold under an explicit merchant rule
- Principal is a business entity with a 4-eyes policy — require two approvers
- Agent asks repeatedly to trigger step-up — rate-limit the agent, not the human
- Human approves but the amount changed between render and confirm — re-verify
Produce the signed evidence pack
One artifact that answers: who the agent is, who it acts for, what mandate allowed it, what it did — and proves none of it was altered.
Trigger → outcome
Trigger: Dispute, chargeback, regulator examination or internal audit
Outcome: One signed, tamper-evident pack, exportable in the format the counterparty accepts
Regulatory anchor
Visa Core Rules §4.1.24.3: the Agentic Payment Provider must retain the consent and payment-instruction information for the duration of the agreement and provide it to the Cardholder or Issuer upon written request. §4.1.24.8: an order confirmation must remain available to the Cardholder for at least 120 days from the Processing Date. Dispute Condition 10.4 accepts the agent-platform login ID as a CE data element, in clear text and unhashed. EU AI Act Art 12 automatic logging over the system lifetime; deployer retention baseline of at least six months (Art 19 / Art 26(6)). NOTE: Chapter III Sections 1-3 apply from 2 Dec 2027 (Annex III) per Regulation (EU) 2026/1744 — the requirement is live, the deadline is not 2026.
Competitive note
t54 ships 'signed, replayable evidence record' and a tamper-evident compliance audit chain. Beltic ships 'a signed record of who really acted'. So the artifact itself is NOT unique — but no verified vendor shows the export format a merchant's dispute analyst hands to Visa. The export and the cross-vendor federation around it are the open ground.
Systems touched
- receipt log
- hash chain
- evidence pack builder
- retention store
Integrations this forces
- Object storage with immutability / WORM
- E-signature or third-party attestation service
- Visa CE 3.0 data elements — including the Agentic Payment Provider login ID in clear text, which Visa's rules explicitly accept for 10.4 disputes
- EU AI Act Art 12 event log export, Art 11 technical documentation, Art 49 registration
Main flow
Acceptance criteria
- Any single field can be proven unaltered without trusting the platform that produced it
- Pack renders in the Visa CE 3.0 element set, including the agent-platform login ID in clear text
- Retention honours the longest applicable obligation: Visa's duration-of-agreement rule, 120-day order confirmation, EU AI Act logging baseline
- A pack for a transaction with no mandate still renders and states plainly that no mandate existed
Edge cases
- Mandate was revoked after the transaction — the pack must show both states
- Agent rotated identity mid-flow — the chain shows both agent ids
- Two merchants share a principal — packs must not leak each other's data
- Examiner wants raw logs, not a summary — export both
Handle the case where the agent bought the wrong thing
No human clicked buy. So who disputes, on what evidence, on which rail — and who pays.
Trigger → outcome
Trigger: "My agent ordered the wrong thing" — a charge with no human in the loop
Outcome: A dispute that names the machine, attaches the evidence, and resolves on the rail it arrived on
Regulatory anchor
Visa rules keep the merchant as the party that must answer: §5.4.3 requires the Merchant to comply with §4.1.24.6 for Agentic Transactions and states a Merchant must not require a Cardholder to waive the right to dispute an Agentic Transaction with the Issuer. FATF Travel Rule applies to agent-to-agent transfers. ACI Worldwide notes mandate-based authorization is 'currently untested in courts and before regulators'.
Competitive note
Natural states it 'mediates all disputes for you' — but for payments Natural itself processes. Stripe's agentic refunds and disputes reuse the existing flow unchanged. t54 ships evidence + dispute + chargeback. No one has solved the case where the loss lands on a merchant whose acquirer has no agent-dispute rule yet.
Systems touched
- dispute workflow
- receipt log
- rail adapters (card / ACH / stablecoin)
- refund engine
Integrations this forces
- Visa and Mastercard dispute APIs
- ACH and stored-credit rails
- Stablecoin rails (x402, MPP) — note x402 v2 has no refund or dispute flow at all
- Merchant support tooling and the cardholder-facing order confirmation
Main flow
Acceptance criteria
- Every agent-initiated charge can be identified as agent-initiated without the issuer telling us
- A 10.4 representation built from our pack is accepted at least as often as one built from shipping proof
- Refund decisions happen inside the issuer's response window, not after it
- The dispute outcome updates the agent's risk profile automatically
Edge cases
- Agent bought inside a genuine mandate and the user is simply unhappy — no published network rule fits; this is the unresolved case
- The merchant never stored the agent's login ID — CE 3.0 data element is missing, dispute is lost
- The agent was compromised rather than mis-scoped — liability is unresolved between issuer, acquirer and agent operator
- The transaction settled on a stablecoin rail with no dispute path — nothing to appeal to
Score agent traffic without false-positiving on it
Ten thousand agents from one datacentre look exactly like fraud. Change the features, not the thresholds.
Trigger → outcome
Trigger: Agent traffic hits the merchant's existing fraud engine
Outcome: A risk score that understands agent patterns instead of flagging them
Regulatory anchor
EU AI Act Art 9 (continuous risk management), Art 15 (accuracy, robustness, cybersecurity) apply to high-risk fraud-scoring systems, from 2 Dec 2027 (Annex III, per Regulation (EU) 2026/1744); ACPR in France already inspects AI in banking. Mastercard's Sept 2026 agent-detection probability score is the network's answer to the same problem.
Competitive note
Mastercard ships an AI-initiated transaction probability score for US testing and a shared intelligence layer with Cloudflare. t54 ships a validator-panel risk decision with confidence score. Adyen publishes a knowledge-hub piece on why traditional fraud detection was not built for AI agents. This is a race we enter third.
Systems touched
- risk engine
- agent traffic features
- case queue
- decision log
Integrations this forces
- PSP fraud APIs (Stripe Radar, Sift, Sardine)
- Chargeback and fraud-outcome feedback feeds
- Device and IP attestation — the signals that invert when the buyer is software
Main flow
Acceptance criteria
- Agent traffic false-positive rate falls materially versus the merchant's existing engine
- The score is explainable in one line for a dispute analyst
- Score inputs are captured on the receipt so the decision can be re-derived later
- Human traffic scoring is unchanged — no regression for the 99% of volume that is not agent traffic
Edge cases
- A compromised agent produces perfectly normal agent-shaped traffic — the risk must sit elsewhere
- Merchant has almost no agent volume — the model is not trainable, use rules only
- Two agents share an IP and device fingerprint — fingerprint is meaningless for agents
Handle delegated agent-to-agent chains
Agent A called agent B. Scope resets at every handoff unless we say otherwise.
Trigger → outcome
Trigger: Agent A calls agent B to complete the user's task
Outcome: Scope, liability and re-verification are explicit at every handoff, with a cap on total chain spend
Regulatory anchor
MetaComp's StableX KYA framework extends the FATF Travel Rule to agent-to-agent transactions. Visa's definition of an Agentic Transaction requires that it be based on the Cardholder-defined payment instruction, which a delegated chain can obscure. IETF ATXN (Apr 2026) is the emerging transaction-definition protocol for agent-to-agent.
Competitive note
t54 lists A2A and x402 messaging among supported protocols and says each handoff is a delegation event where risk and assumptions reset. Beltic's CEO states the same principle. Nobody publicly ships a total chain-spend cap with per-hop re-verification.
Systems touched
- chain graph
- scope propagation
- receipt log
Integrations this forces
- MCP tool-call layer
- Agent-to-agent protocols: A2A (AAIF), IETF draft-stone-atxn (ATXN), x402 A2A messaging
- Recursive attestation resolution
Main flow
Acceptance criteria
- A chain deeper than the merchant's policy allows is refused before the final action
- The chain-level cap cannot be bypassed by splitting spend across hops
- Every hop is independently attributable in the receipt
- A delegation that cannot be resolved to a principal is denied
Edge cases
- A hop uses a protocol we do not parse — the chain is unverifiable, deny or step_up
- The chain exceeds a maximum depth — refuse, do not truncate silently
- The intermediate agent is operated by a third party — liability splits are visible in the receipt
- An intermediate agent caches a credential and replays it — replay detection on every hop
7 · Optional use cases — the long list
58 candidates across 7 groups. Scored on the same rubric; anything scoring under ~55 is a candidate, not a commitment. Several are marked NOT core because a competitor already ships them, because they need a buyer we do not have, or because they belong to apruuv (M8) rather than to this company.
Agent identity & lifecycle
| ID | Optional use case | Who wants it | Why it has value | Why it is NOT core | Score |
|---|---|---|---|---|---|
| OPT-A1 | Agent census — inventory every agent that touches our systems | P1 Risk / platform engineering | Know your exposure: which agents, which vendors, which volumes | No external demand yet; internal tool | 48 |
| OPT-A2 | Resolve one agent's many identities across protocols | P1 Risk / integrations engineer | KYA token, AP2 mandate, SPIFFE ID, x402 key, ERC-8004 registry entry all point at the same agent | Only pays off at scale; depends on protocol convergence | 45 |
| OPT-A3 | Bind an agent to a verified principal (person or business) | P1 Risk / KYC team | The anchor that makes every downstream record meaningful | Baselayer already does business identity for 2,300+ FIs — we consume, we do not compete | 52 |
| OPT-A4 | Agent runtime attestation — prove which model, tools and guardrails are live | P1 Risk / model governance | Distinguishes a sanctioned agent from a jailbroken one | Requires runtime hooks into agent frameworks we do not control | 50 |
| OPT-A5 | Continuous attestation monitoring and drift detection | P1 Risk | Catches an agent whose scope or behaviour changed after onboarding | Needs deep agent-side instrumentation | 47 |
| OPT-A6 | Third-party agent vendor due diligence | P1 Risk / procurement | Score the operator of the agent, not just the agent | Slow, research-shaped, hard to sell self-serve | 38 |
| OPT-A7 | Agent credential issuance, rotation and short-lived tokens | P2 Payments Ops | Credentials that expire, so a leaked key stops mattering | Card networks and PSPs already issue scoped tokens | 44 |
| OPT-A8 | Emergency kill switch — stop one agent, one vendor, or all agent traffic | P1 Risk / incident response | The reflex you need at 2am when an agent misbehaves | Feature-shaped, but cheap and trust-building | 58 |
| OPT-A9 | Agent operator reputation score across merchants | P1 Risk | Network effect: the more merchants use it, the better the score | Needs critical mass; a chicken-and-egg problem | 42 |
Mandate & consent
| ID | Optional use case | Who wants it | Why it has value | Why it is NOT core | Score |
|---|---|---|---|---|---|
| OPT-B1 | Mandate issuance — a user grants an agent a scope in one tap | P4 end user via agent app or apruuv | The upstream source of every mandate we later verify | That is apruuv / M8's job. Our job is verifying what it issues | 55 |
| OPT-B2 | Mandate store with versioning, expiry and revocation | P1 Risk | The system of record we sell on top of | Only valuable once mandates actually exist in the wild | 51 |
| OPT-B3 | Scope algebra — compose and intersect multiple mandates | P1 Risk | Least privilege across agent, merchant policy and user grant | Engineering-heavy, no buyer asks for it yet | 40 |
| OPT-B4 | Mandate translation between protocols (AP2 → internal → ACP → MPP) | P2 Payments Ops | Nobody has a mandate format that all five protocols speak | Protocol churn; translation is a maintenance tax | 43 |
| OPT-B5 | Signed consent via wallet (eIDAS 2.0 / W3C VC) | P1 Risk / legal | Consent that survives a court and a regulator | Enterprise integration burden, slow cycles | 41 |
| OPT-B6 | Intent vs instruction — separate what the user wanted from what the agent was told | P1 Risk / disputes | The exact contested fact in an agent dispute | Needs agent-side telemetry we do not own | 46 |
| OPT-B7 | Hard spend caps and category restrictions on the mandate | P2 Payments Ops | 'Up to $200 a week at this grocer' enforced at transaction time | Natural feature of UC-2 mandate check | 53 |
| OPT-B8 | Time-window and expiry enforcement | P1 Risk | A mandate that expires stops being a liability | Part of UC-2 | 54 |
| OPT-B9 | Counterparty allow-list — which merchants this agent may use | P2 Payments Ops | Blocks the compromised-agent case | Part of UC-2 | 52 |
| OPT-B10 | Consent evidence for privacy law (GDPR / CCPA) — was the agent authorised to share data | P1 Risk / DPO | A second, separate record from the payment mandate | Different buyer, different regulation; expands scope | 36 |
Transaction-time decisions
| ID | Optional use case | Who wants it | Why it has value | Why it is NOT core | Score |
|---|---|---|---|---|---|
| OPT-C1 | Pre-action verify call (the API itself) | P2 Payments Ops | One call before money moves | This IS UC-1 | 88 |
| OPT-C2 | Post-action reconcile — match the request to what actually settled | P2 Payments Ops | Closes the gap between intent and settlement | Needs per-rail integrations | 60 |
| OPT-C3 | Agent-aware fraud features — velocity, geo and device signals that invert for agents | P2 Payments Ops | Stops good agent traffic false-positiving | That is UC-7 | 74 |
| OPT-C4 | Step-up orchestration across channels (push, SMS, voice, 3DS) | P1 Risk | One integration instead of four | That is UC-4 | 78 |
| OPT-C5 | Duplicate and replay detection for retried agent calls | P2 Payments Ops | Agents retry hard; humans do not | Infrastructure, not a use case a buyer buys | 49 |
| OPT-C6 | Liability routing — decide which party bears the loss before the transaction | P1 Risk / legal | Prevents the 'whose fault' fight from becoming a 9-month dispute | Needs a rulebook we would be inventing | 57 |
| OPT-C7 | Automated refund and rollback for agent purchases | P2 Payments Ops | Speed of refund is what agent users actually notice | Feature-shaped; refunds are already a merchant process | 56 |
| OPT-C8 | Merchant policy engine as code | P2 Payments Ops / platform | Policies versioned, testable, diffable | Developer-facing, small buyer | 50 |
| OPT-C9 | Agent traffic dashboard — what agents are buying, from whom, at what scope | P1 Risk | The operational view that makes the whole thing usable | Bundled with the platform, not sold alone | 59 |
| OPT-C10 | Cost attribution per agent, per team, per customer | P1 Risk / FinOps | Who pays for the agent's mistakes, and who benefits | Adjacent to the existing agent FinOps category (SpendOS, Tarmac, KazenAI) | 45 |
Evidence, audit, compliance
| ID | Optional use case | Who wants it | Why it has value | Why it is NOT core | Score |
|---|---|---|---|---|---|
| OPT-D1 | Tamper-evident receipt log with hash chain | P1 Risk | Makes the record worth something in court | That is the core of UC-5 | 84 |
| OPT-D2 | Dispute evidence pack export (Visa CE 3.0 data elements, incl. agent-platform login ID in clear text) | P2 Payments Ops | Win or lose a 10.4 dispute on mandate evidence | That is UC-5 plus UC-6 | 82 |
| OPT-D3 | Regulator examination export (EU AI Act Art 12 + Art 49, from 2 Dec 2027) | P1 Risk / compliance | Answer the examiner in hours, not weeks | That is UC-5 | 83 |
| OPT-D4 | Retention policy engine — keep what the law requires, delete what it does not | P1 Risk / DPO | Retention is a legal obligation and a cost line | Table stakes inside the platform | 61 |
| OPT-D5 | EU AI Act conformity documentation service (Art 11) | P1 Risk / compliance | A required document set the client must produce | Consultancy-shaped, deadline-shaped, Big 4 will sell it too | 54 |
| OPT-D6 | Risk-management system as a service (Art 9) | P1 Risk | A required continuous process, not a document | Deep consulting engagement; not self-serve | 49 |
| OPT-D7 | Human-oversight register (Art 14) — every time a human could and did intervene | P1 Risk / compliance | Proves oversight was real, not theoretical | Only meaningful if step-up volume exists | 58 |
| OPT-D8 | ML-BOM / model provenance attestation for agents | P1 Risk / model governance | Knows whether a sanctioned model ran the action | Hard, and only three platforms can really attest | 47 |
| OPT-D9 | Chain audit trail — a complete delegated lineage | P1 Risk | Who delegated to whom, with what scope, at each hop | That is UC-8 | 70 |
| OPT-D10 | PSD3 / SCA readiness report for autonomous agents | P1 Risk / bank compliance | Prepares for a rule that is not fully in force yet | Binding date uncertain — Council first-reading position published 21 Oct 2026, not yet in the Official Journal | 51 |
| OPT-D11 | SOC 2 Type II and ISO 27001 evidence pipeline | P2 Payments Ops / procurement | Table stakes for selling to any mid-market buyer | Certification is a cost, not a use case | 60 |
| OPT-D12 | Independent attestation of our own receipts (third-party notary service) | P1 Risk / legal | Makes our evidence credible when the counterparty does not trust us | Strong moat idea, but needs a notary partner we do not have yet | 62 |
Agent-side (distribution)
| ID | Optional use case | Who wants it | Why it has value | Why it is NOT core | Score |
|---|---|---|---|---|---|
| OPT-E1 | Free verification SDK for agent builders | P3 agent platform engineer | Makes us the default check inside the agent stack | Free by design — this is the distribution channel, not revenue | 79 |
| OPT-E2 | MCP server exposing verify() to any agent | P3 agent platform engineer | One install, every agent | Free by design | 77 |
| OPT-E3 | Agent-side compliance score badge — 'this agent is verified' | P3 agent platform engineer | Distribution plus marketing; drives receiving-side demand | Free by design | 66 |
| OPT-E4 | Self-service agent onboarding portal | P3 agent platform engineer | Agent registers itself, gets a scoped credential | Free tier of UC-3 | 63 |
| OPT-E5 | Merchant-side agent catalogue — which agents are approved to buy from us | P1 Risk / merchandising | Turns agent traffic into a curated channel | Only works once merchants have traffic to allocate | 44 |
Merchant readiness
| ID | Optional use case | Who wants it | Why it has value | Why it is NOT core | Score |
|---|---|---|---|---|---|
| OPT-F1 | Catalog legibility for agents — structured product data agents can parse | P2 Payments Ops / e-commerce manager | 'Most catalogs are invisible to shopping agents' | Feature-shaped, and Shopify ships it free to its own merchants | 55 |
| OPT-F2 | Machine-readable policy — returns, warranty, restrictions as data | P2 Payments Ops | The agent cannot guess our policy; it must read it | Same bundling risk as F1 | 52 |
| OPT-F3 | Agent-referred traffic attribution and analytics | P2 Payments Ops / growth | Prove agents are a channel, not a threat | Analytics is easy to copy | 50 |
| OPT-F4 | Agent-specific merchandising — control what agents can see and at what price | P2 Payments Ops / merchandising | New capability with no incumbent | Needs catalog depth we do not have | 46 |
| OPT-F5 | Agent-checkout endpoint conformance testing | P2 Payments Ops | A test suite that says 'your checkout is agent-ready' | Nice, small, and copyable by a test-suite vendor | 43 |
Later / adjacent
| ID | Optional use case | Who wants it | Why it has value | Why it is NOT core | Score |
|---|---|---|---|---|---|
| OPT-G1 | Credit and underwriting for agent-initiated purchases | P2 Payments Ops / risk | Agents have no credit history; the merchant carries the risk | Regulated, capital-heavy, wrong shape for us now | 34 |
| OPT-G2 | Agent purchase insurance / indemnity | P1 Risk / treasury | Transfer the residual liability we cannot eliminate | Needs a balance sheet | 31 |
| OPT-G3 | Dispute arbitration between agent operator and merchant | P1 Risk / legal | The 'who pays' question needs a forum | Two-sided network, very slow to start | 37 |
| OPT-G4 | Cross-border agent payment compliance (VARA / ADGM / MiCA) | P1 Risk / treasury | Stablecoin agent rails are moving faster than the rulebook | Jurisdiction-by-jurisdiction | 35 |
| OPT-G5 | AML / sanctions screening of the agent's principal | P1 Risk / financial crime | Complements KYC for software actors | Baselayer's home turf | 33 |
| OPT-G6 | White-label the verification layer to card networks and PSPs | P1 Risk at a network | Distribution at scale, no sales team needed | Needs protocol-level credibility first — and Mastercard has already picked Skyfire for this | 53 |
| OPT-G7 | Public agent-verification registry other markets can query | P1 Risk / ecosystem | Network effect and a standard-setting play | Only credible once several vendors adopt it | 45 |
8 · Competitive landscape
Verified against vendor sites on 2026-10-23, not press summaries. This is the uncomfortable part of the document.
| Player | What they actually ship | Claims | Threat to us |
|---|---|---|---|
| t54 Trustline $5M seed, Ripple-backed (Jun 2026) | KYA graph of agents/owners/workloads; Authorization & Intent challenge with intent explanation and agent-trace delta; validator-panel risk decision with confidence score; tamper-evident compliance audit chain; signed replayable evidence record for disputes and chargebacks; A2A / x402 / MCP / AP2 / ACP / Visa TAP / Skyfire KYAPay integration; Agentic Risk Standard underwriting; x402-Secure as a hosted service | 20M+ agent transactions analyzed, 41,000+ agents KYA'd, 97.6% approval rate, <5s decision latency | HIGHEST. Covers 5 of our 8 core UCs including the receipt and the dispute module. But positioned at 'institutional finance' — issuers, funds, institutional desks — not the mid-market merchant receiving side. |
| Beltic $8.8M seed led by Norwest + $1.5M pre-seed (30 Sep 2026) | Agent identity of its own per agent; operator and origin on every request; live traffic on websites, APIs and MCP servers; a signed record of who acted; policy engine with business-specific rules; intent intelligence that reads the intent behind searching/ordering/paying | 86% straight-through allow, 5% step-up over 14 days; no public pricing (404 on /pricing) | HIGH. Closest to the receiving-side wedge — but no published pricing, no mandate-citation output, no dispute workflow, no rail adapters. |
| Ralio £2.1M / $2.5M pre-seed led by SVV, with SeedX, Antler, Plug and Play (2026) | Rail-agnostic safety layer between agents and payment rails — FPS/BACS/SEPA, Visa/Mastercard/Amex, stablecoins, own wallet; per-workflow spend rules; approvals; confidence thresholds; allowlisted recipients; full audit trail tying payment to agent, prompt, policy and outcome; sells both sides (agent SDK and a control dashboard for receiving platforms) | ISO 27001 and SOC 2 in progress | HIGH on the payer side, MODERATE on the receiving side — Ralio sits between the agent and the rail, we sit between the merchant and the decision. |
| Natural $30M Series A led by Forerunner, 20 Jul 2026 — 193 days after founding | Agent-first payment primitives: FDIC-insured accounts up to $200M, transfers, cards and credit, processing, billing; stable agent identities tied to a verifiable legal identity; full agent observability on every payment; mediates disputes; MCP, CLI, SDK and API | Backed by Forerunner, Mercury, Brex, Y Combinator, Vercel and others | HIGHEST CAPITAL. If it owns the wallet it can own the identity and the dispute. But its centre of gravity is moving money, not proving decisions. |
| Skyfire $11M seed (Apr 2026, reported) | KYA identity tokens ('kya', 'kya-pay') that disclose only the required fields; KYAPay settlement across cards, ACH, wires and USDC; agent history as a verifiable track record; budgets and per-agent limits; IETF KYAPay profile draft | MASTERCARD NAMED SKYFIRE AS ITS KYA PARTNER in the Agent Pay Trust Framework announcement (30 Sep 2026) | HIGH. Already has the network's endorsement. Also the most protocol-native of the set. |
| Baselayer / Osiris Ratings $35M Series A led by M13 (4 Oct 2026) | Agentic Identity Suite built on 'Know Your Agent'; cryptographic traceability of agent actions to the deploying platform and the authorising business; MCP server and Agentic Search tool; Counterparty Verification so agents can check who they are buying from | Business identity used by 2,300+ financial institutions including 1 in 5 US banks; 10M+ applications reviewed; $1B+ fraud prevented | MODERATE-HIGH on identity, LOW on the merchant-side receipt and dispute. Deep incumbent relationships we do not have. |
| Stripe n/a | ACP (with OpenAI), Shared Payment Tokens, Machine Payments / MPP with Tempo, x402 stablecoin support, agentic checkout for sellers, manual capture, refunds and disputes — and explicitly does NOT verify agents: existing refund and dispute flows work without changes | n/a | THE SQUASH RISK. If Stripe decides to verify, it bundles. Our defence is that our record spans merchants and vendors, not just Stripe's rails. |
| Mastercard + Cloudflare n/a | Agent Pay Trust Framework: identity, intent, controls, execution, intelligence; an AI-initiated-transaction probability score in US testing; a shared intelligence layer for risk signals; privacy-preserving environments with Cloudflare | 1 in 10 consumers projected to routinely use agents to purchase by 2030 | HIGH and rising. They are building the risk layer we scored UC-7 on. |
| Visa n/a | Intelligent Commerce: Trusted Agent Protocol with Cloudflare; purchase-intent mandates with decline thresholds; the 18 Apr 2026 rules that define Agentic Payment Providers and require consent, expiry disclosure, identity verification, retention for the agreement's duration, and a 120-day order confirmation | 'Hundreds' of agent transactions as of Dec 2025 — no published volume since | HIGH. Visa is writing the rules we must satisfy. We are a compliance supplier to them, which is a real business and a real dependency. |
| Basis Theory $33M Series B led by Costanoa (14 Oct 2025); ~$50M total; Bessemer, Kindred, Box Group, Offline Ventures | PCI-compliant payment vault that runs independently of any processor; basistheory.ai unified platform for agentic commerce (launched Jun 2025); agents can initiate, approve and manage transactions inside a PCI-compliant environment; LEDS the Agentic Commerce Consortium (20+ companies defining standards for agent-led commerce) | Customers incl. Pinterest, Melio, MoneyGram; PCI Level 1, SOC 2, developer-first API, zero lock-in | HIGH and structural. This is the merchant-side control plane for agentic payments, plus it is running the standards body. If Basis Theory defines the consortium's agent authorization format, we are downstream of it. |
| Trustap $10M led by Aperture Capital (10 Jun 2026); ~$19.7M total | Trustap Index — makes marketplace and ecommerce listings structured, discoverable and transactable by AI shopping agents; API into existing marketplace transaction infrastructure; full transaction layer from payment processing to dispute resolution; human confirms each transaction before funds release | Cork-based, founded 2017; hundreds of transactions annually across ecommerce, p2p and marketplaces | MODERATE-HIGH. They already own the dispute-resolution piece for marketplaces — which is our UC-6 white space. Their weakness: dispute resolution is on THEIR rails, not across the ecosystem. |
| Okta Agent SSO / Cross App Access n/a (Okta public) | Agent SSO GA 24 Aug 2026 — registers agents as first-class identities via the open Cross App Access protocol, replacing static API keys with identity-governed short-lived tokens; admins register an agent as a workload principal and connect it to XAA-enabled OIN apps, SAML or OIDC (30 Sep 2026); Cross App Access introduced Jun 2025 | Every agent it touches becomes a first-class identity; no re-registration needed when upgrading to Okta for AI Agents | HIGH. This is the enterprise identity incumbent shipping agent identity natively, and it is where agent 'first-class identity' as a phrase is being set. But it is workforce/enterprise IdP — not the merchant-side receipt, and not the agent-vs-principal mandate model. |
| Palo Alto Networks (CyberArk) $25B acquisition of CyberArk completed 11 Feb 2026 | CyberArk machine-identity and privileged-access management folded into the Palo Alto platform; machine identities are the same primitive as agent identities, with secrets management, least privilege and audit already built and sold into every large enterprise | Positioned explicitly to 'secure the AI era' | HIGH. This is the incumbent most able to bundle agent authorization into an existing enterprise contract. It is the reason agent identity alone is not a moat. |
| ERC-8004 (Trustless Agents) n/a — Ethereum standard; authors incl. Marco De Rossi (MetaMask), Davide Crapis (Ethereum), Jordan Ellis (Google) | Registry and reputation system for agents: discover agents, establish trust through reputation and validation; on-chain identity records for agents | Emerging open standard for agent identity and reputation | LOW direct, HIGH strategic. If agent identity standardises on-chain, our federation layer (OPT-A2) becomes a bridge between a wallet identity and a compliance record — which is more valuable, not less. |
| Agentic Commerce Consortium n/a — consortium led by Basis Theory, 20+ companies | A standards body defining the standards and infrastructure that let AI agents become trusted buyers, with a white paper for merchants | Explicitly 'giving merchants the ability to opt into agentic commerce in a secure, controlled manner' | HIGH. If the consortium defines the merchant-facing agent authorization format, our receipt schema must interoperate with it — or be replaced by it. Partnership target, not an enemy, but it sets the spec we must live inside. |
| Nekuda cumulative ~$5M backing | Secure infrastructure for AI-driven purchasing agents; listed among protocols supported by t54 Trustline | UNVERIFIED beyond funding reports and the t54 integration list | LOW-MODERATE. Appears to be a credential/identity layer for purchasing agents — adjacent to UC-1. |
White space — what nobody ships today
A merchant-facing evidence artifact with an EXPORT a dispute analyst hands to the issuer — Visa CE 3.0 element set, EU AI Act examiner export, and a plain-language cardholder summary
Why open: t54 and Beltic ship a signed record, but neither publicly shows a counterparty-format export; the Agentic Commerce Consortium is writing standards for the authorization format but not for the dispute-evidence format
Defensibility: STRUCTURAL — the export schema becomes the contract, and it must interoperate with whatever the Consortium defines
A merchant-facing evidence artifact with an EXPORT a dispute analyst hands to the issuer — Visa CE 3.0 element set, EU AI Act examiner export, and a plain-language cardholder summary
Why open: t54 and Beltic both ship a signed record, but neither publicly shows a counterparty-format export or cross-vendor federation
Defensibility: STRUCTURAL — the export schema becomes the contract
Federated identity resolution across KYA token, AP2 mandate, SPIFFE, ERC-8004 and A2A — one agent, many credentials
Why open: Every vendor has one credential model; no one publicly resolves across them
Defensibility: STRUCTURAL — becomes a de-facto standard if we ship it as an open spec
The merchant-side dispute workflow for agent transactions where no network rule yet exists
Why open: No card network has published an agent-specific dispute rule; x402 v2 has no refund or dispute flow at all
Defensibility: STRUCTURAL — owns the precedent, and the precedent is what gets cited
Chain-level total spend cap with per-hop re-verification
Why open: t54 and Beltic both name the delegation-reset problem in marketing; neither publicly ships a chain-level cap
Defensibility: STRUCTURAL
Liability pre-allocation before the transaction, not after the dispute
Why open: t54 does post-hoc underwriting; nobody pre-assigns
Defensibility: WORKFLOW — becomes sticky once contracts reference it
Bundle-able within 24 months
- Verify-the-agent as a single API call — Stripe, Visa, Mastercard or CyberArk can ship this inside their existing surface
- Agent-aware fraud scoring — Mastercard is already shipping a probability score
- Registry and attestation — t54, Skyfire and Baselayer all ship it
- Catalog legibility and machine-readable policy — Shopify ships it free to its own merchants
- First-class agent identity inside the enterprise IdP — Okta Agent SSO already shipped it (GA 24 Aug 2026)
- Machine-identity and least-privilege enforcement — Palo Alto/CyberArk already own the enterprise contract
- The consortium's agent-authorization format — Basis Theory is leading that standards body
NOT bundle-able
- A cross-vendor evidence record that includes another vendor's agent and another network's mandate
- The dispute precedent and the format the counterparty accepts
- The chain-level cap across vendors' agents
- The compounding dataset of real agent decisions across the ecosystem
- Interoperating with a standards body we do not control — the Consortium's format is dictated, not discovered
9 · Risks and the kill criteria
Structural risks
- Feature-shaped. CyberArk/Palo Alto, Stripe, Visa, Mastercard and Google can each ship a verification call. If they do, our defensible surface shrinks to the receipt and the dispute layer.
- No dispute rule yet. Neither card network has published an agent-specific dispute rule, so the rules the product exists to satisfy are still being written.
- Untested in court. ACI Worldwide calls mandate-based authorization "currently untested in courts and before regulators". A receipt is only worth what a court gives it.
- Merchant of record stays with the merchant. Under ACP the merchant keeps settlement, refunds, chargebacks and compliance. That is our customer — and our liability.
Kill criteria
- 30 named accounts approached, 0 paid pilots by day 60 → wrong buyer.
- Every buyer demands on-prem or bespoke implementation → wrong price point.
- Visa/Mastercard/Stripe ship a free bundled equivalent covering verification → pivot to the dispute and evidence layer where they are weak.
- No mandate format stabilises by mid-2027 → the mandate layer cannot be built on sand; pivot to the receipt as the primary product.
9.5 · SOTA scan — last 6 months (Apr–Oct 2026)
| Date | Development |
|---|---|
| 2026-09-10 | Visa + Mastercard + Ant International announce joint KYA interoperability framework Shared principles for agent onboarding/identification across networks; each network keeps its own verification & decisioning. Reuters + Ant PR. McKinsey $3-5T agent-orchestrated consumer commerce by 2030 cited by all three. |
| 2026-08-18 | Agentic Payments Alliance (APA) launched by Rain 26 founding orgs incl Visa, Mastercard, Circle, Solana, Avalanche, Fiserv, Fireblocks, Chainalysis, Uniswap Labs. Scope: how AI agents get AUTHORIZED to spend (authorization, identity verification, disputes listed in coverage). |
| 2026-10-01 | Mastercard extends Agent Pay with trust & intelligence US-testing probability score: how likely a tx was agent-initiated; trust/intelligence signals for issuers (pattern match, needs-look, proceed-or-check). Identity side via Skyfire (KYA provider), data side with Cloudflare. |
| 2026-10-03 | 8 live agentic protocols mapped — stacking, not competing MCP (Anthropic), A2A (Google), ACP (OpenAI/Stripe), UCP (Google/Shopify + Amex/MC/Stripe/Visa), AP2 (Google, consumer mandates), TAP (Visa, agent identity), Agent Pay (Mastercard, identity + tx trust), MPP (Stripe/Tempo, machine-to-machine card). No winner; layers stack. |
| 2026-08 | AP2 v0.2 security analysis (arXiv 2608.23858) — PEER VALIDATION of our thesis 48 threats, 5 attack families, 8 High-band (AIVSS). Core finding: 'valid mandate signatures alone do not ensure that an agent-mediated transaction reflects the user's intent when its pre-authorization context is manipulated' — prompt injection, tool-result poisoning, A2A message manipulation all unsecured by the signed mandate. That is exactly our UC-2 MANDATE + UC-5 RECEIPT white space, academically confirmed. |
| 2026-10-20 | ACAGS (arXiv 2610.27483) — behavior-aware fraud detection for agent payments Agent impersonation, unauthorized payments, compromised agents, delegated-authority misuse; supervised ML + behavioral analytics framework. Validates UC-7 RISK being needed; also confirms it's an academic swarm (feature-shaped). |
| 2026-07-14 | x402 Foundation launches under Linux Foundation Coinbase donated protocol; 40 member companies. Real volume is TINY: 75.41M transactions but only $24.24M trailing-30d volume (~$0.32 avg). Same 'lots of tx, cents per tx' picture as our spec. |
| 2026-09-01 | t54 ships on AWS Bedrock AgentCore; Skyfire+Forter enrich merchant checkout (Oct 19) t54: 20M+ agentic transactions screened, 41k agents KYA'd via Amazon Bedrock AgentCore. Skyfire+Forter announced checkout-time trust enrichment 19 Oct 2026. |
| 2026-04-27 | Solowin/SC Ventures AGENPAY — bank-grade KYA engine NASDAQ AXG + Standard Chartered venture arm incubating AGENPAY: KYA + Bahrain stablecoin license as the rails for AI wallets. Banks are building in-house KYA engines. |
Market sizing — updated
- McKinsey (cited by Visa/MC/Ant, Sep 2026): $3-5T agent-orchestrated consumer commerce by 2030
- Bain (via commercetools, Oct 2026): US agentic commerce $300-500B by 2030, 15-25% of US ecommerce; Gartner: 20% of digital commerce via AI platforms by 2030
- IDC (2026 edition): agentic commerce $18.4B in 2025
- x402.org live: 75.41M tx / $24.24M volume trailing 30d (~$0.32 avg)
Where we stand per core UC
| UC | Standing |
|---|---|
| UC-1 VERIFY | CROWDED and consolidating — TAP, Agent Pay (+Skyfire), Ant AMP, Solowin AGENPAY all ship identity verification at network/bank layer. Do NOT lead with verify. |
| UC-2 MANDATE | Semantically validated by arXiv 2608.23858: mandates don't bind pre-auth context. Productable as intent-check on top of AP2/A2A/MCP; AP2 owns authn, nobody owns pre-auth context verification. |
| UC-5 RECEIPT | Still open. No protocol, network, or Alliance member ships a merchant-facing evidence artifact with counterparty-format export. Strongest remaining white space. |
| UC-6 DISPUTE | OPEN and unclaimed: APA lists disputes in scope but has published no dispute standard; x402/AP2/A2A have no refund path; Visa CE 3.0 10.4 is the only network precedent. 16-month window before APA or the KYA framework writes over it. |
| UC-7 RISK | Feature-shaped swarm (ACAGS, Mastercard probability score, t54 risk engine). Bundle-able; do not lead. |
10 · Sources
Primary sources first. Anything not directly verifiable is marked UNVERIFIED in the canonical JSON.
- Visa Core Rules and Visa Product and Service Rules, 18 April 2026 — §4.1.24 Agentic Platform Requirements (§4.1.24.1–4.1.24.9), §5.4.3 merchant obligations, Dispute Condition 10.4 (CE 3.0) data elements — Primary. Binding network rules effective 18 April 2026. 2026-04-18
- Mastercard advances agentic commerce with new trust and intelligence services — Agent Pay Trust Framework — Primary. Agent-detection probability score + shared intelligence layer; Mastercard names Skyfire as its KYA partner. 2026-09-30
- t54 Trustline — transaction-level trust, risk, compliance and evidence for the agentic economy — Competitor site. Ships KYA graph, intent challenge, validator-panel risk, tamper-evident audit chain, evidence/dispute/chargeback. 2026 (accessed 2026-10-23)
- Beltic — infrastructure for incoming agent traffic — Competitor site. Agent visibility + policy engine + intent intelligence on websites, APIs and MCP servers. No published pricing page (404 on /pricing). 2026 (accessed 2026-10-23)
- Regulation (EU) 2026/1744 of 8 July 2026 (Digital Omnibus on AI) — amends 2024/1689 application dates — PRIMARY. Recital (40): high-risk obligations in Chapter III Sections 1-3 deferred to 2 December 2027 for Art 6(2)/Annex III systems and 2 August 2028 for Art 6(1)/Annex I systems, because of delayed standards and national competent authorities. CORRECTS the earlier 'live since 2 Aug 2026' framing. 2026-07-08 (published OJ)
- Ralio — the trust layer for agentic business payments — Competitor site. Rail-agnostic guardrails between agents and payment rails; spend limits, allowlists, audit log. ISO 27001 + SOC 2 in progress. 2026 (accessed 2026-10-23)
- Natural — agentic payments primitives (wallets, cards, processing, billing) — Competitor site. $30M Series A led by Forerunner, 20 July 2026. Mediates disputes; ties IDs to a verifiable legal identity. 2026 (accessed 2026-10-23)
- Skyfire — KYA (Know Your Agent) and KYAPay — Competitor site. KYA identity + KYAPay settlement + agent history. IETF draft for KYAPay profile. 2026 (accessed 2026-10-23)
- AP2 — Agent Payments Protocol, Payment Mandate schema and constraints — Primary protocol spec. Mandate constraints incl. allowed payee, amount, recurrence. 2025-09-16 (spec), donated to FIDO Alliance 2026-04-28
- Agentic Commerce Protocol (ACP) — open specification, OpenAI + Stripe — Primary protocol spec. Delegated payment spec keeps settlement, refunds, chargebacks and compliance with the merchant and its PSP. 2026 (accessed 2026-10-23)
- Model Context Protocol — Authorization (2026-07-28 revision) — Primary spec. OAuth 2.1, scope challenge, step-up authorization flow, Protected Resource Metadata. 2026-07-28
- Stripe — Handle orders from agents (agentic commerce for sellers) — Primary vendor doc. Existing refund and dispute flows work without changes for agentic checkouts — Stripe does not verify agents. 2026 (accessed 2026-10-23)
- EU AI Act — Article 12 Record-keeping (automatic event logging over system lifetime; ≥6-month deployer retention baseline under Art 19 / Art 26(6)) — PRIMARY. Regulation (EU) 2026/1744 moved Chapter III Sections 1-3 application to 2 Dec 2027 (Art 6(2)/Annex III) and 2 Aug 2028 (Art 6(1)/Annex I). General application date unchanged at 2 Aug 2026. Article 12 text: https://artificialintelligenceact.eu/article/12/ 2024 in force; general application 2026-08-02; Annex III high-risk obligations deferred to 2027-12-02 by Regulation (EU) 2026/1744 (Digital Omnibus on AI, 8 July 2026)
- Council of the EU — PSD3/PSR first-reading position, view to adoption — PSD3/PSR NOT yet in the Official Journal as of 2026-10-23. Build to the rule, not to a date. 2026-10-21 (position), published 2026-10-23
- Linux Foundation — Agentic AI Foundation (AAIF): MCP, goose, AGENTS.md, A2A, Agent Router, agentgateway — Primary. Neutral home for the agent protocols we would federate. 2025-12-09 (formation)
- IETF Internet-Draft — ATXN: Agent-to-Agent Transaction Definition Protocol (draft-stone-atxn-00) — Primary draft. Expires 27 Oct 2026. 2026-04
- Machine Payments Protocol (MPP), Stripe + Tempo — sessions primitive for pre-funded spend limits — Primary. First protocol-level acknowledgement that agents need a limit, not just a payment. 2026-03-18 (launch)
- Baselayer / Osiris Ratings — Agentic Identity Suite, $35M Series A led by M13 — Business-identity incumbent entering agent identity. 2,300+ FIs, 10M+ applications, $1B+ fraud prevented. 2026-10-04
- Chargeback.io — Agentic Payments and Chargebacks: A Merchant Guide — Maps agent disputes onto existing Visa reason codes 10.4 / 13.1 / 13.3. Cites ACI: mandate-based authorization 'currently untested in courts and before regulators'. 2026 (accessed 2026-10-23)
- Digital Applied — Agent Checkout Authentication: Who Vouches for the Bot? — Analysis. No card network has published an agent-specific dispute rule. Visa CE 3.0 accepts the agent-platform login ID as a CE data element, in clear text. 2026 (accessed 2026-10-23)
- Agent Payments Tracker — protocol-by-protocol status and public volume evidence — x402 ~109.6M transactions / ~$15M adjusted volume (Visa & Artemis analysis), Apr 2026. Visa 'hundreds' of agent transactions as of Dec 2025. 2026 (accessed 2026-10-23)