CFES Issues Recommendations on Agentic Payments Guardrails in New Report

The Coalition for Financial Ecosystem Standards (CFES), an industry-led coalition focused on modernizing financial services, issued a new report analyzing regulatory and policy opportunities related to agentic AI tools in payments. The report, titled “Agentic Payments: An Industry Approach to Liability and Authority,” was developed in partnership with FS Vector, a leading strategic consulting firm for companies innovating in financial services and a major sponsor of CFES.

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AI agents have become an increasingly common vehicle for interactions between customers and product or service providers. This raises questions around the extent to which agents can act on behalf of an individual, as well as who is responsible for oversight. The report details that these questions can be answered through three concepts derived from the common-law principal-agency relationship: Verification of an agency relationship, understanding the scope of authorization, and a framework for responsibilities for when things go wrong. In doing so, the report demonstrates that existing payments law largely provides a workable foundation for governing agentic behavior, with an opportunity for industry to proactively help define a path forward where gaps exist.

“In this period of rapid and consequential technological development, industry has an opportunity — and a responsibility — to help establish best practices and guardrails,” said Sima Gandhi, co-founder of CFES and Senior Advisor at FS Vector. “Industry working groups, much like those that coalesce around technical standards, can play a meaningful role in shaping acceptable norms on the policy and liability fronts when technology creates ambiguity and gaps in existing regulatory frameworks.”

CFES and FS Vector are issuing this report following a productive roundtable discussion which included a broad range of perspectives including banks, payment companies, and other key industry voices. Leaders discussed the report’s findings and initiated a collaborative effort to drive conversations about the importance of setting guardrails for agentic payments.

“This report is just the beginning of the efforts that we must undertake to ensure that agentic payments can be implemented with the end user top of mind,” said Ashwin Vasan, Partner at FS Vector. “We look forward to continued collaboration with the entire industry and regulators to develop a framework today that works for tomorrow’s financial tools.”

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