The paper reflects insights from a broad cross-industry roundtable bringing together banks, technology companies, regulators, consumer advocates and payments experts.
WASHINGTON, DC – The Consumer Bankers Association (CBA) today released a new white paper, Agentic AI Payments: Navigating Consumer Protection, Innovation and Regulatory Frameworksexamining how new agentic AI tools could reshape consumer payments, and the opportunities and risks this development presents for consumers, banks, merchants and policymakers.
Agentic AI tools – systems capable of autonomously making decisions and executing transactions on behalf of a consumer – are poised to become an important feature of the payments and commerce ecosystem in the relatively near term. While these tools offer the potential to reduce friction, save time, and improve consumers’ financial outcomes, they also raise new questions about authorization, accountability, transparency, fraud, and the adequacy of existing consumer protection frameworks.
The white paper builds on a two-day Agentic AI Payments Symposium hosted by CBA in Washington, DC in fall 2025, which brought together senior representatives from across the payments ecosystem, including CBA member banks, technology and AI developers, payment networks, fintech companies, merchants, consumer advocates, academics, and federal and state regulators. Discussions were conducted under Chatham House rules to encourage frank dialogue and rigorous exploration of emerging risks and solutions.
“This article reflects what we have heard directly from a remarkably diverse group of experts who are actively building, regulating, using and reviewing these technologies.” said Lindsey Johnson, president and CEO of the Consumer Bankers Association. “Agentic AI has the potential to fundamentally change the way consumers shop, pay and manage their finances, but history shows that innovation succeeds when consumers trust the system. Our goal is to help ensure that consumer protection evolves alongside technology, not years after problems arise.”
Background
Key themes explored in the white paper include:
- How agent payments differ from traditional electronic payments, particularly when consumers do not directly authorize transactions at the point of sale;
- Potential gaps in existing legal and regulatory frameworks, including application of the Electronic Funds Transfer Act and the Truth in Lending Act to agent-initiated transactions;
- Risks related to misaligned incentives, fraud, data use and consumer misunderstanding, particularly as new payment methods and AI-driven business models emerge;
- The essential role that banks play as trusted managers of consumer payments and dispute resolution; And
- Market-based and policy-oriented approaches that could help balance innovation with consumer protection in the early stages of this technology’s development.
It is important to note that the document does not call for immediate new regulations. Instead, it highlights the value of early and collaborative engagement between industry stakeholders and policy makers to identify risks, clarify responsibilities and determine whether existing frameworks – public and private – can be adapted to support the safe adoption of agent payment tools.
“Electronic payments were only widely adopted because clear rules of conduct gave consumers confidence. » said Kelvin Chen, Senior Executive Vice President and Chief Policy Officer. “Agent payments may be at a similar inflection point. Thoughtful dialogue now can help avoid confusion, consumer harm and fragmented results later.”
The full white paper is available HERE.
ABC Advocacy
- The CBA encouraged members of the House Financial Services Committee to build on existing regulatory frameworks and apply them to non-banks to promote AI innovation in financial services. letter submitted December 10, 2025.
- The ABC responded to the Office of Science and Technology Policy’s RFI on AI regulatory reform, submitting comments on October 27, 2025.
- The CBA runs an “AI Forum,” bringing together senior executives and technology experts from all CBA member firms to discuss the most prescient AI issues facing banks. The meetings provide members with the opportunity to share AI use case experiences and challenges with their peers. They also feature CBA-led discussions on the AI regulatory landscape as well as third-party presentations highlighting specific AI solutions focused on banks. CBA’s goal with the Forum is to provide a space for CBA members to share best practices in deploying AI solutions and to understand the barriers they face in order to inform CBA’s advocacy efforts.