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Agentic commerce, where artificial intelligence (AI) systems act on behalf of users to find products, negotiate purchases, and execute payments, is developing rapidly. This creates shared responsibility: developers must build legally sound systems, while regulators and infrastructure operators must consider how existing frameworks apply and where new approaches may be needed. The Bank of England operates, oversees and is co-ordinating the design of payment systems as part of its statutory responsibilities. Emerging agent‑based payments can have implications for how the private sector safely innovates and how regulators and payment infrastructure providers adapt. This post explores how agentic commerce could reshape future payment design.
How might agentic commerce be used in practice?
It is important to note from the outset that agentic AI always requires human deployment, and that deployers retain legal responsibility for an agent’s actions; responsibility does not sit within a ‘black box’.
Visa provides one example from industry for how agentic commerce could be used, setting out a four‑step adoption process:
Recommending products: using Large Language Models (LLMs) to recommend better products. An agent could compare products and recommend the most suitable option.
Initiating payments on your behalf: agents can make payments with user verification, such as one-off bill payments.
Transacting on your behalf: agents execute payments according to predefined rules, such as renewing a service when usage hits a threshold.
Orchestrating payments: an agent owns the whole lifecycle of payments and communicates with other agents to orchestrate complex payment flows.
This last point leads to a potential scenario where agentic payments become like ‘locals paying at bazaars’, with agents forming informal relationship-based agreements with other agents. This highlights a future state where agents might adapt the behaviours we see in payments, with potential downstream impacts:
Payments move from being human-initiated to agent-initiated.
There is an increase in speed and volume of transactions as agents may transact, negotiate, return and refund payments at speeds faster than humans.
There are decreased transaction sizes, as agents may transact in small values to complete complex, orchestrated workflows.
We need new authentication to resolve how humans and their agents interact, moving from Know-Your-Customer (KYC) to Know-Your-Agent (KYA) for payments, as highlighted by Dave Birch.
While some automated activity exists today in areas such as algorithmic trading, consumer and retail payments introduce distinct requirements around authentication, liability and consumer protection.
So how do payments and agents interact, and what are the responses to this?
A previous post examined how existing financial infrastructure can govern agents. I am developing this by highlighting how the infrastructure for managing agents can impact how payment systems are built.
Today’s agent payments landscape is fragmented, with multiple identity frameworks, payment protocols and communication layers that are not interoperable across providers. For example, some agent identity standards are only supported by specific card schemes, while agent payments protocols and how they integrate with checkouts vary across stablecoin and card‑based rails. Addressing this fragmentation is a shared task: the private sector needs to build and adopt interoperable standards; with public sector participants having a role in setting clear expectations and, where appropriate, common requirements.
We are already seeing new private sector solutions to solve the issues around fragmentation, standards and interoperability with different payments methods. These solutions tend to cover four aspects: how agents communicate with each other, how they pay, how they assure identity and how they settle payments.
How agents communicate: New shared standards are emerging that allow AI agents to exchange information and instructions with each other. Examples include the Model Context Protocol (MCP) and Agent2Agent (A2A) frameworks. Think of these as like a common language that different agents can use regardless of who built them.
How agents pay: New protocols are being developed to define how agents interact with online checkouts and payments processes. Examples include the Agentic Commerce Protocol (ACP), Universal Commerce Protocol (UCP), and Agentic Payments Protocol (AP2). These are the equivalent to giving agents a standard way to navigate the payments processes, like authentication of your card, that humans currently do manually.
How agents prove their identity: For payment systems to trust an agent, they need a reliable way to verify who or what is acting. Card schemes are developing their own solutions (such as Visa Intelligent Commerce and Mastercard’s Agent Pay). Some solutions have also been developed by users for specific blockchains, such as ERC-8004 for Ethereum. The challenge is that these approaches are not consistent with each other.
Which payment rails agents use: A payment rail is the underlying infrastructure that moves and settles money from one party to another, such as card networks, Faster Payments or blockchain-based systems. Agents will need to connect to these rails to complete transactions. Both established card providers and newer blockchain-based options (like the X402 protocol) are developing ways to accommodate agent-initiated payments.
These innovations highlight a future route to solving issues with how agents and payments infrastructure work together; but there still may be issues that arise that require further integration with payments infrastructure, new standards or reimaging payments infrastructure we have.
So, what are the design challenges for building payment rails that work with agentic payments? Some of these fall on private sector designers; others raise questions for regulators and infrastructure operators.
The potential use-cases and private sector innovations bring to the fore a few questions I grapple with when thinking about designing future payments infrastructure. These are:
How to ensure consistent identity and authentication across human and agent actors.
Whether payment systems should support higher‑frequency, lower‑value transactions.
How deterministic requirements in payment law can be upheld when interacting with non‑deterministic AI systems.
How regulation can encourage interoperability and enable integration between competing standards.
On the first issue, one question when integrating agent identity into payments is what role there should be for a central entity to mandate agent identity, like the conduct principles around how the private sector is required to implement KYC.
On the second issue, agents might need faster, lower value and high-volume payments. We need to consider if the existing rails can support these transactions or if new ones are needed. This also raises a larger infrastructure point: do payment rails need to be designed and built from the start to incorporate the ways mentioned above on how agents communicate, pay, and prove identity, as opposed to these being bolted on afterwards?
Thirdly, payment systems are designed to be deterministic: given the same input, they produce the same result. This predictability underpins reconciliation, fraud controls and legal certainty. Agentic systems rely on probabilistic AI outputs. An agent may phrase requests differently, pursue alternative paths to achieve a goal, or retry transactions in unexpected ways. This mismatch creates risks. Agents could generate excessive payment requests, submit non‑standard data, or trigger unintended transactions. Payment rails therefore need guardrails, clear policies and the ability to detect erroneous agent‑initiated activity. Designers of agentic payment systems – public and private – will need to manage this variability while preserving the predictability required for settlement. Regulators may also need to consider appropriate safeguards and standards.
Finally, agents will require a universal way to interact with online checkouts and allow interoperability. Today, each checkout journey varies by merchant, payment service and rail. For agents to participate meaningfully in commerce, we will need a layer of abstraction that allows them to complete checkout flows regardless of whether the underlying rail is Visa, Mastercard, Faster Payments, or emerging options like stablecoins. This means designing rails that provide interoperability with agent identity, payments protocols and communications standards so payment systems can interact with the many private sector frameworks that might get adopted. This also raises the question of to what extent a central authority should be the standard setter for agentic payments and commerce, to better enable this innovation.
These design choices have direct implications for how policymakers and payment system designers approach future infrastructure. While acknowledging payments sits in the context of a broader ecosystem where agents would not just interact with payments through the underlying rails but also via intermediaries (eg wallets, checkouts etc), there is an understanding that different payment technologies have different strengths in an agentic context. Blockchain-based forms of money, including stablecoins and tokenised deposits, can support programable, rule-based payments and small transaction values and flexible automated workflows. Existing card-based rails benefit from broad acceptance and established consumer protections. It is important that payment system builders, be it in the public or private sector, choose technologies and design them in ways that meet appropriate safety and resilience standards.
The broader challenge, for the public and private sector, is to determine how existing payments infrastructure can be adapted for agentic use, and where genuinely new approaches may be needed. In some cases, existing infrastructure may be sufficient; in others, new technologies such as blockchains could enable step changes in how agents, payments and commerce interact. Acknowledging these decisions helps us understand how to develop payment systems that remain trusted and fit for purpose in an economy where agentic payments may grow.
Prem Munday works in the Bank’s Distributed Ledger Technology Lab.
If you want to get in touch, please email us at bankunderground@bankofengland.co.uk or leave a comment below.
Comments will only appear once approved by a moderator, and are only published where a full name is supplied. Bank Underground is a blog for Bank of England staff to share views that challenge – or support – prevailing policy orthodoxies. The views expressed here are those of the authors, and are not necessarily those of the Bank of England, or its policy committees.
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The bank says its first autonomous AI model is already reducing parts of the pre-adjudication process from an average of 15 hours to less than three minutes.
Disclaimer – This is our personal view and mutual funds and equity investments are subject to market risk. Please read all offer documents before investing. This video is only for education purpose. Please consult your adviser before investing. This video is only to give information and only for education purpose.
A case in point is the recent 600% share price surge of Allbirds, after the once-trendy sustainable footwear business issued a vague announcement in April 2026 that it would pivot to AI. In the coming months, the company plans to rename itself NewBird AI and give up its status as a public benefit corporation.
As a scholar who studies corporate sustainability, I see parallels between this “AI washing” phenomenon – when companies oversell the benefits of AI while glossing over the risks – and the greenwashing trend in the recent past, when companies claimed to commit to sustainability but didn’t enact fundamental change. Widespread deception was rampant, with businesses spending far more on green marketing than on actual sustainability improvements. And those efforts often backfired on both the companies and the communities they served. Even more worrisome: AI washing’s rapid rise and widespread adoption will likely eclipse the greenwashing trends.
AI washing is thriving because companies and policymakers ignore four important principles. These shortfalls, in the past, also characterized greenwashing.
Making matters worse is that the U.S. currently relies on fragmented AI rules, with most being voluntary. The Trump administration has generally sided with Big Tech to push back efforts at state or federal regulation. At a global level, one of the few exceptions is the European Union AI Act, perhaps one of the most comprehensive frameworks, but its implementation won’t be fully phased in until 2027 or later.
The U.N. climate change summits, like this one in Brazil in 2025, have offered a global forum for policymakers and business leaders on climate and sustainability issues. AP Photo/Fernando Llano
When companies must report carbon emissions using the same methodology, for example, or disclose labor conditions using identical categories, investors can compare performance, identify laggards and allocate capital accordingly. This push made comparisons possible and deception harder, although it still wasn’t foolproof. For example, a 2023 United Nations Environment Programme report on the fast-fashion industry found that many companies continue to make “vague and inflated” sustainability claims.
Second, there are no comprehensive frameworks in the U.S. that require businesses to judge how AI affects them in a material way and publicly disclose those impacts. Examples of AI-driven material impacts include whether algorithmic bias shapes business outcomes, or whether decisions on how to use AI systems carry significance for shareholders and the public.
Instead, AI governance remains dominated by the narrow inner circle of companies that build the AI systems, while affected communities rarely have a say in determining which AI impacts are material enough to warrant public attention. For example, Big Tech companies like Google, Microsoft, Apple, NVIDIA and others adhere to their own AI governance guidelines, with relatively little public input.
The development of sustainability principles offers some examples of how to build these frameworks. The EU’s Corporate Sustainability Reporting Directive requires over 50,000 companies to formally evaluate which sustainability topics are material to their stakeholders, and then disclose that information. These efforts try to ensure that accountability is clear across entire supply chains.
While nowhere nearly as comprehensive, U.S. regulations such as the 2010 Dodd-Frank financial reform and California’s law requiring reporting on statewide greenhouse gas emissions provide a similar blueprint that U.S. policymakers could build on if they chose.
A third problem is the general lack of third-party verification, making AI washing trivially easy. Effective disclosure means reporting all material impacts – not just cherry-picked successes.
In practice, AI audits can vary dramatically in rigor, scope and methodology. One auditor might conduct extensive testing across demographic groups, analyze decision-making and validate the quality of training data. Another might simply review documentation and accept company explanations at face value. Given the variety of AI auditing models out there, different auditors may use incompatible methodologies, making results impossible to compare. If companies adopted third-party accreditation systems to assess how they use AI, they would help ensure the accountability that self-reported claims cannot match.
By contrast, there was reasonable progress in this respect as companies adopted ESG principles. For example, institutions such as the Carbon Disclosure Project and Global Reporting Initiative have a network of partners that offer independent verification. These providers, certified under international standards, verify corporate sustainability data against rigorous criteria. That way, they provide the assurance that lets companies show the progress needed to unlock sustainable finance and mitigate legal risks. Third-party audits are far from perfect, but they offer a clear path for improvement.
The fourth principle is robust enforcement. Early ESG initiatives relied on reputational pressure and stakeholder goodwill – things that corporations routinely ignored when profits were at stake. When change came, it was because regulations established legal liability and financial penalties.
These consequences changed how corporations assess risk and continue to shape sustainability practices today. Volkswagen’s 2015 ‘Dieselgate’ scandal, for example, cost the company over US$30 billion in fines, settlements and criminal charges after U.S regulators found that the carmaker was cheating emissions tests. BP faced billions in penalties and liabilities for the 2010 Deepwater Horizon disaster, the biggest oil spill in the history of marine oil drilling operations.
The current enforcement gap in AI creates a predictable dynamic. The expected value of AI washing – like potential investment gains, competitive advantage, and market valuation increases – far exceeds the expected cost in terms of penalties and risk of detection. Until enforcement imposes consequences that exceed benefits, AI washing will persist as a rational business strategy rather than a risk to a business’s reputation.
Fortunately, investors are beginning to step up. The Federal Trade Commission, for example, launched Operation AI Comply in 2024, targeting deceptive AI claims, although this effort has been partially scaled back by the current Trump administration.
New standards for a new era
Until businesses address these four principles, AI washing will continue. Without standards and audits, even well-intentioned companies can’t know if their work meets adequate rigor. Without assessments of material impact, some groups of consumers or shareholders will be hurt. And without liability, even thorough auditors won’t be able to identify whether a business’s claims about AI are truthful.
These principles, applied broadly, also help explain why greenwashing persists. For example, the lack of universal reporting standards continues to leave some gaps, with data-quality issues persisting even as reporting frameworks emerged. More fundamentally, political buy-in for ESG has diminished significantly, particularly in the U.S., where over 150 bills were introduced across multiple states by 2023 to disincentivize firms from adopting ESG. Major financial institutions – including JP Morgan, State Street, BlackRock and PIMCO – have retreated from their earlier climate commitments amid political pressure as well as antitrust concerns.
This trend shows that even well designed accountability measures require durable political support to succeed. After all, corporate sustainability took more than 25 years to develop from an initial framework to mandatory standards, and it still remains a work in progress. AI, by contrast, is advancing exponentially in terms of its reach and societal impact. There may not be 25 years to catch up – but at least there are lessons from the recent past.
Suvrat Dhanorkar, Associate Professor of Operations Management, Georgia Institute of Technology
This article is republished from The Conversation under a Creative Commons license. Read the original article.
Chase is offering some people the following spend offer:
Spend $2,000 or more from 5/14/26 through 8/14/26 and get $50 cash back.
Our Verdict
Apparently this offer is showing within the Chase Offers (?) and possibly on their other offer channels. Not sure if it’s only being seen on Freedom or other cards as well.
Reader Adrian sent this in, and I haven’t seen anyone else mention it. It’s likely a highly targeted offer, and maybe some people haven’t noticed it buried in their Chase Offers.
Big and uncertain shocks have pushed UK inflation above the 2% inflation target over the past few years. How did financial markets view the Monetary Policy Committee’s (MPC’s) monetary policy during this unprecedented period? We show that markets have come to perceive the MPC’s policy stance as increasingly dependent on data releases. In particular, the responsiveness of UK market rates in tight windows around data releases rose significantly from 2022 to 2025. Zooming out to longer time windows in between MPC meetings, the change in services inflation explained a historically large share of the overall change in market rates over the same period.
UK interest rates have recently had to respond to big shocks.
The MPC has had to respond to very large shocks in recent years. It routinely considers a wide range of inputs – including data, analysis, forecasts and scenarios – when deciding its strategy and policy stance at each meeting. In its communications it has often pointed to specific data sources (for example, in the August 2023 minutes). Financial markets are important because they play a key role in transmitting monetary policy to the economy. So which inputs do financial markets appear to think the MPC cares about most? And how data dependent do they think policy has been in practice?
Interest rates have become more responsive to UK inflation data releases.
To analyse the data dependence of UK monetary policy as perceived by markets, we use high-frequency data to look at how short-term market interest rates respond in tight windows around UK inflation data releases, over the period 2012 to early 2026. The size of this response signals how strongly markets expect the MPC to react to domestic inflation news (refer to Healy and Jia (2024) and Mangiante et al (2025) for similar methods).
We find that the estimated responsiveness of market rates to inflation data has risen significantly in the UK since 2022. The estimated responsiveness to inflation data has risen by more than for GDP, PMI or labour market data. A 10 basis point surprise in UK inflation data releases was associated with a 3 basis point change on impact in three-year swap rates on average over the three years to 2025, compared to close to no change in the three years to 2022 (Chart 1). This points to greater importance of inflation data in market participants’ perceptions of the MPC’s reaction function, consistent with the idea that policy itself has become more data dependent.
Chart 1: Market rates have become more responsive to data surprises in narrow windows around UK inflation data releases since 2022
Note: Chart shows coefficient estimates from a set of rolling three-year regressions of the high-frequency change in three-year swap rates in 10-minute windows surrounding UK data releases on the total surprise in the data release.
We test whether market perceptions of higher data dependence also show up over longer time windows between consecutive MPC meetings.
We next assess whether perceptions of heightened market rate responsiveness to inflation data only affect market rates the day the data is released or whether those perceptions appear to be reflected over longer time periods. This is important because short-term changes in market rates that then dissipate quickly have smaller impacts on the economy than changes in rates that persist over time.
Specifically, we widen the window to measure the change in market interest rates from market close on the day of each MPC meeting to the next. This is a simple proxy for markets’ perception of the change in policy stance between MPC meetings. We then analyse how this change in market rates correlates with the macroeconomic data that is released between meetings (a simpler version of Orphanides (2001)). We compare how well different data – such as inflation (both outturns and short‑term forecasts), wage growth, employment and PMIs – explain movements in market rates.
This exercise has limitations. We add controls for other changes in macroeconomic data but these controls will not capture all possible drivers of market rates in these time windows. The results should therefore be interpreted as suggestive rather than definitive.
Markets have come to view services inflation data as a key determinant of the policy stance.
We find that services inflation – specifically the change in the annual service inflation rate between MPC meetings – was the most important variable in explaining UK market rates from the end of 2021 to 2025. A 10 basis point change in annual services inflation between MPC meetings was associated with around a 6 basis point change in the three-year swap rate over the three years to late 2025 (Chart 2). The change in services inflation explained 35% of the variation in market rates over that period. This represents a clear break from the past: before the recent cycle, the link between services inflation and market rates was much weaker. Over the three years to 2019 for example, the change in services inflation explained roughly 5% of the variation in market rates – which was a period when services inflation was much lower than post 2022.
Chart 2: Market rates have been strongly correlated with the change in UK services inflation between MPC meetings since 2022
Note: Chart shows coefficient estimates from a set of rolling three-year regressions of three-year swap rate on changes in services inflation using data summarised in windows between MPC meetings. Shaded area is 95% confidence interval.
This finding is robust to the inclusion of a set of other macroeconomic variables as controls, such as headline inflation, the unemployment rate and PMIs. Including the unemployment rate alongside services inflation improves the fit but only slightly. Even including the US one-year swap rate in the same regression – which on its own explains around 60% of the variation in UK rates, given the well-documented close relationship between the two – only slightly reduces the importance of UK services inflation in explaining UK rates.
Our findings might point to a broader international trend towards stronger data responsiveness of market rates. Our analysis suggests that a similar, albeit less strong, relationship also held in the US until recently.
It isn’t obvious that monetary policy should be equally data dependent at all times.
At first glance, it might seem obvious that monetary policy should always be data dependent, and that that financial markets should incorporate this throughout. But that isn’t necessarily the case. Our estimates suggest market perceptions of the MPC’s data dependence were much lower before 2022. And this has some theoretical underpinning. Market responses may reflect that, if a monetary policy maker broadly understands the shocks hitting the economy, and monetary policy can only affect the economy with some lag, the policymaker should respond to the future economic outlook rather than data releases, which are backward-looking. Of course, data releases will often contain some signal about the outlook, but the strength of that signal will vary over time. At a time when big and uncertain shocks are hitting and certainty about the outlook is low, it may make sense to place more weight directly on the data (Bailey (2025) and Haberis et al (2025)).
What happens next?
Markets have perceived the MPC as being very data dependent over recent years. This represents a big change compared to the period before the Covid pandemic. This raises an important question: what will markets look at to determine the UK policy stance going forward? Placing greater weight on real‑time data may be a sensible response to the heightened uncertainty of recent years. That uncertainty does not appear to be going away any time soon, so perhaps the perceived data dependence of monetary policy is here to stay.
Nades Raviraj and Danny Walker work in the Bank’s Monetary and Financial Conditions Division.
If you want to get in touch, please email us at bankunderground@bankofengland.co.uk or leave a comment below.
Comments will only appear once approved by a moderator, and are only published where a full name is supplied. Bank Underground is a blog for Bank of England staff to share views that challenge – or support – prevailing policy orthodoxies. The views expressed here are those of the authors, and are not necessarily those of the Bank of England, or its policy committees.
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Student loan debt is one of the most common concerns we hear from borrowers. Each mortgage agency calculates student loan debt differently. Here’s what you need to know.
Fannie Mae Student Loan Guidelines
Under Fannie Mae, if a student loan payment is not reflected on the credit report or is in deferment, the lender must use:
1% of the outstanding balance
This can significantly impact DTI, especially for borrowers with higher balances.
Example: If you owe $50,000 in student loans, Fannie Mae may require using $500 per month as your qualifying payment.
Freddie Mac Student Loan Guidelines
Freddie Mac takes a more flexible approach. If no payment is listed, they allow lenders to use:
0.5% of the outstanding balance
Using the same $50,000 example, the qualifying payment would be:
$250 per month
This difference alone can sometimes determine whether a borrower qualifies.
FHA Student Loan Guidelines
ForFHA loans, the rule is similar to Freddie Mac:
0.5% of the outstanding balance
If the actual documented payment is higher, the higher amount must be used. But if the payment is lower or deferred, FHA defaults to 0.5%. FHA can be a strong option for borrowers managing student debt, particularly when combined with flexible credit guidelines.
VA Student Loan Guidelines
VA loans handle student loan repayments differently depending on the repayment timing. If the student loan payment will begin in:
Less Than 12 Months
The lender must use:
0.5% of the outstanding balance
If repayment begins in:
More Than 12 Months
The payment may be:
Omitted entirely OR
Counted as $0.00
This can dramatically improve qualification for eligible veterans. VA loans are often the most flexible option for borrowers carrying student loan debt.
Important: Watch for CAIVRS Issues
Before moving forward with FHA or VA financing, borrowers should be aware of CAIVRS (Credit Alert Verification Reporting System). If you have delinquent federal student loans, you may receive a negative CAIVRS result, which can:
Delay your approval
Require resolution before closing
Potentially disqualify you temporarily
If student loans are holding you back, let’s evaluate:
Conventional (Fannie vs Freddie comparison)
FHA
VA (for eligible veterans)
Non-QM options when needed
If you’re ready to explore your options, our team atMortgageDepotis here to guide you in the right direction.