AttestZ note 1 · Australian payments · 21 October 2026

When an AI agent pays: who said it could?

Australian banks and card schemes are testing AI agents that pay on a customer’s behalf. The ones announced so far are trials. Before agent payments reach the public, one question needs an answer that holds up in a dispute: did the agent act within what the customer authorised?

Submissions to the Reserve Bank named the gap

In its summary of submissions from 75 stakeholders to the Review of Payments System Regulation (6 October 2026), the RBA recorded: “Without a framework for identifying agentic transactions and recording an agent’s instructions, merchants, issuers and PSPs may be unable to determine whether the agent acted within its authority.” Submitters generally asked it to support industry standards rather than regulate. The RBA plans to publish its priorities by the end of 2026.

The industry has described what the record must hold

The Australian Payments Network told the review that a delegated mandate needs to be “capable of being expressed, evidenced, varied and revoked”, with the information available for dispute resolution. Six banks, among them the Commonwealth Bank, ING and Bank of America, published principles on 23 September 2026 saying providers “should maintain auditable records to evidence consumer instructions, authentication, intent, and transaction decisions and outcomes”.

What that record needs, in practice

The mandate, written down before the agent acts: what it may buy, the limits per payment and in total, and the amount above which a person must approve.
Each action checked against that mandate when it happens: within, over a limit, or outside it. A mandate that is checked only after a dispute is a reconstruction, not a record.
Which model acted, and on what instructions. The agent payment protocols we reviewed (AP2, Mastercard Verifiable Intent, Visa’s Trusted Agent Protocol, ACP and x402) record the authorisation; none we read records which AI model made the decision or what it was told.
The human approval, with its time. If a person approved after the agent had already paid, that is a different fact from approval first, and the record should show it.
Revocation, with a cause and a time. “Varied and revoked” is half of AusPayNet’s sentence.
A copy each side can check. The buyer’s agent and the seller’s agent each hold a record of the same deal. If both can prove their record has not changed since, a dispute starts from facts instead of logs only one side controls.

What AttestZ Map does

Map keeps that record for the company running the agent: the grant a named person signed, every action checked against it and flagged (never blocked) when it falls outside, the human decisions and their timing, and a receipt for each deal that either party, or either party’s insurer or lawyer, can verify offline against a checkpoint AttestZ signs every day, publishes and anchors in Bitcoin. Map does not decide whether a payment was fair or lawful, and it cannot stop an agent: the payment runs on the client’s systems first. About AttestZ Map →

The standard is still open. The records kept by the first banks and merchants to run agent payments are likely to shape what it asks for.

Sources: Reserve Bank of Australia, Review of Payments System Regulation, Summary of Submissions to the Issues Paper (6 October 2026); Australian Payments Network, submission to the review (21 August 2026); “Building Trust in Agentic Commerce” principles paper (23 September 2026).