InvestNot yet confirmed elsewhere1 publisher3 min readPublished
RBA submissions find chargeback liability unclear when AI agents exceed their authority
Merchants, issuers and payment firms among 75 RBA submitters said chargeback liability is unclear when an AI agent exceeds its authority. Amazon's AgentCore Payments already lets agents pay in stablecoins, so for now merchants and networks are left to price the risk of a disputed order.
The Investor · Invest desk
What happened
- One stakeholder in the RBA consultation referred to reports of an additional 4% charge being applied to AI-assisted purchases.
- The submissions described agent adoption as early and evidence of harm as limited, and generally favored industry standards and monitoring.
- Shopify has moved toward admitting browser-based AI shopping agents into its checkout.
Why it matters
- cost A flat surcharge on agent orders puts the price of disputes on every agent buyer, including the ones who never file one.
- contradiction The warning that merchants will raise fees or block agents is Nemse's projection, while the RBA record leans toward monitoring, so pressure to assign liability is more likely to come from networks and merchants than from the regulator.
- exposure Small merchants are the exposed side: an agent can find them, but a buyer who wants a dependable refund still has reason to buy from a platform that runs its own.
Edgars Nemse, CEO of the GenLayer Foundation, told CryptoSlate that payment "is the easy part, because it's deterministic: the money moved, or it didn't," while "the outcome isn't." [1][7] AgentCore's preset spending limits settle the first part [8]. The RBA submissions were about the second. Networks, they said, may struggle to tell whether an agent followed its customer's instructions, and agentic commerce could raise merchant costs [11].
Mastercard and Datos projected 324 million chargebacks worldwide by 2028 [15]. Mastercard's 2026 US benchmark puts each one at $128 in internal costs and third-party fees, excluding the lost goods or services [16]. Apply that US figure to the global count, as CryptoSlate does for illustration, and the 2028 handling bill is about $41.5 billion [22]. CryptoSlate's own scenarios add about $2.1 billion if volume rises 5% and $6.2 billion if it rises 15% [2].
Against that, one submission referred to reports of an additional 4% charge on AI-assisted purchases [12]. At $128 a case, a 4% fee pays for one chargeback per $3,200 of agent sales [23], and since the benchmark leaves out the merchandise itself, the real cover is thinner [16]. A merchant whose agent customers dispute more than once per $3,200 of orders loses money even after collecting the fee.
Nemse expects agents to "dispute far more often, because disputing costs them nothing." [3] The supporting figures come from complaint queues. Complaints to the Consumer Financial Protection Bureau doubled to 6.6 million in 2025 [4], and a Nature Human Behaviour study estimates that LLM use raises the probability of favorable relief there by 6.9 percentage points [5]. The CFPB data covers mostly credit reporting [6], and none of these figures measures how often a shopping agent files a chargeback.
Industry could write its own liability rules, the route the submissions generally favored, alongside monitoring [13]. Surcharges like the reported 4% are a second path [12]. The third is platforms shutting outside agents out. Amazon already has, for a different stated reason. It cut off Meta's Muse shopping agent on grounds of unauthorized access and its own policies; Nemse sees the move as a contest over the interface [17]. Google, he said, will follow: "they'll block outside agents and ship their own." [18] So the company that built AgentCore with Coinbase and Stripe to let agents find and pay for services [8] has also blocked a rival's shopping agent [17].
I think the dispute gap favors whoever already runs a refund process buyers trust. Nemse said as much: "Without it, your agent finds the small merchant, and you still go back to Amazon." [20] The case against is documented too. Submissions called adoption early and evidence of harm limited [13], only 27% of 1,011 US consumers in a CI&T survey were comfortable with full AI shopping [21], and Shopify has moved toward letting browser-based agents into checkout [19]. If the first published dispute rates on agent-placed orders come in at or below the rates on human orders, the 4% fee has little to cover, and Amazon's block stands on the interface argument alone.
What to watch
- Whether the RBA's regulatory priorities assign chargeback liability for purchases an agent makes outside its authority, or leave it to industry standards.
- Whether Shopify admits AI agents into checkout at standard rates or adds a fee like the reported 4%.
- Whether Stripe or Coinbase attach a refund or dispute process to agent payments made through AgentCore.
Clarity's read
What the record supports and how the coverage leans. The claims behind it follow.
Reality
- Evidence50
- Adoption20
- Hype gap+25
- Incentives70
- Confidence45
Claim ledger
Ranked by verification strength, evidence, and original report placement.
- [1]
Nemse told CryptoSlate that payment "is the easy part, because it's deterministic: the money moved, or it didn't," while "the outcome isn't."
ReportedSupportedSource: Edgars Nemse to CryptoSlate2 sources— create a free account to open themView cited source - [2]
Applying the US benchmark to global volume as an illustrative assumption, a 5% increase would add 16.2 million chargebacks and about $2.1 billion in operational costs; a 15% increase would add 48.6 million and about $6.2 billion.
ReportedSupportedSource: CryptoSlate's illustrative calculation2 sources— create a free account to open themView cited source - [3]
Nemse expects agents to "dispute far more often, because disputing costs them nothing."
ReportedSupportedSource: Edgars Nemse to CryptoSlate2 sources— create a free account to open themView cited source - [4]
Complaints to the Consumer Financial Protection Bureau doubled to 6.6 million in 2025, and the regulator warned that LLMs and autonomous software can flood complaint systems with duplicative submissions.
ReportedSupportedSource: CryptoSlate, citing CFPB2 sources— create a free account to open themView cited source - [5]
A Nature Human Behaviour study estimates that LLM use raises the probability of favorable relief at the CFPB by 6.9 percentage points.
ReportedSupportedSource: CryptoSlate, citing Nature Human Behaviour2 sources— create a free account to open themView cited source - [6]
The CFPB data covers mostly credit reporting.
- [7]
Edgars Nemse is CEO of the GenLayer Foundation.
- [8]
Amazon's Bedrock AgentCore Payments, built with Coinbase and Stripe, lets AI agents discover paid services, authenticate, and pay with stablecoins and x402 under preset spending limits.
- [9]
The RBA's Oct. 6 summary of its payments consultation drew on written submissions from 75 stakeholders.
- [10]
Merchants, payment service providers and issuers said chargeback rules leave liability unclear when an agent acts outside its authority.
- [11]
Submitters said agentic commerce could raise merchant costs and that networks may struggle to tell whether an agent followed its customer's instructions.
- [12]
One stakeholder referred to reports of an additional 4% charge for AI-assisted purchases.
- [13]
Submissions described adoption as early and evidence of harm as limited, generally favoring industry standards and monitoring.
- [14]
The RBA plans to announce regulatory priorities by the end of 2026.
- [15]
Mastercard and Datos's 2025 outlook projected 324 million chargebacks worldwide by 2028.
- [16]
Mastercard's 2026 US merchant benchmark is $128 per chargeback, covering internal costs and third-party fees and excluding the lost goods or services.
- [17]
Amazon blocked Meta's Muse shopping agent, citing unauthorized access and its own policies; Nemse reads the block as a fight over the interface.
- [18]
On Google, Nemse said: "they'll block outside agents and ship their own."
- [19]
Shopify has moved toward admitting browser-based AI shopping agents into checkout.
- [20]
Nemse said: "Without it, your agent finds the small merchant, and you still go back to Amazon."
- [21]
A CI&T survey of 1,011 US consumers found 27% comfortable with full AI shopping.
- [22]
Applying Mastercard's $128 US benchmark to the 324 million projected global chargebacks gives about $41.5 billion in handling cost on 2028 volume (illustrative).
- [23]
A 4% surcharge covers one $128 chargeback for every $3,200 of agent sales.
Sources
1 independent publisher whose own reporting we read for this story.
- cryptoslate.comAI agents can pay for your shopping. Who gets your money back?
1 article · October 9, 2026
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