Commerce at Machine Speed Part II: The Governance, Accountability and Regulatory Framework Agentic Commerce Requires
When a human authorises a payment, the accountability chain is direct: a person approved the transaction, their identity is on record, and liability can be attributed to them if something goes wrong. Agentic commerce removes that person from the point of execution, replacing individual transaction approval with mandate design — the parameters within which an agent is authorised to act, defined before deployment and without human review at each transaction. Governance relocates upstream: to how accountability is attributed when the transacting party is a machine, how liability is allocated when an agent acts outside its mandate, and how regulators across jurisdictions are building the frameworks to answer those questions.
Commerce at Machine Speed, Part II is co-authored by Nicole Sandler, Chief Ecosystem Officer at Ubyx, and Colin Payne, Head of Innovation at the Financial Conduct Authority (FCA) and the Chair of the Global Financial Innovation Network (GFIN), with key contributions from A&O Shearman, AllUnity, Amazon, Ava Labs, the Emerging Payments Association Asia (EPAA), the European Commission, Fireblocks, Hedera, Latham & Watkins LLP, Quantoz, Standard Chartered, and Thunes.
The paper examines the governance, liability, and regulatory frameworks that agentic commerce requires. It is the second in a three-paper series.
