Liability and rules tracker
In short
23 dated rows from 5 sources that bear on agent-initiated payments, each with the primary document, the page or section, and a plain reading of who carries the dispute. The latest row is dated 24 Oct 2026. No card network has added an agent-specific dispute reason code in the documents we read.
How to read the tracker
Each row is a change in a rulebook, a published framework or a court decision that touches a payment an agent starts. The dispute column is our plain reading of where the loss lands, written from the document and its page reference. It is not legal advice and it is not the network's own summary. Where the public text of a network says nothing, the row says so. The chargebacks guide and the merchant of record guide work through the practical side. Download: CSV, JSON.
Visa
| Date | Change | Document and page | Who carries the dispute |
|---|---|---|---|
| Dispute Condition 10.4 (Other Fraud, Card-Absent) invalid-dispute evidence: matching customer account or login IDs now explicitly include login IDs for an Agentic Payment Provider as well as the merchant site; the section was last updated in the October 2026 edition. | Visa Core Rules and Visa Product and Service Rules, 24 October 2026 edition. Section 11.8.5.3, ID# 0030254 (Last Updated Oct 2026), p. 710; related response rules p. 715 | Merchant still carries a 10.4 fraud dispute, but can defeat it by matching the agent provider login ID plus IP or device data from prior undisputed orders. | |
| The October 2026 Summary of Changes lists no new agent-specific dispute condition; changes to 10.4 in this edition concern Address Verification Service liability shifts in selected countries (24 Oct 2026 and 24 Apr 2027). | Visa Core Rules and Visa Product and Service Rules, 24 October 2026 edition. Summary of Changes, pp. 43-69 (10.4 entries at pp. 46 and 52) | No agent reason code exists: agent purchases dispute under 10.4 (fraud) or category 13 (consumer) like other card-absent orders. | |
| Defines the Agentic Payment Provider: an application that searches, discovers and buys for a cardholder on a payment instruction plus cardholder verification, stores and transmits a token, and is not involved in authorization, clearing or settlement. Initiators of Agentic Transactions are not merchants. | Visa Core Rules and Visa Product and Service Rules, 24 October 2026 edition. Glossary, "Agentic Payment Provider", ID# 0031164 (Last Updated Apr 2026), p. 840 | The merchant that receives the token stays the merchant; the agent is not a merchant, so ordinary merchant dispute exposure applies. | |
| Defines an Agentic Transaction as an e-commerce transaction by an Agentic Payment Provider on cardholder-defined instructions, completed without direct cardholder-merchant interaction by submitting the credential for the merchant to complete with its acquirer; includes future-dated and repeated transactions. | Visa Core Rules and Visa Product and Service Rules, 24 October 2026 edition. Glossary, "Agentic Transaction", ID# 0031165 (Last Updated Apr 2026), p. 841 | Card-absent e-commerce rules apply; the merchant carries card-not-present dispute exposure as for any web order. | |
| An Agentic Payment Enabler must enroll in Visa Intelligent Commerce, register with Visa, contract with each provider (with a right to terminate), obtain tokens directly from Visa for stored credentials, never submit transactions for a provider, and comply with PCI DSS. | Visa Core Rules and Visa Product and Service Rules, 24 October 2026 edition. Section 4.1.23.1, ID# 0031167 (Last Updated Apr 2026), p. 263 | Not a dispute rule; it makes the enabler answerable to Visa for its providers. | |
| An Agentic Payment Provider must enroll in Visa Intelligent Commerce, use Visa tokens for stored credentials, not steer customers away from a chosen payment method, not act in a card-present environment, and not aggregate several agentic purchases into one transaction. | Visa Core Rules and Visa Product and Service Rules, 24 October 2026 edition. Section 4.1.23.2, ID# 0031168 (Last Updated Apr 2026), p. 264; aggregation also at p. 458 | One purchase equals one transaction, so a dispute maps to a single order at a single merchant. | |
| Before an agentic purchase the provider must obtain consent to tokenise and to use the cardholder-defined instruction, state the instruction's expiry date, obtain the cardholder's acknowledgement that they are responsible for the provider's actions, and verify identity per Visa Intelligent Commerce specifications. | Visa Core Rules and Visa Product and Service Rules, 24 October 2026 edition. Section 4.1.23.3, ID# 0031169 (Last Updated Apr 2026), pp. 264-265 | The signed acknowledgement shifts the "I did not authorise it" argument away from the merchant when the agent acted within instructions. | |
| During the purchase the provider must use only the cardholder-defined criteria and pass the cardholder name, billing and shipping address and email to the merchant. | Visa Core Rules and Visa Product and Service Rules, 24 October 2026 edition. Section 4.1.23.4, ID# 0031170 (Last Updated Apr 2026), p. 265 | The merchant receives real cardholder data, which is the evidence it needs to fight a fraud dispute. | |
| Digital wallets and pass-through wallets used for agentic transactions must verify the cardholder with a Visa-approved CDCVM when presenting the payment instruction and send the confirmed instruction to Visa. | Visa Core Rules and Visa Product and Service Rules, 24 October 2026 edition. Section 4.1.23.5, ID# 0031236 (Last Updated Apr 2026), p. 266 | A wallet-confirmed instruction gives the issuer a record of what the cardholder approved. | |
| The provider must obtain cardholder consent for limited refund or cancellation policies, delayed or amended charges, estimated authorisations, and merchant upsells, either at final checkout or when capturing the instruction. | Visa Core Rules and Visa Product and Service Rules, 24 October 2026 edition. Section 4.1.23.6, ID#0031172 (Last Updated Apr 2026), pp. 266-267 | A merchant whose policy was disclosed and accepted through the agent can rely on it in a consumer dispute (category 13). | |
| After the purchase the provider must make an order confirmation available for at least 120 days: goods, merchant contact, total, currency and cancellation policy; repeated transactions need a confirmation that charges continue until cancelled. | Visa Core Rules and Visa Product and Service Rules, 24 October 2026 edition. Section 4.1.23.8, ID# 0031174 (Last Updated Apr 2026), pp. 267-268 | The agent, not the merchant, must keep the cardholder-facing record; merchants should still keep their own. | |
| A cardholder is responsible for any actions taken by an Agentic Payment Provider as part of an Agentic Transaction as if the cardholder initiated the transaction. | Visa Core Rules and Visa Product and Service Rules, 24 October 2026 edition. Section 4.1.23.10, ID# 0031176 (Last Updated Apr 2026), p. 268 | Plain reading: an agent mistake within the instruction is the cardholder's purchase, so a "my agent got it wrong" claim is not fraud by itself; the cardholder's remedy runs against the provider. | |
| For the purpose of the Visa Rules an Agentic Payment Provider is considered to be the Cardholder for an Agentic Transaction. | Visa Core Rules and Visa Product and Service Rules, 24 October 2026 edition. Glossary, "Cardholder", ID# 0024372 (Last Updated Oct 2025), p. 852 | The provider stands in the cardholder's shoes toward the merchant. | |
| Issuers must pay acquirers for an Agentic Transaction processed in accordance with a cardholder's payment instructions, and general blocking rules state they include transactions undertaken by Agentic Payment Providers. | Visa Core Rules and Visa Product and Service Rules, 24 October 2026 edition. Section 1.7.6.1, p. 134; Section 1.7.4 footnote, ID# 0029326 (Last Updated Oct 2025), p. 133 | Issuers cannot refuse settlement just because an agent initiated the payment. | |
| 14 rows |
Other rule and policy changes
| Date | Change | Document and page | Who carries the dispute |
|---|---|---|---|
| Walmart terms for AI agents: purchases need customer approval by default, agents never receive card data or change payment methods, and agents that break the terms are blocked; Agent Profiles set per-agent approval or spending limits. | Making It Possible for Agents to Shop on Behalf of Customers (Walmart). Sections on Agent Profiles and terms | Walmart keeps the card relationship, so disputes stay ordinary Walmart card disputes. | |
| Amazon Conditions of Use Agent Terms: an agent must identify itself in every HTTP request with the user agent string "Agent/[agent name]", must not mimic human input or solve CAPTCHAs, and must stop when asked. | Amazon.com Conditions of Use. Section "Agent Terms" (last updated 14 Aug 2026) | Not a payment rule; Amazon enforces access, and blocked Meta Muse from 20 Sep 2026 under these terms. | |
| FIDO Alliance formed the Payments Technical Working Group (chaired by Mastercard and Visa) and the Agentic Authentication Technical Working Group, taking AP2 and Verifiable Intent as inputs. | FIDO Alliance to Develop Standards for Trusted AI Agent Interactions. Press release, working group list | Standards work only; no dispute rule yet. | |
| Verifiable Intent draft v0.1: SD-JWT delegation chain from credential provider to user to agent with cryptographically bound constraints (amount, payee, merchant, line items). | Verifiable Intent specification (draft v0.1). README, "What VI Does" | Evidence of the user's delegated scope for disputes; no liability rule of its own. | |
| 4 rows |
Mastercard
| Date | Change | Document and page | Who carries the dispute |
|---|---|---|---|
| Agent Pay trust and intelligence services: a probability score that a transaction was initiated by an AI agent, rolling out for testing in the US, plus shared agent signals with Cloudflare and Know Your Agent identity from Skyfire. | Mastercard advances agentic commerce with new trust and intelligence services (press release). Section "A probability score identifies AI-initiated transactions" | An authorisation signal for issuers, not a rule; liability is unchanged. | |
| The public Mastercard Rules (2 Jun 2026) and Transaction Processing Rules (9 Jun 2026) returned no provision naming agentic transactions, AI agents or agentic tokens in a full-text query on 4 Nov 2026. | Mastercard Rules; Transaction Processing Rules. Whole documents (503 and 436 pages) | Agent purchases follow ordinary card-not-present chargeback rules; no agent-specific allocation is public. | |
| Agent Pay Acceptance Framework: agents are registered and verified before transacting, then use agentic tokens; merchants verify agents with Web Bot Auth at the CDN; purchase intent data (cart, limits, validity) is provided as an audit trail for disputes. | Agentic token framework: Driving trusted AI transactions. Sections "Agent registration", "Purchase intent data" (web article, 14 Oct 2025) | Unchanged card rules; intent data is evidence the merchant or issuer can use, not a liability shift. | |
| 3 rows |
AP2 (FIDO Alliance)
| Date | Change | Document and page | Who carries the dispute |
|---|---|---|---|
| AP2 v0.2: Checkout Mandate and Payment Mandate (each open and closed) as signed verifiable credentials; Human Not Present payments on pre-authorised instructions; standardisation moved to FIDO working groups. | Agent Payments Protocol (AP2) specification. Sections "Mandates" and "Human Present vs Not Present" | AP2 provides a non-repudiable audit trail but assigns no liability; the network rules of the underlying rail decide. | |
| 1 row |
American Express
| Date | Change | Document and page | Who carries the dispute |
|---|---|---|---|
| Amex ACE specifications for Account Enablement, Intent Intelligence and Payment Credentials available; Amex Agent Purchase Protection described for the future: eligible Card Members protected from charges caused by agent error when a registered agent sent authenticated purchase intent. | Agentic Commerce Experiences (ACE), American Express. Sections "Developer kit" and "Amex Agent Purchase Protection" | Amex absorbs eligible agent-error charges after the Card Member tries a return with the merchant; subjective intent ("best") is excluded; normal disputes remain. | |
| 1 row |
Open points
A few rows depend on text we could not diff or could not find in public. They are listed with their sources on the corrections page.
Sources
- Visa Core Rules and Visa Product and Service Rules, 24 October 2026, read 4 Nov 2026
- corporate.walmart.com/news/2026/10/Making-It-Possible-for-Agents-to-Shop-on-Behalf-of-Customers, read 4 Nov 2026
- Mastercard trust and intelligence services, read 4 Nov 2026
- Amazon Conditions of Use, read 4 Nov 2026
- Mastercard Transaction Processing Rules, 9 June 2026, read 4 Nov 2026
- AP2 protocol site, read 4 Nov 2026
- FIDO Alliance to develop standards for trusted AI agent interactions, read 4 Nov 2026
- Amex Agentic Commerce Experiences, read 4 Nov 2026
- Verifiable Intent repository, read 4 Nov 2026
- Mastercard Agent Pay Acceptance Framework, read 4 Nov 2026
Last reviewed