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ARTICLE · 30 APRIL 2026

From Assistant To Agent: Navigating The Legal And Regulatory Shifts In AI-driven Commerce

A&O Shearman
A&O Shearman
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AI Agents are transforming commerce by autonomously selecting goods, comparing prices, and initiating payments on behalf of consumers. This briefing explores the complex regulatory challenges and opportunities that agentic commerce presents for businesses, from contract formation and payment regulation to consumer protection and strategic partnerships.

United KingdomConsumer Protection
Nikki Johnstone
Nikki Johnstone
Alex Shandro
Alex Shandro
Jordano Vasquez
Jordano Vasquez
Luca Britos
Luca Britos
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AI Agents are no longer a future invention. Systems that autonomously select goods, compare prices, initiate payments and switch providers on behalf of consumers are already being deployed; regulators are developing their policy positions at speed.

For many businesses (whether merchants or their payment providers), agentic commerce brings opportunity but also raises complex issues across multiple regulatory frameworks.

We held a practical briefing in which we discussed the latest market developments, as well as some key prevailing issues, including: 

  • contract formation and liability 
  • payments regulation, including requirements with respect to consent, software composition analysis (SCA), fraud and dispute resolution 
  • consumer protection and 
  • strategic considerations for firms exploring agentic products/partnerships.

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The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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