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ARTICLE · 22 JUNE 2026

Authorizing Agentic Payments

AI agents are now making autonomous payments for flights, subscriptions, and purchases without transaction-by-transaction human approval. As these agentic payment systems proliferate, a critical legal question emerges: when an AI agent initiates a payment, who bears the risk if the transaction exceeds its delegated authority? This analysis examines the evolving legal frameworks governing authorization disputes between users, financial institutions, agentic payment platforms, and merchants.

United StatesFinance and Banking

AI agents are making payments — booking flights, renewing subscriptions, and buying gifts — without human review and approval for specific transactions using a set of parameters the principal preauthorized. The legal question that arises is whether a particular payment was actually authorized.

This question arises in two contexts: disputes between a user and their financial institution and disputes between a user and the platform initiating payments on their behalf. The first is largely settled — a user who hands credentials to a third party, human or AI, is responsible for what follows unless the financial institution was notified of a revocation or breached its own security procedures. This alert focuses on the second. That is where the real risk lives.

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