CBA Releases White Paper Examining Agentic AI, Consumer Payments, and the Future of Regulation

Paper reflects insights from a broad, cross-sector roundtable of banks, technology firms, regulators, consumer advocates, and payments experts

WASHINGTON, D.C. - The Consumer Bankers Association (CBA) today released a new white paper, Agentic AI Payments: Navigating Consumer Protection, Innovation, and Regulatory Frameworks, examining how emerging agentic artificial intelligence tools could reshape consumer payments-and the opportunities and risks that evolution presents for consumers, banks, merchants, and policymakers.

Agentic AI tools-systems capable of autonomously making decisions and executing transactions on a consumer's behalf-are poised to become a significant feature of the payments and commerce ecosystem in the relatively near term. While these tools offer the potential to reduce friction, save time, and improve financial outcomes for consumers, they also raise novel questions about authorization, liability, transparency, fraud, and the adequacy of existing consumer protection frameworks.

The white paper is informed by a two-day Agentic AI Payments Symposium convened by CBA in Washington, D.C. in Fall 2025, which brought together senior representatives from across the payments ecosystem, including CBA member banks, technology and AI developers, payment networks, fintech companies, merchants, consumer advocates, academics, and federal and state regulators. Discussions were conducted under Chatham House rules to encourage candid dialogue and rigorous exploration of emerging risks and solutions.

"This paper reflects what we heard directly from a remarkably diverse group of experts who are actively building, regulating, using, and scrutinizing these technologies," said Lindsey Johnson, President and CEO of the Consumer Bankers Association. "Agentic AI has the potential to fundamentally change how consumers shop, pay, and manage their finances-but history shows that innovation succeeds when consumers have confidence in the system. Our goal is to help ensure that consumer protections evolve alongside technology, not years after problems emerge."

Background

Key themes explored in the white paper include:

• How agentic payments differ from traditional electronic payments, particularly when consumers are not directly authorizing transactions at the point of sale;
• Potential gaps in existing legal and regulatory frameworks, including the application of the Electronic Fund Transfer Act and Truth in Lending Act to agent-initiated transactions;
• Risks related to misaligned incentives, fraud, data use, and consumer misunderstanding, especially as new payment rails and AI-driven commerce models emerge;
• The critical role banks play as trusted stewards of consumer payments and dispute resolution; and
• Market-based and policy-oriented approaches that could help balance innovation with consumer protection in the early stages of this technology's development.

Importantly, the paper does not call for immediate new regulation. Instead, it underscores the value of early, collaborative engagement among industry participants and policymakers to identify risks, clarify responsibilities, and consider whether existing frameworks-public and private-can be adapted to support safe adoption of agentic payment tools.

"Electronic payments only achieved mass adoption because clear rules of the road gave consumers confidence," said Kelvin Chen, Senior Executive Vice President and Head of Policy. "Agentic payments may be at a similar inflection point. Thoughtful dialogue now can help avoid confusion, consumer harm, and fragmented outcomes later."

The full white paper is available HERE.

CBA Advocacy

• CBA encouraged members of the House Financial Services Committee to build on existing regulatory frameworks and apply them to nonbanks to promote AI innovation in financial services in a letter submitted Dec. 10, 2025.
• CBA responded to the Office of Science and Technology Policy's RFI on AI Regulatory Reform, submitting comments on Oct. 27, 2025.
• CBA operates an "AI Forum," convening senior leaders and technology experts from across CBA's corporate membership to discuss the most prescient AI issues facing banks. The meetings offer members an opportunity to share AI use case experiences and challenges with their peers. They also feature CBA led discussions of the AI regulatory landscape as well as third party presentations highlighting specific bank-focused AI solutions. CBA's goal with the Forum is to provide a space for CBA members to share best practices for deploying AI solutions and to understand the obstacles they face to inform CBA's advocacy efforts.