In short (TL;DR)
Not autonomously — not today. EU payment rules (PSD2) and Strong Customer Authentication require a human to authorize a payment, and there is currently no mechanism for an AI agent to be treated as an equivalent payer. What's both legal and useful right now is a clear division of labor: the AI prepares, checks and flags; a person reviews and approves. Meanwhile the card networks are building protocols that could change the picture within a few years.
What does the law say today?
Authorizing a payment in the EU is a personal act. PSD2 and the SCA rules expect the payer (a human authenticating with at least two factors) to approve the payment order. Taylor Wessing's analysis sums up the current state: there's no special regime for agent-based payment models, so the ordinary rules apply.
In practice that means three things:
- An AI agent can't be the "payer" — that role belongs to a person or a mandate a person has explicitly granted.
- Standing bank mandates (direct debits, standing orders) are fine, because behind them sits a human-granted, bounded and revocable authorization.
- Handing an AI your online-banking credentials doesn't make its payments authorized: it breaches your bank's terms and leaves the liability with you.
What are the card networks and tech firms building?
The interest is enormous because the stakes are: McKinsey estimates agentic commerce could influence $3–5 trillion in global commerce by 2030. In September 2025 Google announced the Agent Payments Protocol (AP2) with more than 60 collaborators, including Mastercard, PayPal, Adyen and American Express; Visa is developing its Intelligent Commerce program. The shared idea: give an agent a cryptographically verifiable mandate with human-set limits that every party in the chain can check.
The IMF's 2026 note on agentic AI in payments is honest about the open questions: who is liable when an agent errs, how to trace an agent's action back to a human authorization, and what happens when thousands of agents behave the same way at once. Until those questions have answers, the human remains in the approval seat. Finextra's practitioner view draws the same line between what's live and what's pilot.
What division of labor already works today?
The pattern the market calls human-in-the-loop is simple and compliant for a small business:
- The AI reads incoming invoices, verifies the details and matches them against orders.
- The AI drafts the payment-day list and highlights anomalies: a new bank account, a duplicate invoice, an unusual amount.
- A person reviews the list and approves the payments in the bank themselves.
- Every step leaves an audit trail, so you can always see who decided what.
You capture the automation benefit without bending authorization rules. We describe what this looks like across a finance workflow in agentic financial management and, on the invoicing bond, in MCP for accounting AI assistants.
A checklist before you delegate anything financial to AI
- Never share online banking credentials or authentication devices with any tool.
- Keep approval human: the AI proposes, you sign.
- Set amount limits and a dual-approval threshold, for example two approvers above €1,000.
- Demand an audit trail: what the agent did, based on what, and when.
- Verify bank account changes through a separate channel every time; it's also the single best defense against invoice fraud.
Summary
An AI agent can't make payments on its own in the EU today: PSD2 requires human authorization and no agent-specific regime exists. What you can do, and benefit from, is let AI prepare, match and flag while a person approves. That model works now, keeps liability clear, and positions you for the moment protocols like AP2 make mandated agent payments real in Europe. This is a general overview, not legal advice.
Try Bilnex's free invoice processing — the AI reads and prepares, you decide.
FAQ
Can an AI agent initiate payments in the EU?
Not autonomously. PSD2 and Strong Customer Authentication require a human payer to authorize payment orders, and EU law currently has no mechanism for treating an AI agent as an equivalent payer. AI can prepare payments; a person must approve them.
What is agentic commerce?
A model where an AI agent finds products, compares offers, assembles the order and initiates payment within human-set limits. McKinsey estimates it could influence $3–5 trillion in global commerce by 2030; Google's AP2 protocol and Visa's Intelligent Commerce are the first large attempts to standardize it.
Are direct debits an example of AI payments?
Well. A direct debit or standing order rests on a human-granted, bounded and revocable mandate registered with your bank. That's precisely the kind of verifiable mandate the new agent-payment protocols are trying to create for AI.
How can a business use AI around payments today?
Let AI read incoming invoices, verify details, match them to orders and draft the payment-day list with anomalies highlighted — a new bank account, a duplicate, an odd amount. A person reviews and approves in the bank, keeping authorization legal and the audit trail intact.