The default architecture for agentic payments is being chosen now. Visa launched its Agentic Ready programme with HSBC, Barclays and Revolut. Mastercard's Agent Pay is live in APAC. These moves establish cards as the default agentic rail, before anyone seriously asks whether that is the right choice.

Agentic commerce is at the centre of almost every industry conversation this year. Money20/20. London Tech Week. Merchant Advisory Group. British Retail Consortium. The concept is clear: a world where consumers use AI agents to order groceries, manage subscriptions and book flights without a ‘human in the loop’.

On 8 June, Chancellor Rachel Reeves sharpened the conversation. Speaking at the AI Adoption Summit, she told the room that Britain has "a genuine opportunity to lead the world in one of the most promising applications of AI: agentic payments." She backed that with concrete commitments: plans to upgrade payments infrastructure, support digital money, modernise payment regulations, and publish the Financial Services AI Adoption Plan at Mansion House on 14 July 2026.

The question is whether the UK wants to use its AI leadership to continue boosting payments competition and innovation. The building blocks are there. The UK is a world leader in open banking, where Pay By Bank is emerging as a significant alternative to global card schemes.

Pay by Bank now handles 40 million payments in the UK each month and sits on the checkout of major global merchants including Amazon, eBay, Ryanair and JustEat. It is an explicit priority for the UK Government’s National Payments Vision to make Pay by Bank ubiquitous. Given that, how do we ensure agentic payments aren’t card-native by default, and who is responsible for driving that agenda?

Agentic payments shouldn’t mean less choice

Card networks understand how to become deeply engrained: standards. EMVCo, the consortium that defines chip-and-PIN standards, was established by Europay, Mastercard and Visa to write the technical rules that shaped global payment acceptance. It’s responsible for standards including 3D Secure, contactless and most recently, Click to Pay. Today, the Payments Working Group of the FIDO Alliance, the body now developing technical standards and protocols for agentic authentication and payments, is co-chaired by Visa and Mastercard. The shape of tomorrow's agentic infrastructure is being decided in the same rooms, with the same organisations.

In human-present payments, consumers can make an active choice about payment methods at the checkout. This helps competition, saving merchants and ultimately consumers money. In a future agentic payment world, if standards and protocols have been developed primarily by card schemes, there may be less choice.

Why Bank on File is made for agentic payments

Bank on File is the latest development of Pay by Bank. It is the ability — as the phrase suggests — to put your bank (instead of a card) on file with a merchant, and allow payments to be taken in the background, without per-payment authentication.

However, there are key differences between Bank on File and Card on File, which make Bank on File ideally placed to handle agentic payments. It represents a different model of consent, one in which permissions are established upfront, enforced by the bank, and designed to support autonomous action within clearly defined guardrails.

The limits a consumer sets - maximum transaction values, cumulative spend over a defined period, mandate duration - are held and enforced by their bank. A payment that falls outside those parameters is rejected at the point of execution, not disputed after the fact. So whether or not the agent goes off piste, the consumer is in control of what gets spent.

By contrast, under the card Merchant Initiated Transaction (MIT) framework, a consumer authorises recurring charges with no pre-defined ceiling enforced by their bank. The merchant is trusted to charge within reason. If an agent makes an unexpected choice, such as booking premium options when instructed to find the cheapest, or triggering multiple purchases while optimising across suppliers, the consumer's recourse is likely a chargeback, after the money has already moved.

Agentic payments where cards are the only payment option have the potential to exacerbate existing merchant and consumer pain points with chargebacks including their complexity, high costs, slow processes and the refund fraud they enable. Bank on File, by comparison, does not have these pain points baked in.

Outstanding questions

Bank on File fits agentic payments well in theory, but several practical questions remain open before it can work at scale:

• Undefined payee: under existing standards and regulation, Bank on File mandates today are established between a consumer and a specific merchant. In an agentic context, a consumer may not know in advance which merchant their agent will transact with. This means banks don’t know where to send the funds to. Can a mandate be established with an agent platform, covering a range of merchants the consumer authorises it to shop with? The current framework doesn't cleanly support that yet. Resolving this, whether through a new mandate type or regulatory guidance on how existing mandates can be scoped for agent use, is a prerequisite for Bank on File to serve as an agentic payment method.

• Bank identification: Currently, there is no mechanism in payment initiation metadata to flag that a transaction was generated by an AI agent rather than a human. Without that, banks cannot build risk models specific to agentic activity, and consumers cannot easily see (in their bank statements) which transactions an agent made on their behalfSolving this requires standardised agentic payment identifiers embedded in the payment metadata itself, agreed across banks, payment processors and agent platforms.

• Timing: Bank on File for ecommerce is not yet live in the UK. If consumer adoption of AI agents outpaces the rollout of Bank on File, it may not be ready when the market needs it. UK Payments Initiative should continue their work to accelerate the rollout of ecommerce use cases.

• Network effects: Every major ecommerce merchant already accepts cards. Agentic platforms building their default payment infrastructure will lean toward what their merchant base already supports. More specifically, the card networks are building the communication standards that define how agents authenticate and how transactions are verified. While the Pay By Bank network is growing, it may need further regulatory support to ensure that the rise of card-carrying agents doesn’t move payments choice and competition backwards.

None of these issues are insurmountable. But they require deliberate coordination across banks, PISPs, government, regulators and agent platforms, and that coordination must start sooner rather than later to protect the gains in payments competition the UK has made to date. The UK Payments Initiative, established earlier this year, can be a key facilitator of the discussions.

What regulators are already thinking

The FCA named agentic payments as a live policy question for the first time in its March 2026 Payments Regulatory Priorities report, and committed to reviewing whether existing regulation needs to change or whether new rules are needed. The Payment Services Regulations 2017 require explicit customer consent for payment initiation, written for a world where humans make deliberate decisions at the point of transaction. How those rules apply to an agent acting within a pre-set mandate is, in the FCA's own framing, unresolved.

The Mills Review, examining how AI could reshape retail financial services by 2030, addresses similar territory, with recommendations shared to the FCA Board earlier this summer. Separately, UK Finance is examining what a Know Your Agent framework might look like, to verify that an agent is authorised to act on a consumer's behalf before a payment executes.

Assuming the PSR’s mandate to promote competition in payment systems transfers to the FCA, this should also extend, in principle, to the agentic layer. One of the core objectives of HMT’s National Payments Vision is to drive greater competition. Renewal of the UK payments infrastructure likewise seeks to support the development of Account-to-Account payment methods as an alternative to cards.

Taken together, these moves suggest the UK should not simply allow card networks to build the default agentic stack unchallenged. But intent and outcomes are different things. Card schemes are not waiting for regulatory review cycles. The decisions being made now by platform providers about which payment rails their AI agents support will outlast any individual policy consultation. The UK's open banking infrastructure, the formation of UKPI, regulatory appetite and government backing give it a credible chance to carry forward the competition that has flourished in human-present commerce into the agentic era. Whether it does depends on how quickly industry, UKPI and regulators act together.

From architecture to practice

TrueLayer is actively working with merchants to explore what agentic payments could look like in practice: how a Bank on File mandate model could power an agentic payment flow, and what that means for the merchant and consumer experience. The theory of why this architecture fits is strong. What we are building toward is proof that it works.

The UK has the payment infrastructure, the open banking rails, the regulatory intent and now the government's explicit backing to make it a world leader in agentic payments whilst protecting the UK’s most promising alternative to cards to drive genuine competition and choice.

The coming months will demonstrate whether industry builds on that base decisively enough to match the opportunity the Chancellor has put on the table.