In the digital euro, an AI agent pays through the customer's own bank

On 28 September 2026 the European Central Bank (ECB) invited companies to join a new round of its innovation platform for the digital euro. Applications close at 17:00 CET on Monday, 9 November 2026. The topics include AI agents, micropayments and, in the long version of the call, interactions between machines. Several trade outlets reported that the ECB would test payments made by AI agents.

The wording of the call does not support that reading. AI agents sit in the “exploration” workstream, a series of workshops the ECB plans to hold at its Frankfurt headquarters in the first half of 2027. Prototypes are built in the “experimentation” workstream, which covers conditional payments, electronic receipts, split payments and app features. The question that matters more to banks has already been settled elsewhere. In their negotiating mandates on the digital euro regulation, the Council and the European Parliament both exempt the provisions on payment initiation services. A provider whose agent is meant to pay on a customer's behalf would therefore have no statutory right of access to a digital euro account. It would need a contract with the institution that holds that account, which in most cases is the customer's own bank. The exemption applies to all payment initiation services and does not mention agents. Agents are simply the use case in which it shows most clearly.

This article analyses the negotiating positions as they stand. It does not forecast the outcome. Trilogue talks began in July, and no agreement had been reported by the cut-off date of 30 October 2026. The scheme rulebook is still a draft. Because the Council and Parliament want the same exemption on this point, there is little reason to expect the exemption to disappear in trilogue. For anyone running payments, the question of agents in the digital euro thus lands on their own desk rather than at the ECB.

The ECB places AI agents in its 2027 workshops, not in its prototypes

The innovation platform began in October 2024. In its first round, according to the outcome report published in September 2025, the ECB selected around 70 participants from more than 100 applicants. The new round has two workstreams. Under “experimentation”, participants are to build proofs of concept and prototypes between January and June 2027. They work under a contract with the ECB and are not paid. A footnote in the long version narrows the scope considerably: every participant acts “as simulated PSPs” (payment service providers), the tests cover the link between the provider and its back end, and they expressly exclude “complete end-to-end transaction flows”. An agent acting for the payer cannot even appear in that test environment.

AI agents belong to the “exploration” workstream. The long version describes it as a series of workshops at ECB headquarters with a particular focus on “AI-enabled payment experiences, AI agents, micropayments and machine‑to‑machine interactions”. The aim is to explore what these developments might mean “for the future design of the digital euro”, assessed against privacy, trust, user control and data protection. The short version on the ECB website says “AI agents and interactions among them” where the long version says machines. Piero Cipollone, a member of the ECB's Executive Board, had already spoken about “machine-to-machine use cases” to the European Parliament's Economic and Monetary Affairs Committee on 24 March 2026. AI also appears in the prototype workstream, but there it means “AI-enhanced features” in the apps of payment service providers: tools for people, not agents.

One sentence of the long version does not appear in any of the reports reviewed. Cybersecurity, fraud prevention, compliance and risk management are, according to the call, “outside the scope of this work”. It would be wrong to conclude that the ECB is leaving agent fraud to the banks. The exclusion applies only to the workshop. The rulebook has a separate fraud component, discussed below. A workshop is admittedly the most a central bank can offer without a legal basis: any decision to issue the digital euro has to await adoption of the regulation. The ECB says as much in the call itself.

The line between conditional payments and programmable money is not new either. The ECB defines conditional payments as “transactions that are automatically executed when predefined conditions are met”, while programmable money comes with restrictions on its use, “like a voucher”. The 2025 outcome report already stated that the digital euro would never be programmable, and Article 24(2) of the Commission's 2023 proposal writes that into law. In the first round the ECB tested the reservation of funds in a simplified simulation, with no real euros moved and no business-to-business payments, according to the outcome report. It concluded that the current design can “successfully enable” conditional payments. Whether agents will one day use those building blocks, the report does not say.

The Council and Parliament both withhold a right of access from payment initiation services

For commercial bank money, the legal route for a third-party agent is already mapped out. Under the second Payment Services Directive (PSD2), a licensed payment initiation service can trigger a transfer from a customer's account with that customer's consent, and the account-holding bank has to grant access without requiring a contract. An earlier article on this site described how that works for agents in the debate about an agentic bank run. The Commission's proposal for the digital euro, published in June 2023, carried the model over. Under its Article 5(3), the payment services rules were to apply to digital euro payments without exception, and recital 30 named payment initiation services as a possible additional service.

The Council changed that in the negotiating mandate it adopted on 17 December 2025. The future payment services rules apply to online digital euro payments “with the exception of: the provisions on payment initiation services”. Recital 10a spells out the consequence. The Council justifies the exemption on licensing grounds: since the services every distributor must offer include a digital euro account, a provider licensed only for payment initiation could not, in principle, build digital euro services on its licence, according to the recital. Account information services keep their access right in the Council text. An agent could read the balance, but it could initiate the payment only under a contract.

The next sentence covers the reverse case: a provider licensed only for payment initiation may offer such services in the digital euro “by contracting with any account servicing payment service provider distributing digital euro payment services”. Parliament wrote the same exemption into its own text. The report of the Economic and Monetary Affairs Committee, with Fernando Navarrete Rojas as rapporteur, dated 26 June 2026, exempts “the provisions on payment initiation services” in Article 5(3)(a) as well. On that basis the plenary voted 416 to 169 on 9 July to open negotiations. The same report still lists payment initiation as a possible additional service in a recital, and the two passages do not contradict each other. The service remains possible. Only the statutory right of access is missing.

Anyone who has worked in futures markets will recognise the structure from clearing. A non-clearing member can trade only under a contract with a general clearing member, which carries the positions vis-à-vis the central counterparty and therefore sets the conditions, the limits and the price. In the digital euro, the account-servicing institution takes that role for every agent provider. The Council has not locked the door for good, though. Under Article 41(4a) of its mandate, the Commission is to report no later than three years after first issuance on “whether payment initiation service providers should be permitted to provide ancillary digital euro payment services”, taking account of open banking, innovation and payment service providers' business models. Parliament's report contains no such review clause. The ECB is aiming for first issuance in 2029, according to Piero Cipollone, provided the legislation is completed by the end of 2026. On that timetable the Commission's report would fall due in the 2030s.

Account money, cards and the digital euro open three different doors to the agent

Set against the other two payment routes, the construction looks unusual. A card network in pilot operation and central bank money still lacking a legal basis cannot usefully be compared on timetable. Account money and cards both run on commercial bank money, so the comparison here is the route of access. With account money, the law opens the door: the payment initiation service has a right of access, and strong customer authentication (SCA) secures every initiation. With cards, the networks' rules open the door. Mastercard announced on 2 June 2026 that “all Mastercard issuers in Europe” had been enabled for Agent Pay at network level, while Visa launched its Agentic Ready programme on 17 March 2026, starting in Europe according to the company. Both rely on tokenised card credentials and passkeys. These are the providers' own statements. With the digital euro, under both mandates, only a contract with the account-servicing institution opens the door.

Christopher Waller, a governor of the US Federal Reserve, set out the questions that attach to that difference at the Sibos conference in Miami on 29 September 2026, a day after the ECB's call. With agentic payments, he said, the question shifts “from proving that a buyer is an authorized payer to proving that an agent has the authority to pay on the buyer's behalf”. On liability, he asked a simple question: “Who is on the hook if an agent makes the wrong purchase?” Christopher Waller leaves the answers to the industry, noting that card networks are already publishing methods to register agents and log cardholders' approvals. HM Treasury raised the same questions in a consultation in July and left standards for agents to the industry. In the digital euro, on the current mandates, those questions have a clear address: the account-servicing institution. That is where it is likely to be decided which agents may pay, within which limits, and who is liable for a wrong purchase, unless the legislator rules otherwise.

Placing agent access with the account-servicing institution can be defended on stronger grounds than the Council's licensing argument. A bank that governs agent access by contract can set liability and limits cleanly, rather than deriving them from rules written for people. The card industry has run on contractual access for decades, and nobody regards it as closed for that reason. In cards, however, one network grants access across all issuers at once. In the digital euro, each agent provider has to negotiate with each account-servicing institution separately for as long as no common standard exists. In its prototype workstream the ECB intends to examine whether a “market-provided common conditionality layer” between payment service providers and merchants would make sense. No such standard is planned for the agents themselves.

Reservations depend on the merchant and on the holding limit

Even with a contract, an agent in the digital euro meets a second constraint, this time in the rulebook. The draft rulebook (version 0.91, dated 2 July 2026), which is expressly preliminary and non-binding, covers standing orders, recurring payments and pre-authorisation. Footnote 22 says a pre-authorisation is the same as a reservation in the ECB's system. It is meant for cases where the amount and timing are unknown at checkout and the customer pays once the goods or services have been used. It is offered to the merchant, who needs certainty of payment. The pattern fits an agent buying from a known merchant. It does not cover an open budget that lets an agent shop across different merchants over a week.

Then there is the holding limit. Under business rule TM-050-003, reserved amounts count “to the calculation of the holding limit and cannot, in total, exceed the holding limit”. The level of that limit is still open, and the Council and Parliament envisage different procedures for setting it. An agent that blocks funds for several purchases at once uses up its user's headroom. Topping up from the linked current account then requires the user's express consent under the legislative text. Admittedly, most purchases an agent makes need only an ordinary payment initiated on the user's behalf, with no reservation at all. The rulebook expressly allows authorisation by “a third party acting on behalf of the payer”. The reservation becomes a constraint only where an agent has to pay before the amount is known.

The ECB appears to see the gap. Its prototype workstream will also examine how conditional payments could work “without having to reserve funds”, for recurring payments, for instance. A spending cap of the kind that Google's Agent Payments Protocol (AP2) sets for open budgets is therefore closer to the ECB's agenda than the workshop label suggests. Anyone wanting to build such a use case will find a better home for it in the prototype workstream on conditional payments than in the AI workshop.

The Eurosystem's fraud screening is not yet designed for agents

For fraud, the digital euro has a component of its own within the Eurosystem. Article 32 of the Commission's proposal allows the ECB to set up a general fraud detection and prevention mechanism, and the Council has kept it. The rulebook calls it Risk and Fraud Management, or RFM. Under rule RMR.07, every payment service provider must request a risk score for each online payment, whether between individuals, in e-commerce or at the point of sale. The decision to reject, hold or release a payment remains with the provider under RMR.06. The rulebook encourages providers to feed the score into their own checks without obliging them to.

This mechanism bears on an observation Christopher Waller made in Miami. Existing fraud detection systems are “calibrated to human behavior”, he said, and may not translate well to agents, so the models will need recalibrating for agent payment patterns. Version 0.91 of the rulebook does not mention agents, and the ECB's AI workshop expressly leaves fraud prevention out. An agent paying twenty small amounts to data providers at three in the morning looks, to a model trained on people, like a hijacked account. The mechanism has a home and an operator, but the rulebook does not yet recognise agents.

Recommendations for payments teams, product development and digital euro programmes

Glossary

Christian Schablitzki – the agentic banker

Strategy & Management Consultant · Agentic AI expert for financial institutions

More than 20 years in investment banking and derivatives trading, followed by over 10 years advising financial institutions. Certified as Claude Partner – Claude Code (Anthropic), as well as in Google AI, Generative AI Leader (Google Cloud) and IBM RAG and Agentic AI.

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