What a payment firm can show after a disputed AI agent payment

Monetary Authority of Singapore · Consultation response ·

Supports requiring MPI and SPI licensees, and MAS-regulated stablecoin issuer licensees, to subscribe to FIDReC. Suggests that FIDReC, when it onboards each newly covered firm that accepts payment instructions from a customer’s AI agent, ask what the firm could show if the customer disputed a payment: the mandate in force, what happened to each attempt, and the amount still charged. Asks MAS to set out in guidance what such an institution should keep.

Read the response (PDF, 7 pages)

The document

Title
Response to MAS Consultation P017-2026
Consultation
Consultation on Expanding FIDReC Membership to Payment Service Providers, P017-2026
Question answered
Question 1, limbs i, ii and iii
Capacity
Personal capacity, with a declared interest as founder of True Primary
Submitted
Length
7 pages
Confidentiality
None. Identity published with the submission.

The case it puts

The worked example is an e-wallet at a major payment institution. The customer and the institution agree that an AI agent run by another firm may pay from it, up to S$50 a payment and S$200 a week, to online merchants, for three months, with one payment per purchase.

A payment that goes wrong may fall into one or more of three cases: outside the mandate, mistaken inside the mandate, or made with a misused credential. The response sets out where the customer can complain in each case, how the E-Payments User Protection Guidelines classify the payment, and which complaints FIDReC’s Terms of Reference let it hear.

What it recommends

  1. FIDReC: ask at onboarding. Ask each newly covered firm, for each payment it accepts from a customer’s agent, which records it holds or can obtain, which it cannot, and which do not arise in its service. The list includes the mandate’s terms in force; when the customer authenticated them and when any withdrawal took effect; each attempt’s amount, payee and time; each attempt’s outcome and the net amount still charged; the purchase identifier; and what each approval counted against the period limit.
  2. MAS: guidance on what to keep. Set out what any institution that accepts payment instructions from a customer’s agent should keep.
  3. MAS: classify payments outside the mandate. State that a payment outside a mandate term the institution agreed with the customer to enforce is unauthorised unless the customer separately approved it before it was made, and consider an equivalent classification for cards, digital payment tokens and MAS-regulated stablecoins.
  4. MAS: say which payment service an agent’s provider supplies. Set out in guidance which service, if any, each of three kinds of provider supplies, and so whether it needs a licence.
  5. MAS: count period limits at approval. Expect an institution enforcing a period limit for an agent to count each amount against the limit as it approves it.
  6. MAS: keep the customer’s instruction. Expect a licensed provider that uses the instruction in its licensed service to keep the relevant part for a stated period, preserve it once it knows of a complaint, and give the customer timely access.

No comment on limb ii, the exclusion of money-changing licensees. Two drafting points on limb iii, the amendments to the DRS Regulations.

Sources