Target’s Consumer Terms “Your Bot Is Your Responsibility”

Posted on by
Reply

Target updated its consumer terms on March 22, 2026 to clarify that AI agent-initiated purchases are the customer’s responsibility.

  • The timing is not coincidental — it’s a signal that Google’s “Buy For Me” launch is coming,
  • The new language is blunt: if a customer authorizes an AI shopping agent to act on their behalf, those transactions are “considered transactions authorized by you.”
  • Added a disclaimer that it “does not guarantee that third-party AI tools will act exactly as you intend in all circumstances.”
  • Target wants to be very clear about who owns the risk: Your bot is your responsibility.

Google “Buy For Me” Is the Trigger

In May 2025, Google announced its agentic checkout feature: track a price, set your threshold, and when it drops, tap “buy for me.” Behind the scenes, Google adds the item to your cart and completes checkout via Google Pay — without you touching a keyboard.

Target is a named Google Gemini retail partner, announced by Google CEO Sundar Pichai at NRF 2026. This is not a generic partnership. When “Buy For Me” goes live at scale, it will represent the first true machine-to-machine (M2M) agentic commerce program with mass consumer reach. An automated, bypass-checkout flow with no human in the loop at the moment of purchase. Target sees this coming. Their terms update is the legal groundwork being laid before launch.

Why Target Is Uniquely Exposed

Target has the largest card services footprint of any US merchant. Approximately 25 million customers that hold a portfolio including:

  • Decoupled debit (Circle card – aka Target Red Card)
  • Closed loop
  • Co-brand credit (issued with TD Bank)
  • Prepaid products

These cards, with integrated loyalty and discounts, drive roughly 24% of Target’s total sales. It is a massive proprietary stake in payments (and a massive liability exposure if agentic purchases go wrong at scale).

The ACP Problem: Simulating the Consumer’s Device

As I wrote in Device Graph Extinction, Stripe’s Agentic Commerce Protocol (ACP) is currently the most operationally capable agentic payment protocol in the market. ACP is notable for one specific capability: it can simulate a consumer’s device environment, backfilling device telemetry (via Stripe Radar data) for transactions that originate from an agent rather than a human. In plain English: ACP can make an automated M2M transaction look, to a merchant’s fraud system, like a normal human-initiated purchase.

This is a direct threat to the 30-year fraud investment that merchants like Target have made. Their risk models depend on behavioral signals — time on site, device fingerprints, navigation patterns. An agent that simulates a device but bypasses the checkout UI strips all of that signal away.

Target’s new terms are also a message to OpenAI and Stripe ACP: You may be able to simulate and bypass controls. But if you do, the consumer owns the fraud — not us.

The Paze Problem: Why Target Won’t Accept a Bank-Led Solution

As I outlined in my analysis of UCP Enables a New Economy, the US bank consortium’s Paze wallet has failed to gain merchant traction, and that failure is structural and political.

Target will not participate in an agentic commerce framework that excludes its proprietary card portfolio. The Paze consortium represents only the top 6 V/MA Issuers. It excludes other cards and also serves as a blocker to V/MA (DAF and TAF) rule sets. If Target is going to take risk in agentic, it certainly isn’t going to add to that risk in a new payment system they have not control over, AND excludes their cards (Duh).

Target’s logic is straightforward: we will not accept an agentic architecture that pushes risk onto us for transactions we can’t see, can’t control, and can’t dispute through our own instruments.

Merchant of Record and the Checkout Control Imperative

IMHO Visa and Mastercard have built a very solid technical and rule infrastructure to manage agentic risk. DAF (Device Authentication Framework) and TAF (Transaction Authentication Framework), along with VAS services like Visa TAP and Mastercard AgentPay, are designed precisely to govern M2M payment flows with liability shift potential. It is open, and standardized.

While AgentPay and Intelligent Commerce will play in ROW, US Banks are effective blockers. For example, AP2 mandates could be sent in “buy for me” BUT retailers own the risk, don’t control authorization process (or including AP2 Mandates within a 3DS payload), AND US banks have no plans to act on them.

Without issuer participation in a formal liability shift framework, merchants like Target bear 100% of the fraud risk — as they do today in US eCommerce. A “Buy For Me” flow that bypasses merchant checkout also bypasses the device data capture that powers Target’s risk models.

Target must own the checkout experience. It is not stubbornness. It is the only available mechanism for risk management in the absence of a network-governed liability shift that includes their full card portfolio. As I noted in UCP Enables a New Economy, UCP’s embedded checkout (iFrame) flow preserves exactly this.

Google Buy For Me represents the first REAL Machine to Machine (M2M) agentic transaction flow. Since merchants own the risk, they can set the consumer terms. Target’s consumer terms act as a liability fence before the product launches. If a consumer’s Gemini agent buys 47 shower curtain rings at 3am, Target wants it on the record that this was an authorized transaction. I also see it as a message to the ecosystem. Any AI platform (Gemini, ChatGPT, Stripe ACP) that attempts to simulate a consumer device or bypass the checkout flow is operating in a zone where the consumer owns the consequences. Target will not absorb the cost.

Until network stakeholders align, the “Your Bot Is Your Responsibility” policy is what the liability infrastructure looks like at the starting line of M2M, I believe the V/MA frameworks will succeed in long term, but Issuers and merchants must buy in.

Related reading: UCP Enables a New Economy | Stripe Agentic Commerce Protocol (ACP) | Device Graph Extinction

Distributed Ledger Governance

Posted on by
Reply

Long Blog – Explaining Visa, Canton, and the Architecture of Super Validators

Executive Summary

  • Stablecoin Industrialization: DLT is transforming settlement and interbank networks. There is more than one approach, ranging from closed networks to open on-chain. We discuss differences between Ethereum, JPM Kinexys and Canton Network.
  • Governance as a Catalyst: Governance and operational oversight have surpassed technical specifications as the primary factors driving institutional participation in distributed ledgers.
  • Visa’s “Super Validator” Role: Visa expands their network governance role into Canton as a Super Validator, applying its established “network of networks” model and operational rigor to a privacy-preserving institutional infrastructure. Trust requires a commercial construct and Visa has it.
  • Canton’s Privacy Architecture: Unlike public chains, Canton uses a “proof-of-stakeholder” model where transaction data is encrypted and distributed only to parties with a “need-to-know”.
  • Super Validators Explained: Visa provides services to manage the “Global Synchronizer,” providing secure sequencing and atomic settlement across domains without ever decrypting sensitive transaction payloads.
  • Transition from Silos: The native deployment of JPM Coin onto the Canton Network signals a definitive shift from closed “digital silos” to an interoperable, institutional-grade ecosystem.
  • Solving the Interoperability Paradox: The Super Validator model addresses the “SWIFT challenge” by allowing banks to maintain private ledgers while enabling the universal connectivity required for global trade. Yes there will still be closed networks, but Canton is shaping up to be the best universal bank network.
Continue reading →

Explaining the Death of OpenAI’s Instant Checkout

Posted on by
Reply

Short Blog

To my regular readers, you know the flow of data within a network is complex (see Data Games). The news that OpenAI is effectively shelving its “Instant Checkout” initiative in favor of a referral-based “conversational commerce” model shouldn’t come as a surprise. While the tech press might frame this as a strategic pivot, those of us in the eCommerce trenches know it for what it is: a collision with merchant’s role in risk, costs, CX, control and their own AI dreams.

OpenAI attempted to solve its monetization problem by trying to seize control of the top of the funnel, betting that the sheer volume of consumer demand would force merchants to bow to their interface. They were wrong. They fundamentally miscalculated the power dynamics of the transaction and the complexity of the global conversion funnel, a funnel that Google understands intimately because they serve both ends of it globally (ie merchant partners).

Continue reading →

MPP Phase 2 Live – Ask Tom Goes Agentic

Posted on by
Reply

Long blog – First 2 Pages are economic implications, last 6 pages are tech deep dive

MPP is a big deal because value exchange enables specialization and market forces to operate (as discussed in last week’s MPP – Addressing the Internet’s “Original Sin”.MPP and X402 are BIG.. really big. A whole new market. This isn’t about cash replacement or taking share from xx this is about enabling a new Economy. Today’s blog is 4 paragraphs of the economic implications (for investors and CEOs), followed by 4 pages on tech detail covering what I built. Please note “Ask-Tom” is just a model of an x402 service…. of course it won’t generate much demand (service ID is at bottom).

First, let me try to explain why this is such a big deal from an economic perspective. The foundational driver for MPP’s success is the radical reduction of transaction costs through standardized commercial terms. As outlined in my 2016 blog Small Wins, the forces that once drove asset-heavy, integrated organizations are atrophying in favor of “refragmentation” and specialized networks. Historically, the economic cost of inking a bilateral contract for every micro-interaction was prohibitive (ex “Account Creation” bottleneck that stifled agentic autonomy). Following the principles of Ronald Coase’s Transaction Cost Economics, MPP and x402 provide the multilateral governance and common commercial rules necessary to bypass these friction points. By establishing trust and speed through a common interface, these protocols allow for the “Small Win” of a single transaction to scale into a global network effect, where the cost of connection approaches zero.

This standardization enables the “Value Assembly” of “super-specialists” who can target previously unreachable “shale deposits” of niche market demand (see Network Effects and Value Assembly). A successful network enables specialists like “Ask-Tom” to provide high-value, grounded intelligence without the overhead of building independent settlement or reconciliation infrastructure. This is far beyond mere “agentic commerce”; it is an evolution in how software and hardware interact with EVERYTHING ECONOMICALLY. For example, MPP’s session-based economics provides a virtual “bar tab” for agents to execute tasks within human-granted budgets, paying only for precise resource consumption. This creates a sustainable commercial model where the incentives for specialization and market forces to operate on software service at a hyper granular level. Market forces in turn encourage specialists to solve increasingly granular problems across diverse domains, and unlocks the “shale deposits” of data that doesn’t play. I’ll discuss what this could look like next week as a follow up to Value Assembly.

Continue reading →

MPP Test – Demonstrating Significance: Phase 1 is Live

Posted on by
1

For over 60 years we have been focused on human-centric communication in our networks. While we still have payment problems in this interaction, a whole world is evolving where machines interact with other machines. The scale of this interaction is limited by value exchange — after all, who wants to spend resources answering a bot’s question if they are just stealing your data and delivering no new customers (see this blog covering Cloudflare CEO Matthew Prince’s comments).

Continue reading →

MPP (and X402) – Solving the Internet’s “Original Sin”

Posted on by
Reply

Yes another agentic payment acronym. This one is important enough to remember. Where AP2 and ACP address agents acting on behalf of humans, X402 and MPP are about agents paying agents. My friend Simon Taylor just put together one of his all-time best posts on MPP and The Intention Layer. Today’s blog is a follow-up with a bit more of a comparison, and why this is a big deal from a payment and economic perspective. My key takeaways from Simon’s post

  • The “Skinny Master Account”: Taylor suggests that humans will grant “intent” (a budget and a goal) to an agent. MPP’s Session model perfectly mirrors this: a human “locks” $50 into a session (the intention), and the agent autonomously spends it in sub-cent increments (the execution).

  • The Substrate of AI: Taylor points out that AI thrives on Structured Text (Markdown). Ironically, legacy finance (ISO 8583, NACHA files) is essentially structured text. MPP acts as the “translator” between the agent’s markdown-based intentions and the rigid requirements of the global banking system.

  • The Outcome: The winner won’t be the protocol that is “most decentralized,” but the one that most effectively manages Trust and Permissioning. Stripe and Visa, as the incumbent trust-layers of the internet, are better positioned to solve the “Agentic Spend” problem than a pure-crypto protocol.

You need to be logged in to view the rest of the content. Please . Not a Member? Join Us

Stablecoins Are Not Free — Why They Are A RAIL in Consumer Payments

Posted on by
Reply

There’s a narrative running through payments circles right now that goes something like this: stablecoins will replace card rails because they’re cheaper, faster, and programmable. Stripe makes acceptance easy. Card networks are too slow to innovate. Machine-Machine payments need programmability. GENIUS Act passed. The future is obvious.

I’ve been writing about stablecoins for over two years, from the case for stablecoin as a trust platform to the ECB’s monetary sovereignty alarm. And I keep coming back to the same conclusion: stablecoins are not a replacement for cards, but rather another rail with cards retaining their role as the layer of abstraction for multiple networks (as they do today). They will do well where cards don’t play (micropayments, B2B and uncarded markets).

Here’s why (and why that matters more than you might think).

Continue reading →

Amazon vs Walmart: Two Very Different Bets on Agentic Commerce

Posted on by
Reply

Amazon and Walmart are the two dominant forces in US retail. They are also taking fundamentally different approaches to agentic commerce — and those differences will shape how payments, checkout, and consumer trust get redesigned over the next three years. This divergence has direct implications for card networks, payment processors, authentication infrastructure, and anyone building for the future of checkout.

Amazon: Closed Stack, Agentic Inside-Out

Amazon is building agentic commerce from the inside out — embedding AI agents deep into its own proprietary infrastructure and deliberately keeping external agents at arm’s length. The strategy is control through ownership.

Continue reading →

Agentic Recap – Last Week’s Big Announcements. 

Posted on by
2

Sorry for delay.. Just had a new grandson on Wednesday, and everyone is doing fine. One quick note, if your looking for one of my old posts, or topics like AP2, try my new search. Completely rebuilt to look through my posts and all “trusted” authorities on a topic.

Exec Summary

Last week’s flurry of announcements confirmed our thesis: Agentic commerce is off to a slow start, and the “machine-to-machine” (M2M) revolution is currently a “human-in-the-loop” (HIL) reality. Despite the hype, machines aren’t autonomously settling transactions yet; they are discovery engines landing consumers on retailer checkout pages. While “lab” pilots show machine to machine transactions are technically possible – in a lab. The reality is conversational commerce, more like an enhanced search. 

Key Items covered today

  1. Agentic Hurdles are huge. Changing consumer behavior, shifting risk, economic “Gordian Knot” of value creation and pricing, Trust and Authorization, …etc. The payment piece is the “easy” party.  There will be no wholesale change in the next 2-3 years, merchants and marketplaces want to retain consumer behavior and leverage their own data, the future for most transactions will be a checkout on the merchant’s website. 

  2. Card networks are firmly established as the payment method and will retain their role as the identity infrastructure of the internet. Stablecoin is a settlement  innovation, and cards can sit on top. Visa is at least 2 yrs ahead of MA. MA’s agent pay integration to Google’s AP2 mandates is still a lab experiment that will require both Issuer and merchant approval. For example Banks will want the full intent mandate to take the risk, something neither Google nor Merchants will be keen to share. 

  3. OpenAI’s abandonment of their own wallet is very significant and a realization that merchants hold the keys in the early days of eCom, with many major merchants wanting a PAR to reference COF, not a tokenized credential where they own the risk. 

  4. Visa’s two big announcements are significant. The partnership with Bridge to issue stablecoin linked cards in 100 markets will propel a new market for cards in M2M based UCs.  “INTELLIGENT AUTHORIZATION” a universal acceptance API against different schemes and payment types, thus eliminating the need for costly infrastructure rebuilds. 

  5. When perfect authentication does happen, it will be a watershed moment for payments and every entity that provides risk services. Processors will be particularly hard hit, afterall how will processors differentiate when every payment type has 0 fraud and 100% authorization rate. Shopify and other merchant service providers (MSPs will gain significant leverage and expand their own VAS). This dynamic explains why Stripe is investing so heavily in Stablecoin, its an effort to differentiate and improve speed and a developer community in something unique.

You need to be logged in to view the rest of the content. Please . Not a Member? Join Us

Stablecoins and Monetary Policy: The ECB Confirms What Italy Said Last Year

Posted on by
Reply

The ECB published a study today warning that stablecoins could erode retail deposits across the eurozone and undermine the effectiveness of monetary policy. The finding is notable — not because it’s new, but because it’s taken this long for the institution to officially say it.

As I related last May, Italy’s Finance Minister Giancarlo Giorgetti made exactly this argument, warning that the displacement of traditional bank deposits by dollar-denominated stablecoins represented a direct threat to European monetary sovereignty. His remarks were largely dismissed at the time as political protectionism. The ECB’s study vindicates the concern. The mechanism is straightforward: if depositors move funds from bank accounts into stablecoins, banks lose the deposit base that anchors their lending capacity — and the ECB loses its primary transmission channel for monetary policy. Rate changes simply don’t land the same way when the money isn’t sitting in a regulated deposit account.

You need to be logged in to view the rest of the content. Please . Not a Member? Join Us