Understanding ApplePay in PIN Debit

Payment Geek detail on the EMVCO Dependencies of Debit and How Cap One Solved It

This is a technical addendum to today’s post on the reported JPMorgan/BofA/Wells/PNC exploration of buying Fiserv’s Star network. That post laid out five business and political reasons the deal is unlikely to happen. This one goes underneath the business case to the technical architecture that makes the wallet portion (ie ApplePay, GPay, SamsungPay) of the problem particularly ugly for any bank that thinks owning a PIN debit network gets them out from under Durbin.

The short version: an issuer that buys Star cannot simply route its ApplePay volume through Star. The tokenization and provisioning plumbing that makes Apple Pay work belongs to Visa and Mastercard, sits inside a standards body (EMVCo) that issuers are not members of, and is architecturally structured around the card brand on the card (not the issuer that issued it). A bank that owns Star still can’t put a Star token in Apple Pay; it is a new AID in the phone.

Continue reading

Are US Banks Really Considering a Durbin End Run with FISV’s Star?

(Paid Subscriber Research)

Yesterday’s WSJ story that JPMorgan, Bank of America, Wells Fargo and PNC have held “preliminary and tentative” talks to buy Fiserv’s Star debit network is being read as the opening shot in a big-bank campaign to escape Durbin. My first reaction: this is a bit of old news. Fiserv and its private equity suitors have been shopping Star as a spin-off for the better part of four years. Every time the pitch surfaces, the same five objections surface with it. Nothing about the current version of the deal has removed those objections; if anything, the political climate has made them harder.

Before I get to why I don’t believe it will happen, a quick refresher on the business logic, because that logic is real, and it explains why Fiserv can keep the pitch alive.

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

Challenger Banks: What the Sell-Side is Telling Us

July 2026 — Tom Noyes Eight months ago I wrote The Neobank Revolution? Not how I see it… after sitting through FinTech NerdCon and listening to the Nubank co-founder and Chime present. My verdict was skeptical: growth is not profitability , the US addressable market is structurally unattractive, and the liabilities of every neobank combined barely register on JPMorgan’s balance sheet. I was right about some of it. I was wrong about enough of it that this update is warranted and this time I want to ground the analysis in what sell-side analytsts are publishing, not just my own read. The most important piece of new evidence: Josh Levin at Autonomous Research published a 21-page report in September 2025 titled “Digital Banks & Fintech: Look, mom, we’re all grown up!” His central thesis is that these companies have crossed into what he calls institutional adulthood : the shift from growth-at-all-costs to profitability, and the embrace of the regulation and compliance they once rebelled against. Combined with the FT Partners + BCG Global FinTech Report 2026 (May 2026), Wells Fargo Equity Research’s Probing the Privates in Payments (June 2026), and Robert Wildhack’s Autonomous coverage of consumer fintech, we now have a rich analytical picture. This blog draws heavily on that work. What the Data Actually Shows The single most important chart in Josh Levin’s report plots ARPU against pre-tax Return on Assets . It shows something counterintuitive that changes how I think about this category: The companies with the lowest ARPU have the highest profitability. Levin’s Chart 6 (using 2024 data, pre-tax to strip out different tax regimes) places the peer group as follows: Company Pre-tax ROA PBT Margin Total Assets Nubank ~6% ~30–35% ~$50B Revolut ~5% ~45–50% ~$35B Fineco ~3–4% ~65–70% ~$41B SoFi ~0–0.5% ~5–10% ~$36B Monzo ~-0.5% ~0–5% ~$25B Chime ~-1.5% negative ~$4B Source: Josh Levin, Autonomous Research, “Digital Banks & Fintech,” Sep 2025. Levin’s fifth takeaway captures this cleanly: “Nubank and Revolut stand out in that they combine high pre-tax ROAs with high PBT margins. They defy the conventional wisdom that high ARPUs drive profitability — the most profitable fintechs master the art of efficiently monetizing tens of millions of customers rather than extracting maximum value from smaller customer bases.” That is a genuine shift from the 2005-era “high-value customer” playbook I grew up with in banking. Nubank and Revolut have proven you can build a profitable bank by monetizing tens of millions of low-ARPU customers efficiently — provided the cost structure supports it. The second observation worth flagging: geography matters. Levin notes: “Companies operating primarily or totally outside the US demonstrate better profitability than do companies operating primarily or exclusively in the US.” Non-US companies (Nubank, Revolut, Fineco) cluster in the upper right of the ROA chart. US-primary companies (Chime, SoFi) cluster in the lower left. That is not a coincidence, and I’ll come back to it. Four Playbooks, Not One My 2025 piece treated challenger banks as a category. Levin explicitly rejects that framing: “Fintechs going after the banking value chain are more dissimilar than they are similar when it comes to business model, marketing positioning and monetization strategies.” The result is four genuinely different strategic playbooks. Revolut: The Global Financial Super-App Revolut has the most aggressive international scaling story in financial services. At year-end 2025 it had 68.3 million retail customers (up 16 million in 2025 alone), 767,000 business customers , and £4.5 billion in revenue growing 46% year-over-year with payment volumes of £1.3 trillion (up 65%). Its media-reported valuation moved from $75 billion in November 2025 to $115 billion by June 2026. (Wells Fargo Equity Research, Probing the Privates in Payments , June 2026.) In March 2026 Revolut submitted its US national bank charter application to the OCC and FDIC. It received its UK banking license on 11 March 2026, and launched full banking operations in Mexico. It committed £10 billion of investment for international growth 2025–2030. The strategic pivot is captured in CEO Nik Storonsky’s own words, cited by Levin: “For a long time I wanted to be as less regulated as possible, it was completely the wrong decision.” That is the sound of institutional adulthood. Revolut is transitioning from a fee-and-FX play into a full deposit-taking bank capable of running a lending book. Its retail lending is small today but expanding fast with the mechanics of NIM generation are being built out country by country. Monzo: The Primary Relationship Hub Monzo has done something every bank wants and few achieve: it has become the main account for its customers . Wells Fargo’s June 2026 report shows Monzo delivered £1.7 billion in revenue (+42% YoY) , £73 billion in card spend (+32%), and 15.2 million customers , up from 12.2 million a year earlier. Three consecutive profitable years. This is the Egg model I wrote about at Citi — build genuine product and service value, become the primary relationship, monetize from there. Monzo is executing it better than most legacy banks. Note: TS Anil was a Citi colleague of mine running GCG Retail across Asia during my time. He is certainly one of the best retail bank CEOs on the planet. But there is a critical new data point that changes the US narrative. On 31 March 2026, Monzo announced it would cease US operations , pivoting back to UK and European growth. If the best-executed primary-account challenger bank in the world walked away from the US market, that tells us something important about the barrier height. Nubank: The LatAm Credit Powerhouse Nubank is the clearest proof of a new model that works at scale. 105 million+ customers across Brazil, Mexico, and Colombia. A 33% ROE that most US regional banks would envy. Stock returns since its 2021 IPO: +551% versus S&P 500 +118% (Levin-Sep25). The engine is elegant: near-zero customer acquisition cost via digital accounts for the underbanked, then conversion into high-margin proprietary credit products at Latin America’s historically elevated interest rates. $41.9 billion in consumer deposits funding a $32.7 billion credit card and personal loan portfolio. The FT Partners (Craig Mauer) + BCG report puts an important number on the structural tailwind: Since Nubank launched in 2014, the unbanked population in Brazil has declined from ~30% to 10%. That reduction was not an accident — it was a policy priority, catalyzed by Nubank and by Brazil’s PIX instant payment rail, which the BIS reports “had signed up 67% of adults a little over a year after launch.” Nubank rode a wave of financial inclusion that the incumbents had left uncovered. Chime: The US Mainstream Liquidity Platform Chime is the most misunderstood of the four. It is not a bank. It operates through sponsor banks (The Bancorp and Stride Bank) that hold its deposits. Its revenue is roughly 75% interchange (Levin-Sep25) — a structural exposure to interchange rule changes that Nubank and Revolut do not share to the same degree. The pivot underway is real. Chime has built a proprietary consumer liquidity stack: SpotMe (overdraft advance secured against direct deposit), MyPay (paycheck advance launched late 2024), and Instant Loans (small-dollar, not secured against direct deposits — the nascent piece). Platform-related revenue reached roughly 33% of total by 3Q25. The concern Autonomous Research is raising loudly is that Chime’s borrower base is precisely the segment now showing stress. Robert Wildhack’s October 2025 note titled “Schrödinger’s Consumer” argues the US consumer is bifurcating: “The economy is separating into one of haves, and have nots. On the latter, the effect seems most acute among subprime or lower end consumers.” Wildhack cut his Chime 2025 EPS estimate from -$2.37 to -$4.40 and rates the stock Underperform . His summary of Chime’s positioning is worth quoting: “Chime sits in the crosshairs if stress on the lower-end consumer is, in fact, emerging.” That is a very different picture from the “Chime as US mainstream success story” narrative dominant in 2024. Where I Was Wrong in 2025 My 2025 argument had three legs. Sell-side research has invalidated one, refined another, and confirmed the third: 1. The profitability trajectory. I framed profitability as the open question. It is no longer open — at least for Nubank and Revolut. Levin’s data is unambiguous. Monzo has three consecutive profitable years. Chime is EBITDA-positive though GAAP profitability remains elusive. My “fewer than 5% of neobanks break even” framing was accurate for the category overall but misleading for the leaders. 2. The bottom 40% is not universally unprofitable. This is the correction I most need to make. I argued last year that neobanks were absorbing the bottom four deciles of retail banking because incumbents had (correctly) determined those customers were structurally unprofitable. Nubank has disproven that at scale. But this deserves the sell-side’s own caveat, because the more important question is what other markets will this work in? The FT Partners + BCG report identifies four structural preconditions that enabled neobank success outside the US: Legacy players that underinvested in digital — leaving obvious gaps Large financially underserved populations — providing low-CAC viral growth Clear pain points (FX fees, no credit access, high incumbent fees) Structurally lower cost-to-serve through digital-only models Bain Capital’s Matt Harris, cited in the same report, put the implication for US expansion bluntly: “Whether a historically successful fintech can succeed in new markets depends on two things — first, the extent to which they find comparable market structures in other countries. Second, what competitive advantages can they port over from their existing codebase, regulatory status, team, brand, etc.? Neither would suggest the US is an easy market for most global competitors to enter.” The FT Partners + BCG conclusion is similarly direct: “The US is a different challenge on nearly all of these dimensions: It is already crowded with trusted incumbents and scaled domestic fintechs, digital acquisition costs are high, the regulatory environment is fragmented, and the population is highly banked.” Monzo’s US exit is the empirical proof point. The best-executed primary-account challenger walked away. 3. The US banking market is structurally the hardest market to penetrate (CONFIRMED) . Levin’s ROA chart shows US-primary companies clustering in the bottom-left quadrant. FT Partners + BCG confirms US unbanked rates below 4%. Wildhack’s coverage shows Chime (the most successful US-native challenger) facing credit-cycle exposure that Nubank does not share. What I got wrong in 2025 was assuming that structural difficulty meant nothing was happening . Something is happening: it’s just not the deposit-replacement threat I was framing. It’s a slower, product-by-product incursion by well-capitalized global players, backed by an emerging regulatory shift. The Charter Wave: A Structural Shift This is the piece of new data that most changes my view. According to FT Partners + BCG (Exhibit 16): Federal bank charter and depository institution applications surged from 6 in 2024 to 34 in 2025 — a 5.7x increase. An additional 15 applications were filed in Q1 2026. Named 2025 applicants include Revolut, Nubank, Coinbase, and Ripple . Of the 49 applications filed in 2025–Q1 2026, 18 were digital-asset related. FT Partners + BCG summarize the regulatory tone shift plainly: “In the US, bank charter and depository institution applications are rising and approval pathways are becoming shorter and more navigable.” The strategic logic for pursuing a charter is compelling: lower funding costs, no sponsor-bank economics sharing, product speed without partner sign-off, and end-to-end ownership of the customer relationship. Federal charter access also brings Fedwire access, which is a genuine operational unlock. But the trade-off is real, and worth quoting in full because I don’t think it’s appreciated enough: “Fintechs that move closer to bank status will increasingly be expected to operate to bank standards, with tighter requirements around governance, compliance, risk management, capital, and supervision. The next phase is not one in which fintechs simply gain the advantages of being banks. It is one in which they must increasingly accept the obligations of being banks as well.” — FT Partners + BCG This matters especially for Chime. Its ~75% interchange dependency has always been protected by its status as a sub-$10B sponsor-bank fintech — which preserves the Durbin debit interchange exemption of ~125bps. As soon as Chime crosses that threshold or obtains a charter, the Durbin dynamic I described last year bites hard. That’s the reason Chime’s charter question — pursued or not — is the most consequential US fintech strategic decision of 2026. There is also the other edge of this sword: lower barriers for challengers are lower barriers for all challengers. Every new charter is a new competitor. The moat Chime built as a first-mover sponsor-bank fintech narrows when any well-funded fintech can now replicate the structure with a charter of its own. This is the same dynamic I flagged in Walmart – Banking and FinTech . The Interchange and Sponsor-Bank Fragility Two risks the sell-side is flagging that deserve more attention in this category discussion: Interchange dependency. Levin flags interchange revenue as facing “continuous potential for regulatory, competitive and card network rule changes.” Chime is the most exposed at ~75% of revenue, but Revolut and Nubank both have meaningful interchange revenue too. A US Durbin-style debit interchange cap in the UK or EU is not on the near-term horizon, but it is a tail risk that would ripple through the entire category. Sponsor-bank exposure. Levin cites a concrete recent example: J.P. Morgan’s decision to start charging for API calls. The sponsor-bank relationship — long treated as a utility — is becoming commercial. For Chime specifically, its dependency on Bancorp Bank and Stride Bank as sponsor banks means any repricing, regulatory pressure, or exit by those sponsors is potentially existential. This is exactly the risk that the charter application trend is trying to address, but resolution is years away. The US Competitive Landscape: Product-by-Product My 2025 argument that US banks are not losing ground was based on deposit comparisons. That framing remains directionally valid — the combined deposits of all US-focused neobanks still don’t move the needle on a JPMorgan balance sheet, and the tokenized deposit initiatives I’ve written about show incumbents investing on a scale challengers cannot match. But the more relevant frame is product-by-product : Debit and everyday spending: Chime and others have captured meaningful share among their target demographics. The question is whether that segment was ever profitable for incumbents anyway. Credit cards: Still the golden goose , still dominated by incumbents. Nubank’s credit model works in LatAm but the US credit card market is the most competitive and sophisticated in the world. Mortgages and lending: Monzo’s Habito acquisition signals intent; Monzo’s US exit signals reality. Early days at best. Cross-border and FX: Revolut is genuinely winning here. Traditional banks charge egregious FX fees and have done little to compete. Wealth and investments: Levin identifies “trading and investments” as the fastest-growing fintech segment globally (+38% in 2025 per FT Partners + BCG). This is where the primary relationship war will be fought over the next five years. Sub-prime lending: This is where the sell-side is most cautious. Wildhack’s coverage of SoFi and Upstart shows Fitch increasing default assumptions on SoFi’s SCLP 2025-4 issue to 8.16% (just above SoFi’s own 8% assumption), and Upstart’s origination growth of +140% year-over-year raising sustainability concerns. Chime’s Instant Loans product — unsecured, small-dollar, targeted at the segment most exposed to macro stress — is the specific product to watch. What to Watch Over the Next 12–18 Months The sell-side reports collectively point to five decisions and data releases that will determine the next chapter: Revolut US charter decision (OCC/FDIC). Submitted March 2026. This is a multi-year process. Approval unlocks the US NIM model Revolut has built in Europe. Chime IPO trajectory and charter question. Chime IPO’d in 2025 but stock has underperformed. Wildhack is Underperform with a $17 target (down from $25). The charter decision is the next major strategic move. Nubank’s credit model outside LatAm. Can the high-margin credit playbook translate to markets where interest rates are capped, banking penetration is already high, and macro conditions are less tolerant of sub-prime concentration? This is the single most important test for the category. If it works, the neobank thesis becomes globally applicable. If it doesn’t, Nubank remains an extraordinary LatAm story rather than a category template. US consumer credit cycle for the “have-nots.” Wildhack’s “Schrödinger’s Consumer” thesis says the lower-end consumer is under increasing stress. If this becomes a hard credit cycle, Chime and other sub-prime-adjacent fintechs will face significant loss recognition. If macro conditions stabilize, the category grows into its unit economics. Incumbent response. The top four US banks maintain annual technology budgets totaling around $50 billion — higher than the total aggregate private FinTech fundraising in 2023. Chase, BofA, and Wells have been quietly improving their digital experiences. The gap is narrowing, and their tokenized-deposit and stablecoin initiatives suggest they are prepared to compete on the next-generation rails, not just defend the current ones. The Revised Verdict Eight months ago I questioned whether neobanks could cross the profitability threshold. They have crossed it — clearly for Nubank, Revolut, and Monzo; imminently for Chime on adjusted EBITDA, less clearly on GAAP. The companies that were growing at the expense of unit economics have found their unit economics. What I still believe: the US banking market is structurally the hardest in the world for a challenger to penetrate at scale. Monzo’s US exit is the empirical proof. The credit card moat, the regulatory complexity, the incumbent tech investment, the Durbin dynamic, and the US consumer credit cycle bifurcation all remain real constraints. The combined deposits of all US-focused neobanks still don’t move the needle on a JPMorgan balance sheet. What I now believe: the profitability question was the wrong question. The right question is whether these companies are building durable, multi-product financial relationships that compound over time — and the sell-side data says Monzo is already doing it in the UK, Nubank is already doing it in LatAm, and Revolut is building the platform to do it globally. Josh Levin’s warning at the close of his report is the right note to end on: “Success should not be measured primarily by customer growth. Success should instead be measured by profitability and long-term viability metrics (CLV, cross-sell ratio, etc.).” I was right that growth is not profitability. They proved the profitability. Now we find out whether US expansion is the next chapter — or the hardest test yet. My money says the charter wave, the Chime IPO trajectory, and the consumer credit cycle over the next 18 months will tell us which. Sources & Further Reading Research reports cited (all subscription/institutional access) Josh Levin, CFA & Vineet Surana, CFA. “Digital Banks & Fintech: Look, mom, we’re all grown up!” Autonomous Research. 13 September 2025. “Global FinTech Report 2026: From Recovery to Resurgence.” FT Partners + Boston Consulting Group. May 2026. Jason Kupferberg et al. “Probing the Privates in Payments.” Wells Fargo Equity Research. 9 June 2026. Robert Wildhack, CFA & Trevor Adams. “Consumer Fintech: Schrödinger’s Consumer (Pt. 2) — 3Q25 Preview.” Autonomous Research. 21 October 2025. Kenneth Suchoski, CFA et al. “US Payments & FinTech: Rising From the SaaSpocalypse.” Autonomous Research. 13 February 2026. Prior blog posts referenced The Neobank Revolution? Not how I see it… — November 2025 Durbin Debit Fees Reduced — August 2025 JPMorgan, Citi and TCH: Tokenized Deposits ON Chain — June 2026 PIX Update — June 2026 Walmart – Banking and FinTech — March 2021 Citi – Bank of the Future? — September 2009 (Egg era) Visa – Golden Goose is Now on the Menu — March 2013 Tom Noyes has over 25 years of experience in banking and payments, having led digital and payment services at Citi and Wachovia. He writes at blog.starpointllp.com.

Open USD – Stablecoin’s New Gold Standard for Trust, Compliance, Governance and Economics

July 1, 2026

Executive Summary

  • 140+ institutions — Visa, Mastercard, Stripe, BlackRock, Google, Coinbase, and major global banks form the largest stablecoin consortium ever assembled
  • Shares reserve economics — Partners receive yield from underlying reserves, not the issuer; flips the Circle/Tether model
  • Zero-fee minting at scale — No volume limits, no enterprise penalties
  • Pre-transaction compliance — Transfer hooks block sanctioned transactions before settlement, not after
  • Burn and clawback authority — Architectural ability to freeze/burn for OFAC compliance built into Token-2022 implementation
  • Confidential transfers with regulatory visibility — ZK-encrypted balances for corporate privacy; viewing keys for auditors
  • Neutral governance — Independent board of ecosystem partners; no single corporate controller
  • Stripe default — “The default stablecoin for businesses running on Stripe”

Yesterday, we witnessed the launch of what may become the most consequential stablecoin ever: Open USD (OUSD). With over 140 financial, technology, and crypto institutions signing on—from Visa and Mastercard to Stripe, BlackRock, and Google. This isn’t merely another stablecoin entering a crowded market. This is the emergence of a new trust network architecture that I’ve been writing about for years.

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

Agentic Apocalypse — How to Stop It

Company Spotlight: Delta Network

June 30, 2026


In my recent posts on Agentic Data Battle: Intent and Agentic – Intent and the New Data Games, I’ve emphasized that the trust challenge in agentic commerce goes far beyond authenticating the consumer and the agent. We must verify the action itself (the fourth pillar of any transaction). But no one is willing to budge. Platforms don’t want to give out intent to banks or networks (even with explicity consumer consent), they don’t want to be measured. While networks are the right neutral party, network VAS means loss of control. Today’s blog outlines the hard data on agent intent failure (28%) and best in class example of how to fix it.

Continue reading

PIX Update

My last blog on PIX was 2022, so it is time for an update. When Brazil’s Central Bank (BCB) launched PIX in November 2020, the stated goal was simple: kill cash. Four years later, mission accomplished and then some. PIX has evolved from a peer-to-peer transfer tool into something far more consequential: a domestic debit scheme that challenges the card networks (debit).

The June 2026 launch of Pix Automático marks the inflection point. Brazil now has a government-mandated recurring payment rail that bypasses Visa and Mastercard entirely for subscriptions and utility billing. The BCB’s own PIX Statistics dashboard shows the trajectory:

  • 79.7 billion transactions in 2025—a 26% year-over-year increase
  • BRL 35.3 trillion (~$6.3 trillion USD) in value moved
  • 93% of Brazilian adults now use PIX
  • For the first time, Person-to-Business (P2B) transactions surpassed P2P, now representing over 44% of total volume
Continue reading

Understanding eIDAS Impact on Banking and Payments

What is eIDAS?

eIDAS stands for Electronic Identification, Authentication and Trust Services. It is European Union law — originally enacted in 2014 (eIDAS 1.0) and substantially revised in 2024 (eIDAS 2.0, formally Regulation 2024/1183) — that creates a legal framework for digital identity across all 27 EU member states.

The core ambition is straightforward: a citizen in Portugal should be able to use their national digital identity credential to authenticate with a German bank, a French hospital, or a Dutch government portal — and that credential should carry legal standing equivalent to a physical ID card.

eIDAS 2.0 goes further. It mandates that every EU member state must offer at least one European Digital Identity (EUDI) Wallet — a mobile application in which citizens store and selectively disclose certified attributes: their national eID, driving license, professional qualifications, and eventually bank account credentials or KYC attestations.

Continue reading

ZelleUSD — A Private Coin

Builds on: Stablecoins: A New Model of Trust | JPMorgan, Citi and TCH: Tokenized Deposits ON Chain | Open Banking, Open Payments and Trust Networks

Early Warning announced this week that Zelle is going international, starting with India — the world’s largest remittance destination. Alongside this, they unveiled ZelleUSD (ZLUSD), which they’re calling a “proprietary U.S. dollar-backed stablecoin.” Cue the analyst notes about banks “finally getting into stablecoin.”

I’m already laughing… this is Banks BEATING Stableocin and Remittance Providers at their own game with a closed network. This Is Not a competitor to USDC, and you can’t buy it on Coinbase, so Don’t Get Confused.

Continue reading

Proposed Stablecoin KYC Rule

The Fed/FinCEN and OFAC just revealed their proposed Stablecoin KYC rule and consistent with the GENIUS Act it entails bank-level KYC requirements for Stablecoin Issuers (see blog: No more Stablecoin “rewards”). This combined with the 303-page FinCEN/OFAC rule on transaction monitoring and secondary uses places substantial compliance burdens on Stablecoin issuers. So much that it is said the hottest job in Fintech is in Stablecoin compliance.

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

Agentic Data Battle: Intent

Paid Content

Key Friction Point in Agent (M2M) Transactions. Example of why real agentic transactions are 2-3 yrs away. We have a new party in a transaction that everyone needs to trust: the agent. Mastercard/Google Verifiable Intent is a LONG WAY from satisfying the need. It’s a self-attestation (see the Technical Addendum at the end of the Blog).

My prior blogs have focused extensively on the trust challenge in agentic commerce: authenticating the consumer and the agent (the actor). As I discussed in EMVCo and DPCs, financial institutions must verify and authenticate the four pillars of a transaction: the User, the Instrument, the Actor (Agent), and the Action (Payment). Today, I want to dive deeper into the fourth pillar—the Action—and the emerging battle over intent data.

A New Party to the Transaction

For decades, payment transactions have involved a familiar cast: the consumer, the merchant, the issuer, and the network. Each party has well-defined roles, risk allocation, and data flows governed by established rule sets. Agentic commerce introduces a new party: the Agent.

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