MADISON, Wis.– Credit unions should begin preparing their payment and risk frameworks for transactions initiated by artificial intelligence agents, even as the technology remains too early to warrant an immediate product launch, according to a new report from the Filene Research Institute, FiLAB and Money20/20.
The report examines agentic payments, an emerging model in which AI software acts on a user’s behalf within defined permissions, rather than requiring the person to directly authorize every purchase or payment.
The approach would move payments from a traditional “click-to-pay” experience toward a more autonomous “decide-to-pay” model, the report said.

Already in Development
Major technology and payments companies are already developing infrastructure that would allow AI agents to conduct transactions within established rules and limits, according to the report.
For financial institutions, however, the implications extend beyond completing a payment. Agentic commerce raises questions about identity, authorization, authentication, fraud, transaction controls and accountability. Those governance issues could become as important as the technology itself as the ecosystem develops, the report said.
Five Questions to Ask
Credit unions do not need to view agentic payments as an immediate product-launch priority, the report said. They should begin assessing how transactions initiated by software could affect existing payment systems and risk management practices.
The report identified five questions for institutions to consider:
- Authorization: How will a credit union establish that a member has legitimately delegated transaction authority to an AI agent?
- Authentication: How should an institution validate an agent acting on a member’s behalf?
- Controls: What restrictions should govern what an agent can purchase, how much it can spend and when additional approval is required?
- Fraud And Risk: How will existing fraud-monitoring systems distinguish legitimate agent activity from unauthorized or malicious transactions?
- Accountability: When an autonomous transaction goes wrong, how will responsibility be determined among the member, the agent, the financial institution and the merchant?
The Near-Term Opportunity
The near-term opportunity for credit unions is to prepare governance, identity controls, payments infrastructure and risk management practices for a world in which software may increasingly initiate transactions on members’ behalf, according to the report.





