A senior investor at QED Investors has outlined a framework for thinking about risk and trust in agentic payments, arguing that the financial industry has yet to price the new liability surface that autonomous AI agents create when they transact on behalf of consumers.
Victoria Zuo, a San Francisco-based partner at the venture firm, said the clearest analogy already exists inside the payments infrastructure: the long-established difference in interchange rates between card-present and card-not-present transactions, which reflects the higher fraud risk of a transaction completed without a physical card and a human at the terminal.
“Vendors should be properly rewarded for that risk, similar to how interchange fees are different between card-present and card-not-present transactions,” Zuo said, describing a category she labels human-present and human-not-present transactions. Authentication and authorisation, she added, are the key controls for limiting chargebacks and fraudulent requests in an agentic environment.
The trust gap
Zuo said the gap between the technology’s capability and institutional trust in it remains wide, and that she herself reflects the ambivalence many professionals feel. Despite being an active follower of AI developments, she has not connected her bank accounts to a general-purpose AI assistant.
“It comes down to trust. I still haven’t linked my bank accounts to my ChatGPT Pro account,” she said, adding that she expects specialist vertical agents in financial services and healthcare to earn that trust before general-purpose horizontal agents do.
Her investment interest follows from that view. She said startups focused on granular permission controls for payments, the kind of architecture that would let a user instruct an agent to transact only within defined parameters, represent a category worth watching.
Agents as a new distribution channel
A second thread in Zuo’s analysis concerns how merchants and financial-services providers need to rethink distribution when the end customer is an AI agent rather than a person. She pointed to Lorikeet, a Sydney-based portfolio company, as an example of a startup already building infrastructure on this assumption. The company recently launched a product designed to help merchants serve structured information, including product descriptions, return policies and refund terms, directly to agents completing transactions on behalf of consumers.
“Now that transactions are happening with consumers closing the purchasing loop, you want to serve up the information packet including product descriptions, return policies and refund policies to the agent rather than humans,” Zuo said.
The observation points to a broader shift in how conversion funnels are being redrawn. As AI agents increasingly handle discovery, comparison and purchase completion, the optimisation task for merchants moves from search-engine ranking and click-through rates toward making data legible to machine decision-makers.
Market context
The trust and liability questions Zuo raises sit at the centre of a fast-developing regulatory debate. In the UK, the Financial Conduct Authority has yet to publish formal guidance on accountability when an AI agent causes or fails to prevent a financial loss, though its Consumer Duty framework requires firms to demonstrate good outcomes for clients regardless of which layer of the stack interacts with them. In the EU, the AI Act’s tiered risk classification and PSD3’s strong customer authentication requirements both bear on agentic payment scenarios, though the interplay between the two frameworks remains unsettled.
From an investment standpoint, QED’s framing, that financial services could function as a revenue model embedded inside personal AI agents rather than as a standalone product category, suggests the firm is looking beyond pure-play fintech into the infrastructure that routes and controls money inside AI-native applications. The near-term signal will be which startups secure the first credible licensing arrangements or banking-as-a-service partnerships to underpin those capabilities.
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