Agentic perfection. If you are a payment provider
Agentic commerce just collided with a regulatory regime that wasn't waiting for it
In a satirical piece I wrote at the start of March, I imagined a 2028 in which Klarna had its best quarter since the dawn of time. The joke was that agentic commerce, having gone live without anyone really thinking through the credit layer, had filled household garages across America with industrial dehumidifiers and Sardinian cheese, all of it bought on instalments by autonomous agents loosely interpreting the prompt “stock up on essentials.” Klarna’s fictional investor presentation, in the bit, opened with a single slide of a warehouse full of uncollected hot tubs. Caption: These are all on payment plans.
I thought I was writing satire. It turns out I was mostly writing a roadmap.
Hot take coming through
This week PYMNTS ran Karen Webster’s Monday Conversation with Libor Michalek, president of Affirm, under the headline Agentic Credit Rewrites the Rules of Consumer Lending. The thesis, on its own terms, is entirely persuasive. The 60-year-old revolving credit line is a workaround that won because underwriting was hard and data was thin. Now it isn’t. Lenders can assess the transaction itself, this purchase, this price, today, against this person’s actual cash flow this month, and price the risk in real time. Affirm calls it agentic credit. They are, to be fair to them, very good at it.
Buried in the framing is the sentence the rest of us should be reading three times.
Affirm sees millions of consumers every year shown the full cost of a purchase and walking away from it. Michalek’s framing: a credit business that earns money when you decide not to spend is, structurally, on your side. He’s right. It’s a better model than the old revolving line, where the lender’s incentive runs in the opposite direction.
Now picture that machinery sitting inside an agentic flow.
Collision
The agent has been delegated a basket. The user has gone for a run, or fallen asleep, or is in another meeting. The agent gets to the lender’s API. The lender does its real-time assessment. The lender comes back and says: no, not this one. Or: yes, but only on these terms, and only for half of it. The user, being absent, doesn’t see the prompt. The agent has to make a call. Drop the basket, downgrade it, switch BNPL provider, kick the whole thing back to a manual checkout, or just abandon. Many will feel embarrassed and does this footprint stop you from a purchase elsewhere? We have been free to manage these sorts of daily struggles ourselves, forever, this might just limit that.
This isn’t a failure of the technology. It’s the technology working exactly as designed. Honest finance and frictionless commerce have, on a long enough timeline, structurally opposite goals. Honest finance puts the cost in front of the consumer at the moment of purchase. Frictionless commerce removes the consumer from the moment of purchase entirely. Affirm’s proof point, the thing they are quietly proud of, becomes a conversion problem the moment you take the consumer out of the loop.
And that’s just the American half of the story.
THE ATLANTIC FLIP
If you’re Irish or European watching this from across the water, there’s a second layer the US-led press isn’t quite reading carefully enough.
From 15 July 2026, the UK’s Financial Conduct Authority brings BNPL, formally re-named Deferred Payment Credit, into full consumer credit regulation. Affordability checks on every transaction. The Consumer Duty’s “good outcomes” test. Access to the Financial Ombudsman Service. And, crucially, Section 75 joint liability between lender and merchant for any purchase over £100. The UK BNPL market grew from £60 million in 2017 to over £13 billion in 2024. The regulators have decided that’s enough running room.
Then on 20 November 2026, the EU’s Consumer Credit Directive II (CCD2) lands across all 27 member states under full harmonisation. Every BNPL provider in the bloc has to do proper credit checks, supply standardised pre-contract info, give consumers a 14-day withdrawal right, and stay inside national APR caps. The Netherlands has gone further and banned BNPL for minors outright. Germany is folding the whole category into the Bürgerliches Gesetzbuch like it’s a building society loan from 1972.
Karen Hao would recognise the shape of this. When a category grows fast inside a regulatory vacuum, the regulators arrive eventually, they always arrive late, and they always arrive with everything they wished they’d done five years ago. UK and EU legislators watched BNPL go from a curiosity to 20% of UK adults, 10.9 million people, using it inside a year, and decided that no protections for those who use it repeatedly and may not be able to afford it was no longer a policy. It was a problem.
The flip matters. In the US, agentic credit is being framed as a product innovation, Affirm telling us it’s the next evolution of consumer lending. In the UK and EU, the same machinery is arriving alongside a regulatory regime that demands affordability checks, robust documentation, customer signposting to debt advice, and a complaint route through an ombudsman. Same technology stack. Wildly different political economy.
Which means the agentic checkout in 2027 won’t look the same in San Francisco as it does in Birmingham, never mind in Berlin or Tralee. The agent that one-clicks a Foundrae piece in Manhattan is operating in a different credit reality from the agent trying to buy a £400 set of trainers in Manchester. The merchant on the EU side will have a regulated lender between the agent and the basket, declining transactions for reasons the agent has no jurisdiction to challenge.
Turn
The honest read is not that agentic commerce is dead, or that BNPL is dead, or that Affirm has misread the room. The read is that frictionless commerce was always a marketing phrase, and the friction we’re now adding back, affordability checks, real-time underwriting, Section 75 liability, ombudsman recourse, is the friction that should have been there all along. The merchant on the ground, the operator who wants to model agentic into 2027 GMV with any seriousness, has to assume a higher decline rate at credit, a different conversion ceiling, and a regulatory landscape tightening faster than the technology is shipping.
Landing
The Klarna piece I wrote in March was meant to land as a joke. The warehouse full of hot tubs was supposed to be the absurd reductio. Six weeks later the FCA has confirmed its July date and the EU has its November one, and the joke is becoming policy. The bots, increasingly, will need a co-signer. The co-signer will be a regulated entity in a Consumer Duty regime, watched by an ombudsman, declining transactions for reasons the consumer will eventually have a right to ask about.
That isn’t dystopia. And, It’s also, from a 2027 conversion standpoint, going to be very expensive.