According to PYMNTS.com, Trulioo Chief Product Officer Zac Cohen revealed that the company is developing “know your agent” (KYA) infrastructure as the next evolution beyond traditional KYC and KYB verification. In an interview for the “What’s Next in Payments” October Surprise series, Cohen identified liability as the major sticking point preventing agentic commerce from scaling, noting that unresolved questions about errors, mis-purchases, and chargebacks in AI-driven transactions remain critical barriers. He highlighted regulatory developments including Europe’s new payee verification regulation and U.S. state-level UBO databases in Delaware, California, and New York as creating stronger trust signals. Cohen predicted that 2026 will bring rapid expansion in AI-driven automation across payment approvals, payouts, card issuing, and merchant onboarding, requiring new verification frameworks for this emerging transaction paradigm.
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The Unresolved Liability Question
The transition to agentic commerce creates unprecedented liability challenges that existing legal frameworks weren’t designed to handle. When an AI agent makes an erroneous purchase or triggers a chargeback, determining responsibility becomes complex. Is the developer liable for the agent’s actions? The platform hosting the agent? The end-user who authorized it? This liability gap represents more than just a technical challenge—it’s a fundamental legal and regulatory void that could significantly slow adoption of automated commerce systems. Without clear liability frameworks, financial institutions and merchants will hesitate to enable agentic transactions at scale, regardless of the efficiency benefits.
Global Regulatory Fragmentation
The regulatory landscape for agent verification is developing unevenly across jurisdictions. Europe’s push for payee verification standards contrasts with the U.S. approach where individual states like Delaware and California are building their own UBO databases. This fragmentation creates compliance complexity for global payment providers who must navigate multiple verification standards simultaneously. The Corporate Transparency Act’s ongoing legal challenges demonstrate how difficult it is to establish unified frameworks. This regulatory patchwork means companies like Trulioo must build flexible systems that can adapt to regional requirements while maintaining global interoperability—a significant technical and operational challenge.
Technical Implementation Hurdles
Building KYA infrastructure requires solving complex technical problems that go beyond traditional KYC systems. Agents operate with varying levels of autonomy, from simple scripted actions to sophisticated AI systems capable of independent decision-making. Verification must account for this spectrum while ensuring traceability across multiple parties—merchants, payment networks, developers, and consumers. The technical architecture must support real-time verification without introducing transaction friction, creating a delicate balance between security and user experience. Additionally, as Cohen noted, the rapid evolution of AI capabilities means verification systems must be designed for continuous adaptation rather than static compliance.
Broader Market Implications
The emergence of KYA represents a significant expansion of the digital identity verification market beyond its traditional financial services focus. As AI agents proliferate across e-commerce, supply chain management, and enterprise automation, the need for agent verification will create new revenue streams for identity providers. However, it also raises important questions about standardization and interoperability. Will we see competing KYA standards emerge from different providers? How will cross-platform agent verification work? The companies that establish early leadership in this space could shape the foundational infrastructure for the next generation of digital commerce, much like early payment networks defined electronic transactions.
Realistic Adoption Timeline
While Cohen’s 2026 prediction for AI automation growth seems plausible, widespread KYA implementation will likely follow a more gradual trajectory. Early adoption will probably focus on controlled environments with limited transaction values and clear use cases. High-value or complex agentic transactions will require more mature frameworks and legal precedents. The transition will likely mirror the gradual adoption of digital signatures—starting with low-risk applications and expanding as confidence in the technology and legal frameworks grows. The critical success factor will be demonstrating that KYA systems can handle edge cases and exceptions without creating operational bottlenecks or exposing participants to unacceptable liability risks.
