Every era of commerce needed a new data layer. Visa led the fifteen-year build-out that made card-not-present safe at scale — AVS, CVV2, 3-D Secure, tokenization, Advanced Authorization, Compelling Evidence 3.0. Agent-originated commerce has none of it on the rails today.
Trust substrates and protocol layers are built outside the dominant vendors and become universal by being open.
In 1999, a card-not-present authorization reached an issuer with almost no structured context. No AVS match. No CVV2. No 3-D Secure. No tokenization. No compelling-evidence schema. Every authorization was a guess against a stolen number, priced into chargebacks after the fact.
Visa led the fifteen-year build-out that followed. Each signal was standardized, schematized, threaded through the authorization or dispute message, and surfaced to the risk models of every participant in the stack. That build-out was not one protocol. It was a data layer — structured, interoperable signals describing the context of each transaction. It is the reason card-not-present volume authorizes at modern loss rates today.
An agent-driven purchase reaches the network carrying none of that context. Not which discovery surface the consumer started on. Not what intent the consumer actually expressed. Not what delegation authority the agent was operating under. Not what policy boundary the merchant enforced. Not what cart the authorization maps to. None of this is in the authorization message.
The precedent for what to do next is built. The standards pattern is proven. What’s left is the work.
Agentic commerce needs four pieces of infrastructure to scale safely. Three of them are well underway. The fourth — the merchant-side data layer — is the missing one.
Trust in the agentic era is bidirectional: consumers trust their agent, merchants trust the agent, networks trust the merchant’s evidence. AEP is the cryptographic substrate that lets each party verify the others independently — without trusting any single vendor or network.
The pattern is consistent: networks build authentication, tokenization, and dispute schemas. The merchant-side data layer has been built outside the networks for fifteen years — ML-driven fraud, chargeback guarantee, PSP-embedded risk scoring. Networks acquire into the category. They don’t compete in it. AEP fits the same pattern.
Network-side infrastructure (authentication, tokenization, dispute schemas) is network-built. Merchant-side data infrastructure has been built by independent startups for fifteen years — networks acquire into the category rather than compete in it. AEP is the next instance of the same pattern, for the agent era.
Today’s risk and evidence schemas were designed for card-not-present patterns — device fingerprints, IP heuristics, behavioral velocity. Agent-originated transactions break those schemas. The merchant-data layer for the agent era has to be built from scratch, for the agent era.
Networks rarely open-source critical infrastructure — it’s their moat. AEP can’t be a moat. It has to be the substrate the whole ecosystem runs on, and open is the only way that works.
Adapted from A-Comm’s technical memo to the Visa Agentic Commerce team, 23 April 2026. Each of these represents a risk-infrastructure gap the industry built solutions for in the CNP era — and has no solution for in the agentic era yet.
Risk engines, issuer-side and acquirer-side, are scoring mixed signal. A consumer-initiated tap-to-pay and an agent-initiated purchase reach the same decisioning model with the same fields. The contamination compounds every quarter as agent share grows.
Issuer decline logic and network-level rules are running on consumer-era data at the moment agent traffic is the fastest-growing transaction class on the rails. The authorization message has no field for “which agent,” “what delegation,” or “what intent.”
Compelling Evidence 3.0 was designed for consumer-initiated patterns. Agent-originated chargebacks reach representment without the context that would resolve them in pre-arbitration. Representment win rates on this class are materially below baseline.
Protocols like TAP, Mastercard Agent Pay, AP2, and ACP address how the consumer authorizes the agent and how the agent handshakes with the network and merchant. The data layer that feeds every downstream risk and dispute system is open for whoever defines it first. The industry has this choice exactly once.
A-Comm Evidence Protocol (AEP) is the agent-era equivalent of the merchant-data infrastructure built for card commerce — designed from day one for agent-originated transactions instead of retrofitted from card-era schemas. Published under Apache License 2.0, the same open-standard model as EMVCo, PCI SSC, OAuth, and OpenID. Eight sequential per-transaction artifacts, each SHA-256 hashed and chained to the prior artifact, so the full bundle is tamper-evident end-to-end.