Payment initiation service

A payment initiation service triggers a payment directly from a customer's bank account on her behalf; in the EU, it is a regulated payment service under the Payment Services Directive PSD2.

PSD2 introduced payment initiation services as distinct, licensed services. Such a service accesses the customer's account with her consent through a bank interface and triggers a transfer, typically with strong customer authentication. In Switzerland, banks have no legal obligation to open up; open banking emerges through market initiatives and contractual interfaces.

AI agents that trigger payments touch these rules directly. What matters is who triggers the payment in the legal sense and how the customer's consent to the specific payment is proven.

Example

An accounting agent is to pay a supplier invoice. It uses a payment initiation service that prepares a transfer through the bank's interface. The business owner confirms it with strong authentication; the agent's mandate shows that amount and payee were within its limits.

How it differs

A payment initiation service is a regulated way to trigger a payment. Rich Authorization Requests describe the specific payment at consent. A mandate proves that the agent was allowed to trigger this payment on someone's behalf.

In practice

  • Clarify whether your agent itself provides a regulated service or uses a licensed provider.
  • Have the customer confirm specific payments or set the limits in a mandate.
  • Keep mandate, decision and payment receipt together.

Role in KYA

KYA does not verify payment services. It verifies the mandate, the decision and the receipt of the payment and shows whether amount and payee were within limits.

Related check: Scope of the action (intent_scope). Is the action within the mandate's action type, amount limit, currency and counterparty?

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Frequently asked questions

What is a payment initiation service?

A service that triggers a payment directly from a customer's bank account on her behalf. In the EU, it is regulated under PSD2.

Does an AI agent need a license as a payment initiation service?

That depends on whether it provides such a service itself or uses a licensed provider. The classification should be clarified legally case by case.

Are there payment initiation services in Switzerland?

Banks have no legal obligation to open interfaces. Open banking emerges through market initiatives and contractual agreements.

How does a customer confirm a payment by an agent?

Either individually with strong customer authentication or in advance through a framework, such as a mandate, whose classification the payment service provider assesses.

What does KYA verify for payments?

Whether the payment lay within the mandate, whether a decision existed and whether the receipt matches. KYA does not verify payment processing itself.

General information, not legal advice. The statutes and the circumstances of each case are decisive.

Sources

  1. Directive (EU) 2015/2366 (PSD2)
  2. Delegated Regulation (EU) 2018/389 (RTS)