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Continuous Tape

RBA submissions spotlight wallet access and AI-agent payment risks

The Reserve Bank of Australia’s summary of 75 submissions puts mobile-wallet access, debit-network routing, token portability and AI-agent payments into the same regulatory decision frame. The RBA will choose its priority issues by the end of 2026 before further consultation from mid-2027.

On 6 October 2026, the RBA published the submission summary for its Review of Payments System Regulation. Stakeholders asked it to consider rules that would preserve merchant choice when dual-network debit cards are tokenised for mobile-wallet and online use, require broader support for least-cost routing, and improve portability of payment tokens when merchants switch providers.

Submissions also pressed for scrutiny of mobile-wallet access and fees, particularly Apple Pay, while raising a newer issue: AI agents can choose payment networks and providers, introduce extra fees, and blur liability when an automated transaction exceeds its authority. Most respondents favoured standards and monitoring before direct regulation of agentic commerce.

The RBA has not endorsed these proposals. It intends to publish its regulatory priorities by end-2026 and begin further consultation on prioritised issues from mid-2027.

FMI WORLD analysis: The competitive control point in payments is moving upstream from the card rail to the token, wallet and software agent that selects the rail. If only one debit-network token is available, or an AI agent embeds a preferred provider, merchant choice can disappear before a payment reaches the clearing path.

The review therefore links market structure and operational design. Rules on token provisioning, routing, portability, agent authority and transaction records will determine whether new payment interfaces widen competition or hard-code new gatekeepers. The RBA’s priority list will show which of those control points moves first toward formal intervention.

Australian merchants, banks, card networks, acquirers, payment service providers, Australian Payments Plus, mobile-wallet operators, e-commerce platforms, token-service providers, fraud and cybersecurity teams, and firms building agentic-commerce tools.

Watch for the RBA’s priority list by the end of 2026; the scope of consultation planned from mid-2027; whether least-cost routing and dual-network token provisioning move toward binding rules; any information-gathering on wallet fees and access; and industry standards for identifying agent-initiated payments, recording authority and allocating losses.

This is a summary of stakeholder submissions, not an RBA policy decision. It does not establish new obligations or a confirmed implementation date.

Sources — RBA: Summary of Submissions to the Review of Payments System Regulation Issues Paper, 6 October 2026.

FMI WORLD NEWSROOM story reference: FMIWT-20261006-001.