AI agents in banking

Customers already ask their banks for the same short list of things: dispute a charge, replace a card, set a travel notice, explain a fee, change a limit. Each request needs the bank to know who is asking and to check that the account holder approved it. An agent acting for a customer and one acting for the bank could settle most of these in a structured exchange, but banking is also where proof of authority and a clean record matter most, because many of these requests start regulatory clocks.

Where agents meet today

Service channels

Service requests reach banks through apps, online banking, secure messages, branches and phone lines. A customer’s agent using those channels today either works inside the bank’s own app or calls the contact centre.

Open banking rails

Data access is moving onto standard APIs in both countries:

• United States. On 8 January 2025 the CFPB approved an application from Financial Data Exchange (FDX) to issue standards for open banking under its Section 1033 rule.
• Canada. The Consumer-Driven Banking Act sets up a framework, administered by the Bank of Canada, for people and businesses to share financial data with accredited providers. The Bank will supervise participating institutions, credit unions, payment service providers, fintechs and third-party service providers.

These rails move data to an authorized third party. They don’t carry a service conversation such as a dispute. The two will meet when a customer’s agent is also an authorized data recipient, and the bank has to decide which authorization covers which request.

Three checks in every request

A request from a customer’s agent raises three separate questions for the bank:

Question	What answers it
Which agent is this, and who operates it?	Authentication of the calling software, for example a signed Agent Card and an OAuth client
Is it acting for this account holder?	Evidence the customer approved the agent, scoped to this account
May it do this particular thing?	A check of the requested action against that approval and the bank’s own limits

Illustrative: a customer’s agent asks the bank’s agent to dispute a card charge. The bank’s agent confirms which provider operates the calling agent, checks that the cardholder approved disputes on this card, asks for the transaction ID and the reason as structured fields, opens the dispute, and returns a case number with the date it was received. The customer sees the same case in the bank’s app.

Top use cases

Use case	Who talks to whom	Notes
Banking requests	Customer agent and bank agent	Card replacement, travel notices, fee questions, limit changes
Billing disputes	Customer agent and card issuer or merchant agent	Unrecognized charges and billing errors
Subscription cancellation	Customer agent and merchant agent	Stopping recurring charges at the source before disputing them
Vendor onboarding and KYC	Business agent and bank agent	Document collection for business accounts
When to keep a human	Either side and a person	Fraud victims, hardship, bereavement

Regulatory considerations

Checked on 26 September 2026 against the regulators’ own sites. This is not legal advice.

United States

• Electronic fund transfer errors (Regulation E). The consumer’s notice must reach the institution within 60 days after it sent the statement showing the error. The institution must determine whether an error occurred within 10 business days of receiving notice, or up to 45 days if it meets the conditions in the rule, including provisional credit.
• Credit card billing errors (Regulation Z). The notice must reach the creditor within 60 days after it sent the first statement showing the error. The creditor must acknowledge within 30 days, unless it resolves the matter first, and resolve within two complete billing cycles and no later than 90 days.
• Personal financial data rights (Section 1033), in litigation and under reconsideration. The CFPB finalized the rule in October 2024. On 22 August 2025 it issued an advance notice of proposed rulemaking to reconsider who may act as a consumer’s “representative”, fees, and data security and privacy. On 29 October 2025 the court in Forcht Bank, N.A. v. CFPB (E.D. Ky.) stayed the rule’s compliance dates. We found no new proposed rule in the Federal Register as of 26 September 2026. The “representative” question is the one closest to agents acting for consumers.

Canada

• Complaint handling (FCAC). Banks must resolve or close a complaint within the legislated 56-day period and may not pause it. FCAC published a revised complaint-handling guideline on 23 June 2026. A consumer can escalate to the Ombudsman for Banking Services and Investments, which became the single external complaints body for federally regulated banks on 1 November 2024. A complaint made through a customer’s agent is still a complaint, so recording it matters.
• Consumer-driven banking, being finalized. Bill C-15, the Budget 2025 Implementation Act, No. 1, received royal assent on 26 March 2026 and completed the legislative framework. Draft Consumer-Driven Banking Regulations were pre-published on 27 June 2026. Finance Canada said on 26 June 2026 that accreditation and common rules would take effect within one year of final publication, and it also pre-published amendments to the Financial Consumer Protection Framework Regulations tied to new fraud measures, including consumer consent for electronic transfers.
• Model risk (OSFI). Guideline E-23, effective 1 May 2027, covers model risk at federally regulated banks and explicitly includes AI and machine learning models.
• Privacy. The OPC notes that PIPEDA applies to federally regulated businesses such as banks even in provinces with their own private-sector laws. Bill C-36, introduced on 15 June 2026 to replace Part 1 of PIPEDA, is at second reading.

Where to start

1. Start with a status request. “Where is my replacement card?” or “what is the status of dispute X?” tests authentication and records without moving money.
2. Separate the agent from the customer. Authenticate the calling agent, then require separate proof that the account holder approved this specific action. Delegated authority explains why these are two checks.
3. Scope every credential. A credential that lets an agent dispute a charge should not let it change a mailing address. Short-lived, narrowly scoped credentials limit the damage if one leaks.
4. Timestamp everything. Error-resolution and complaint clocks run from receipt. Keep the time each agent message arrived and what it contained.
5. Route vulnerable situations to people. Fraud victims and customers in hardship need a person with the full exchange in front of them.