Do checkout protocols like ACP and UCP cover returns and refunds?

They focus on buying. The ACP repository describes checkout APIs and delegated payment. The UCP overview lists checkout, cart, catalog, order and payment capabilities. Post-purchase service such as a return, a warranty claim or a cancellation is a service task that an A2A endpoint can expose alongside them.

Does a purchase made by a shopper's agent count as a contract?

The E-SIGN Act in the US and provincial statutes such as Ontario's Electronic Commerce Act, 2000 say contracts can be formed with electronic agents involved. Who is bound depends on attribution and the facts of the transaction.

AI agents in e-commerce and retail customer service

Retail customer service is full of requests a person’s agent can make: where is my order, start a return, why was I charged twice, cancel my subscription, is this in stock. Most of these requests have a short list of structured inputs, an order number, a SKU, a reason, and a policy that decides the answer. That makes them good first tasks for an agent-to-agent endpoint, and the consumer protection rules around them define what the exchange must preserve.

Where agents meet today

Buying: commerce protocols

Two open protocols target the buying side:

Agentic Commerce Protocol (ACP). Maintained by OpenAI and Stripe and marked beta in its repository, it covers checkout APIs and a delegated payment specification so a buyer’s agent can complete a purchase while the merchant stays in control of the order.
Universal Commerce Protocol (UCP). A business publishes a profile at /.well-known/ucp listing the capabilities it supports, such as checkout, cart, catalog, order and payment handling. The specification supports REST as its primary transport, plus MCP, A2A and an embedded protocol.

After the purchase: service channels

Service requests still arrive through help centers, chat widgets, email and phone lines. A shopper’s agent either fills in those forms or talks to the retailer’s own service bot as if it were a person. An A2A endpoint lets the retailer accept the same request as structured data, with the order number and SKU as fields. Making your customer service agent-ready walks through that setup.

What makes retail requests suit agents

Retail service requests share a shape: an identifier (order number, SKU, serial number), a reason from a short list, and a policy that decides the outcome. That shape maps directly onto an agent skill with named input fields. The hard parts are the exceptions, such as a return outside the window, a damaged item with no photo, or a refund to a different card, which is why each request type needs its own rule for when to hand the case to a person. Returns fraud is the other hard part: a refund to a new payment method, or to an account that didn’t place the order, deserves a stronger check than an order-status question.

Top use cases

Use case	Who talks to whom	Why it suits agents
Refunds, returns and order status	Shopper agent and retailer agent	Short, structured inputs and a policy that decides the outcome
Price, stock and bulk quotes	Shopper agent and retailer agent	Read-only, frequent, time-sensitive
Subscription cancellation	Shopper agent and merchant agent	The request is simple; retention offers make it contentious
Warranty claims	Shopper agent and retailer or manufacturer agent	Proof of purchase and serial numbers are data
Marketplace buying and selling	Buyer agent and seller agent	Questions, offers and pickup arrangements

Regulatory considerations

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

United States

Shipping promises and refunds (FTC). The Mail, Internet, or Telephone Order Merchandise Rule requires a reasonable basis for any shipping time stated, or shipment within 30 days if none is stated. If the seller can’t ship on time, it must offer the buyer the choice to accept the delay or cancel for a prompt refund, which the rule defines as within 7 working days, or one billing cycle for credit sales. An order-status answer from a retailer’s agent states a shipping time.
Subscriptions: the rule was rolled back and reopened. The FTC’s 2024 “click-to-cancel” amendments to the Negative Option Rule were vacated by the Eighth Circuit. On 12 February 2026 the FTC restored the rule’s earlier text, and on 13 March 2026 it published an advance notice of proposed rulemaking asking whether to amend it again. That proceeding was open when checked.
Card billing errors (Regulation Z). Cardholders have 60 days from the statement to give notice of a billing error, and the creditor must resolve it within two billing cycles and no later than 90 days. A shopper’s agent that disputes a charge with the card issuer, instead of asking the merchant for a refund, starts this process.
Contracts through agents. The E-SIGN Act says a contract may not be denied legal effect solely because electronic agents were involved, if the agent’s action is attributable to the person to be bound.

Canada

Pricing (Competition Bureau). The Bureau treats drip pricing, advertising a price that can’t be paid because of mandatory added fees, as deceptive marketing, and 2022 amendments to the Competition Act addressed it directly.
Provincial consumer protection. Ontario’s Consumer Protection Act, 2002 lets a consumer ask the credit card issuer to cancel or reverse a charge in the cases section 99 lists. Its replacement, the Consumer Protection Act, 2023, received royal assent but e-Laws still marks it as not yet in force.
Errors with electronic agents. Ontario’s Electronic Commerce Act, 2000 says a transaction between an individual and another person’s electronic agent is not enforceable against the individual if the individual made a material error, the agent gave no opportunity to prevent or correct it, and the individual acted promptly. A confirmation step before an order is final is one way an agent can offer that opportunity.
Order messages (CASL). Canada’s Anti-Spam Legislation exempts messages that solely confirm or complete a transaction the recipient agreed to, or give warranty, recall or safety information, from the consent requirement. The identification and unsubscribe requirements still apply.
Privacy. Bill C-36, introduced on 15 June 2026 to replace Part 1 of PIPEDA, is at second reading in the House of Commons.

Where to start

Expose order status first. It is read-only, it is asked often, and it tests authentication and identifiers.
Add returns with structured inputs. Order number, SKU, reason and refund method, with a confirmation step before anything is final.
Make cancellation as easy for an agent as for a person. An agent that can’t cancel through your endpoint may go to the card issuer instead.
Check who the agent represents. Before changing an order, confirm the agent acts for the account holder. A separate approval step for refunds to a new payment method closes an obvious fraud path.
Keep a record both sides can check. Every refund, return label and cancellation should produce a record with the request, the outcome and the time.