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07/06/2026 8:15 pm
TL;DR: PSD3 is moving European payment rules toward bank liability for bank impersonation scams and stronger fraud prevention expectations, while also signalling that AI agents are not yet covered by current legislation, according to OneSpan's interview with ThreatFabric's Eward Driehuis. The gap is no longer theoretical: payment governance is now colliding with delegated automation, and identity controls must catch up.
NHIMG editorial — based on content published by OneSpan: PSD3 updates and the regulatory impact on fraud prevention
By the numbers:
- 75% of APP fraud actually originated on social, on social media platforms or via SMS messages.
- When AWS credentials are exposed publicly, attackers attempt access within an average of 17 minutes.
Questions worth separating out
Q: What breaks when payment fraud controls assume a human is always the actor?
A: Controls break when they rely on human behaviour, because delegated software or impersonation scams can move value without the same signals a person would produce.
Q: Why do bank impersonation scams create a liability problem for identity teams?
A: They create a liability problem because the scam is built on trust abuse, not only transaction abuse.
Q: How should organisations govern AI agents that can make payments on behalf of users?
A: They should govern those agents as separate non-human actors with their own approval, audit, and delegation boundaries.
Practitioner guidance
- Map payment flows to the real decision-maker Separate human-authored transfers, delegated software actions, and bank-initiated workflows so each has a distinct trust and liability path.
- Classify impersonation cases by origin and actor Build fraud taxonomy that distinguishes bank impersonation, tech impersonation, and other APP scam types, then preserve evidence on channel origin, customer interaction, and verification step.
- Inventory delegated payment capabilities Identify where AI agents or other software can make or complete purchases, and document whether those paths have a separate approval model, audit trail, and rollback path.
What's in the full article
OneSpan's full interview covers the regulatory detail this post intentionally leaves for the source:
- The political-trilogue background behind PSD3 and PSR, including how the liability language reached agreement.
- The discussion of when banks can transfer liability to social media platforms or telecommunications providers.
- The interview's examples of technical and behavioural fraud prevention measures beyond the high-level policy view.
- Frederik Mennes's view on where AI agents fit into the next wave of payment regulation.
👉 Read OneSpan's interview on PSD3 fraud liability and AI agent gaps →
PSD3 and AI agent payments: are current controls enough?
Explore further
07/06/2026 10:04 pm
Payment fraud governance is becoming an identity problem, not only a reimbursement problem. PSD3 shifts attention from what happens after fraud to which actor was trusted, authenticated, and allowed to move value in the first place. That pushes IAM and fraud teams into the same operating model, because liability is now tied to the trust decision as much as the transaction. Practitioners should treat payment authorisation as an identity control surface.
A few things that frame the scale:
- When AWS credentials are exposed publicly, attackers attempt access within an average of 17 minutes, according to LLMjacking: How Attackers Hijack AI Using Compromised NHIs.
- DeepSeek accidentally embedded over 11,000 secrets in its training data and left a database exposed online, revealing more than one million sensitive records including chat histories, backend credentials, and API keys.
A question worth separating out:
Q: Who is accountable when fraud starts on social media or SMS and ends in a payment?
A: Accountability depends on the legal regime, but the operational lesson is consistent: the organisation that trusted the wrong origin signal may still be responsible for the loss. Teams should be able to show where the scam originated, what identity proof existed, and whether a stronger control could have broken the chain earlier.
👉 Read our full editorial: PSD3, fraud liability, and the limits of AI agent governance
