Returns, Warranties and Support When an AI Agent Is the Buyer
Who handles returns, warranties, support and disputes after an AI agent places the order, mapped by scenario to OpenAI, Google, Visa, CFPB and FTC documents.
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After an AI agent places the order, the merchant that took the payment still handles the return, the warranty claim and the support ticket. Both checkout programs whose merchant documentation we read, OpenAI's Agentic Commerce Protocol (ACP) and Google's Universal Commerce Protocol (UCP), keep the seller as merchant of record, and Visa's rules add that the cardholder answers for what an enrolled agent does. One caveat: on March 24, 2026, OpenAI said it is "allowing merchants to use their own checkout experiences while we focus our efforts on product discovery." Its checkout spec and production guide remain published. We read these documents on October 7, 2026, did not review the Perplexity, Amazon or Microsoft programs, and offer none of this as legal advice.
Who is the customer when an AI agent is the buyer?
When an AI agent is the buyer, your returns, warranties and customer support policy still runs to the person who asked it to shop, because neither program we read makes the agent platform the merchant of record. The production guide from OpenAI says so twice in its FAQ. On the merchant of record: "OpenAI and other trusted payment service providers are not the merchant of record." On who manages chargebacks and refunds, the answer opens with "The merchant does." Customers, it adds, will see the merchant's name on their card statement.
Google's wording matches. The UCP FAQ from Google, last updated October 2, 2026, tells merchants, "You are the Merchant of Record." On the purchase contract it adds: "Your Terms & Conditions cover the purchase, just as if the customer checked out on your own website." The customer must accept those terms during checkout. At launch, the FAQ says, UCP integrations power experiences in AI Mode in Google Search and the Gemini web and mobile apps.
The agent changes how the order arrives and leaves the contract where it was. Winning the recommendation is a separate job, covered under AI share of voice.
What do the card rules say about returns and disputes in 2026?
The most specific agentic commerce policies on returns and disputes for AI shopping agents that we found in 2026 sit in the Visa Core Rules and Visa Product and Service Rules, 18 April 2026 edition, published by Visa. They define an Agentic Transaction as an ecommerce transaction undertaken by an Agentic Payment Provider on behalf of a cardholder, based on the cardholder's payment instructions and completed without direct interaction between cardholder and merchant. The provider must enroll in the Visa Intelligent Commerce program, and the glossary adds: "Initiators of Agentic Transactions are not considered Merchants for the purposes of Visa Rules." Four provisions matter after the sale.
- Responsibility (4.1.24.10). "A Cardholder is responsible for any actions taken by an Agentic Payment Provider as part of an Agentic Transaction as if the Cardholder initiated the Transaction." The provider must obtain the cardholder's acknowledgement of that responsibility first (4.1.24.3).
- Restricted returns (4.1.24.6). Before a purchase at a merchant with a limited cancellation, exchange or refund policy, the provider must obtain the cardholder's consent or acknowledgement, at final checkout or when it captures the payment instructions.
- Order confirmation (4.1.24.8). The provider must keep an order confirmation available to the cardholder for at least 120 days from the processing date, with the merchant's contact details and any cancellation and refund policies.
- Dispute rights (5.4.2.5). "A Merchant must not require a Cardholder to waive the right to dispute a Transaction, including an Agentic Transaction, with the Issuer."
The same edition changes the fraud-dispute evidence rules for disputes processed on or after 24 October 2026: a login ID for an Agentic Payment Provider counts among the customer account identifiers that can tie a disputed transaction to two earlier undisputed ones. We found no rule in that edition for an agent that is not enrolled in Visa's program, and no comparable public rule text from Mastercard in the pages we could open.
How should a store handle returns, warranties and support for agent orders?
Handling returns, warranties and customer support when an AI agent is the buyer is ordinary commerce work with one twist: the buyer may never load your product page, so the policy has to travel with the data.
- Publish the return policy as data. The Merchant Center guide from Google requires return cost, return window and a link to the full policy, as a Merchant of Record requirement that will be referenced on the checkout screen. In ACP, the checkout spec from OpenAI has the merchant send links typed
terms_of_use,privacy_policyandseller_shop_policiesfor display to the customer. - Give the buyer a way to reach you. Google requires at least one customer service website URL, email address or phone number, and uses it to build the "Contact Merchant" link on the order confirmation page.
- Hold back what you can't take back. Google's guide lists items marked "Final Sale", refurbished and used goods, personalized goods, and products bundled with warranty or installation contracts as ineligible for UCP checkout.
- Report refunds back to the assistant. OpenAI's spec puts a
refundslist in the order webhook data, each refund typedstore_creditororiginal_payment, and the production guide asks merchants to notify ChatGPT when a refund or chargeback status changes. The spec's six order statuses run fromcreatedtofulfilledand include no returned state, so a return surfaces only as a refund. - Make the warranty reachable before the sale. The warranty guide from the FTC says written warranties on consumer products costing more than $15 must be available to buyers before they purchase, and that sellers taking mail or telephone orders must put the warranty, or a statement on how to get a copy, in their catalog or advertising. We found no mention of agent checkout in the guide. Our reading is that the warranty link belongs in the feed and the policy links.
- Keep the order's identifiers. Store the checkout session ID, the delivery address and any agent login ID your integration receives. Visa's evidence rule names the login ID and the full delivery address among its matching fields, and it also requires a match on the device ID, device fingerprint or IP address.
The policy also has to say the same thing everywhere. A site that promises 30 days while the feed says 14 (invented numbers) is the mismatch we describe in LLMs cite the brand that agrees with itself, and assistants answer pre-purchase questions from whichever copy they can read, a theme of our guide on how to get cited by ChatGPT.
Who is liable when the agent gets it wrong?
In agentic commerce, customer service and returns stay with the merchant, while liability for an AI shopping agent's mistake depends on whose mistake it was and whether the shopper authorized the order. The table maps five scenarios to the rule we read for each.
| Scenario | First stop | Who carries it | Rule we read |
|---|---|---|---|
| Merchant ships the wrong item | Merchant support | The merchant refunds or replaces. If it refuses, the shopper can send the card issuer a billing error notice | OpenAI production FAQ; 12 CFR 1026.13 |
| Agent picks the wrong item from a loose instruction | Merchant's standard return policy | The shopper, whom Visa holds responsible for the agent's actions. The merchant owes what its return policy promises | Visa 4.1.24.10 |
| Agent ignores a criterion the shopper set | Merchant return policy, then the agent provider | Unsettled. Visa requires the provider to use only the cardholder-defined criteria and still holds the cardholder responsible. We found no rule that moves the loss to the provider | Visa 4.1.24.4 and 4.1.24.10 |
| Order the shopper never authorized | Card issuer | Credit card liability is capped at the lesser of $50 or the amount obtained before the issuer is notified, and the official interpretation says no liability may be imposed for an internet order placed with the card number alone. The merchant faces a fraud dispute | 12 CFR 1026.12(b); Visa Dispute Condition 10.4 |
| Product fails under warranty | Merchant or warrantor | Whoever gave the written warranty, plus the merchant's implied warranty of merchantability on products it is in business to sell | FTC warranty guide |
Regulation Z covers credit cards. Section 1026.12 from the CFPB defines unauthorized use as use of the card by a person other than the cardholder who lacks actual, implied or apparent authority, and from which the cardholder receives no benefit. Its official interpretation says that authority is determined under state or other applicable law, and gives the example of a cardholder who hands the card to a family member or coworker who exceeds the authority given: the cardholder is liable until they tell the creditor the use is no longer authorized. Neither passage mentions software agents, so where an overspending agent falls is an open question. Under section 1026.13 from the CFPB, a billing error notice must reach the creditor no later than 60 days after it sent the first statement showing the charge, and the interpretation lists delivery of property different from what was agreed as an example.
Take a hypothetical. A shopper asks an assistant to reorder a pitcher filter, and the agent buys the cartridge for a different model at an assumed $28. The shopper emails the merchant named on the card statement. Under an assumed 30-day policy the merchant accepts the return, refunds the card and sends an order_updated event with an original_payment refund. If the shopper instead tells the issuer the charge was fraud, the merchant answers with the order record: session, delivery address and agent login. Every figure in this example is invented.
What to settle before the first agent order
Agent orders land in the same support queue as everything else, so tell the team that an order placed through an assistant gets the standard policy with the session record attached. If you want help with the ticket routing or with the feed and policy data assistants read, that is the ground our agentic AI automation and AI search optimization services cover, and the AI Visibility Checker is a further resource on the visibility side. Write the return window, the warranty link and the support contact once, and publish the same words to every surface an agent can read.
Sources
- OpenAI, Agentic commerce in production
- OpenAI, Agentic Checkout Spec
- OpenAI, Powering Product Discovery in ChatGPT, March 24, 2026
- Google, Universal Commerce Protocol FAQ
- Google, UCP Merchant Center setup guide
- Visa, Visa Core Rules and Visa Product and Service Rules, 18 April 2026
- CFPB, Regulation Z, section 1026.12
- CFPB, Regulation Z, section 1026.13
- FTC, Businessperson's Guide to Federal Warranty Law