Resolve the regulatory status of ASP-based settlement

Determine the applicable regulatory requirements for sector accreditation, consumer-protection obligations concerning refunds and cancellations, stablecoin regimes, and classification of the operator’s refund pool across relevant jurisdictions for the Agentic Settlement Protocol.

Background

The Agentic Settlement Protocol couples stablecoin escrow with off-chain fulfilment engines and contemplates use in sectors such as air travel, where accreditation requirements may apply. Its refund and cancellation mechanisms may also interact with consumer-protection law, while the use of stablecoins raises jurisdiction-specific regulatory issues, including regimes such as MiCA in the European Union and VARA in the United Arab Emirates.

The protocol further relies on an operator-funded refund pool as a potential backstop for seller defaults and late-capture losses. The legal classification of that pool, together with the other listed regulatory questions, is not resolved by the protocol specification and must be determined for each applicable jurisdiction.

References

Regulatory posture. Sector accreditation where it applies (IATA for air), consumer-protection rules on refunds and cancellations that vary by class and jurisdiction, stablecoin regimes (MiCA in the EU, VARA in the UAE) and the classification of the operator's refund pool are unresolved and jurisdiction-dependent.

— Agentic Settlement Protocol: An Application Profile for Refundable, Delayed-Fulfilment Agent Commerce on Stablecoin Rails  (2609.02208 - Behnam et al., 2 Sep 2026) in Section 9, “Limitations and Open Questions”