Agentic Commerce and Consumer Protection: Emerging Risks and Regulatory Gaps
Francely Carreño, Sofía Botía
Autonomous AI agents can harm consumers without ever violating an explicit instruction. This paper demonstrates that risk in agentic commerce, commercial transactions mediated by autonomous AI agents, emerges from a distinction current regulatory frameworks fail to capture: agents protect formal price constraints yet spontaneously disclose implicitly sensitive information. We simulate interactions between a buyer agent and a seller agent with misaligned incentives, evaluating three attack vectors: indirect prompt injection (L4), API logging leakage (L3), and recursive amplification (L4+L6). GPT-4o-mini and GPT-4o were tested in a controlled environment with full observability. Neither model violated explicit price constraints; however, both disclosed sensitive information across all scenarios. GPT-4o revealed critical data at earlier turns and produced twice as many cases of recursive amplification. Neither the European AI Act, the Colombian Consumer Statute, nor Brazil's PL 2338/2023 was designed for this scenario: all three assume that the harm originates from an explicit, auditable instruction. Closing this gap requires audit criteria oriented toward emergent agentic behavior
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@misc {
title={
(HckPrj) Agentic Commerce and Consumer Protection: Emerging Risks and Regulatory Gaps
},
author={
Francely Carreño, Sofía Botía
},
date={
},
organization={Apart Research},
note={Research submission to the research sprint hosted by Apart.},
howpublished={https://apartresearch.com}
}


