MiCA and Autonomous Agent Payments
"We do not move money" is a fact about a system. "Therefore we are outside a regulatory regime" is a legal conclusion about a company. This page states the first and refuses the second.
Nothing here is legal advice
This page describes our own engineering state. It is not legal advice, it states no requirement of any regulation, and nothing on it should be relied on as a description of what any regime demands of you or of us.
The distinction this whole page turns on
"We do not move money" is a fact about our system. It is measured, it is checkable, and this estate has published it repeatedly.
"Therefore we fall outside a regulatory regime" is a legal conclusion. It depends on how an activity is defined, on how a supervisor reads a definition, and on facts about a specific arrangement.
We are qualified to state the first and not the second, and this page states only the first.
Anybody who has read a company describe itself as "not in scope" has read a legal conclusion presented as a technical one. That is the move this page is refusing.
What is measured about us
No settlement of any kind. No value moves through us, in any direction, under any arrangement.
No custody. We hold no funds belonging to anybody, and there is no path in the system that could.
No intermediation of a payment. Our identity header binds a request method, a path and a timestamp, and nothing about an amount, an asset or a recipient, so it does not authorise, instruct or execute anything financial.
What we do is issue attestations about who an actor is and what somebody said about them.
The questions that actually decide it, which you can ask of anybody
Does value move through the system? Does the operator hold assets belonging to somebody else? Does the system control funds, or instruct their movement? And is it an intermediary in a payment, in the sense the relevant regime defines rather than the sense the marketing uses?
Ask those of any vendor, including us, and ask for the code path or the licence rather than the sentence. A vendor who answers the first three from architecture and the fourth from a lawyer is answering honestly.
Why we will not tell you anybody else's regulatory status
Our internal notes record a regulatory authorisation for at least one company in this field. We refused to print it on the page about them and we refuse it here.
The reason is specific rather than general caution: a licence or an authorisation is one of the very few facts that lives in a public register. It is checkable by anybody, in minutes, at the source. Quoting a secondhand note about it instead of the register is inexcusable in a way that quoting a note about somebody's product roadmap is not.
If a company's regulatory status matters to your decision, look it up in the register. We are not a substitute for it and neither is anybody's competitor brief.
Where the regulated part of agent payments actually sits
Somebody has to hold or move the money, and that party is not us.
And an identity layer does not become a payments participant by being adjacent to one. A credential travelling beside a payment says who the actor is; it does not carry, authorise or settle value, and a service that read it as approving an adjacent payment would be making an inference the cryptography does not support.
So the honest description of our position in a payment flow is: upstream of it, and not in it.
Claims this page does not make
We hold no compliance status, no authorisation, no licence and no registration under any financial regime. None of those is claimed anywhere, and this estate has a standing rule against implying one.
Our alignment with the European identity architecture is a roadmap conformance target for the final quarter of 2026 and nothing more, which is stated in full on its own page.
And none of this is advice about your obligations.
What is already built, because absences alone would misdescribe us
A credential format that is a published standard, verifiable by any conformant implementation with the issuer's key and none of our code.
An identifier method registered in the W3C DID Method Registry, checkable in one request.
A live passport in a public registry, readable with no account.
And a boundary that has held on every page of this estate: identity checking happens elsewhere, we ingest the result, we issue attestations, and we move no money.