AI “agents” are not just chatbots that make suggestions – they are autonomous software systems that can string together multiple steps (browsing the web, filling out forms, sending instructions to physical equipment, etc.) to complete a high‑level goal .  Recent agentic systems like OpenAI’s Operator and Perplexity AI’s “Buy with Pro” feature illustrate how quickly the technology is advancing: Operator can not only suggest how to get to the airport but actually book an Uber for you, turning what was once an “augmented consumer” experience into an “algorithmic consumer” experience .  In practice these agents operate either through APIs or by autonomously navigating websites, carrying out tasks a human would normally have to click through .

What “turning an AI into a consumer” really means

  • Machine customers or “Custobots”: Researchers and regulators are beginning to refer to AI agents that buy goods and services on behalf of users as machine customers or Custobots .  This shift is expected to transform e‑commerce from designing interfaces that persuade humans into designing data and interfaces optimized for agents .  Some analysts even foresee “dark supermarkets” or agent‑only storefronts built to serve these Custobots .
  • New customer journeys: Instead of a consumer starting their search on Google or Amazon, a future “T‑phone” concept envisions consumers simply telling their personal agent what they want; the agent will then select the right apps, gather options and complete the purchase .  Because agents can process huge amounts of data, they can perform exhaustive comparison shopping, consider customer reviews and test data, and find cheaper alternatives – saving their human users time and money .
  • Benefits and vulnerabilities: AI agents may be less susceptible to dark patterns and emotional advertising, but they introduce new risks such as prompt‑injection attacks that can trick an agent into making unintended purchases .  They could also disrupt loyalty programmes, as agents tend to optimize for price and quality rather than brand .

Legal and regulatory challenges

Current consumer law assumes that humans make purchasing decisions.  The EU’s “average consumer” test, for example, evaluates whether a practice would mislead a “reasonably well‑informed, reasonably observant and circumspect” person .  In a Custobot economy, human consumers will coexist with “algorithmic consumers,” meaning that concepts like fairness, disclosure obligations and even behavioural assumptions need to be re‑examined .  Regulators are beginning to discuss whether AI agents should have their own “average consumer” test and how to factor behavioural biases into agentic decision‑making .

A recent Consumer Reports/Stanford workshop (March 7 2025) highlighted several big issues that must be addressed before agents can shop autonomously :

  • Authentication & consent: Consumers must be able to authorize an agent, grant limited permissions, and easily revoke them.  OAuth‑like schemes may work in the short term but more robust identity/authorization solutions will be needed .
  • Liability & accountability: When an agent makes a mistake, clear norms are needed to determine whether the agent’s provider, the consumer, or the vendor bears responsibility .
  • Consumer control & privacy: Users need granular control over what data the agent accesses and clear explanations of the agent’s behaviour .
  • Interoperability & choice: Consumers should be able to switch between agents and ensure that agents from different companies can interact; otherwise, a handful of platforms could become gatekeepers .

The role of digital identity

At present, human supervision is still required for sensitive tasks like entering payment details; OpenAI’s Operator, for instance, cannot fully perform financial transactions without human involvement .  A recent Forbes analysis argues that true a‑commerce will only become possible when agents have their own digital identities and credentials .  Rather than “borrowing” a user’s login details, a future agent would present a cryptographically signed credential to a bank or merchant to prove its authorization .  This would allow transactions to proceed securely while providing an audit trail for liability and competition .

So, can an AI agent be a “consumer”?

In the legal sense, today’s AI agents cannot be consumers because they are not persons and cannot hold rights or obligations; they are tools that act on behalf of human consumers.  However, the concept of machine customers—agents that autonomously buy goods and services within parameters set by their users—is rapidly becoming a reality .  The transition to this future will require:

  • Technical advances (robust identity/authorization systems and security safeguards),
  • Regulatory updates to adapt consumer law and allocate liability, and
  • Thoughtful design to ensure users retain control and privacy.

If these challenges are met, AI agents will become powerful “personal shoppers” that free people from mundane tasks and democratize access to information.  In other words, they won’t become consumers in their own right, but they will revolutionize the way humans consume.