
Diana Vorniceanu
22 Apr 2026 / 8 Min Read
Cathrin M. Daniel and Dara Kossok-Spieß of the German Retail Federation (Handelsverband Deutschland - HDE) discuss retail visibility risks, regulation, and readiness as agentic commerce is expected to reshape how products are found and bought.
Agentic commerce is not simply the next AI tool. For retail, it marks a structural shift in how products are found, compared, and purchased. AI is increasingly mediating discovery, ranking, and transaction decisions, which means it may become a new gateway to the market.
From an HDE perspective, the core issue is visibility. If AI assistants and interfaces increasingly shape which products and merchants are shown to consumers, visibility becomes a decisive competitive factor. As Cathrin M. Daniel says: ‘The central question is no longer only who offers the best product, but who is still visible in AI-mediated commerce’.
Retailers should therefore assess where their visibility comes from today, how dependent they are on third-party interfaces, and whether their product, pricing, and transaction data can be interpreted and prioritised by AI-driven systems. For payments stakeholders, the same shift matters. If purchasing journeys move into AI-assisted environments, payment processes must remain secure, reliable, interoperable, and trusted.
This is not a distant scenario. The shift is already being acknowledged by platforms, payment providers, and technology firms. For retailers and payments actors alike, the challenge now is to understand how AI may reshape market access and commercial relationships.

The four scenarios describe increasing levels of AI mediation in commerce. They are not business models retailers can simply choose from. Rather, they illustrate how control over visibility, customer access, and purchasing decisions may gradually move away from the retailer.
In the first scenario, ‘AI-Enhanced Webshop’, AI strengthens the retailer's own environment. Search, recommendations, and assistance improve efficiency, but the retailer still controls the customer interface, checkout, and commercial logic.
In the second scenario, ‘AI-Guided Shopping Assistant’, AI starts to guide the customer more actively. It helps identify and compare products, but the transaction still takes place in the webshop. In practice, the retailer retains the checkout and much of the customer relationship, while discovery becomes more mediated.
The third scenario, ‘All-in-One AI Commerce’, marks a structural turning point. The shopping journey itself moves into the AI environment. Here, visibility depends less on the retailer's storefront and more on the logic of the AI interface.
The fourth scenario, ‘AI-Concierge’, gives the highest level of autonomy to the AI agent. It selects, compares, and purchases on behalf of the consumer. In this setting, the retailer's role shifts from interface to supplier and fulfilment partner.
Dara Kossok-Spieß captures the development succinctly: ‘With every stage, the retailer loses a little more control over how customers find and choose products’. That progressive shift in control is what most clearly differentiates the four scenarios.
It will do both. Like many major technological shifts, agentic commerce creates new opportunities, but it also brings clear structural risks. Much will depend on how quickly businesses understand the change and adapt to it.
For merchants that still rely mainly on direct traffic, interface control, and traditional digital visibility, the shift can become a serious threat. At the same time, businesses that are easy for AI systems to evaluate, trust, and transact with may gain new advantages.
As Cathrin M. Daniel notes: ‘The risk is not AI as such. The risk is becoming invisible in the new decision-making layer of commerce’.
From an HDE perspective, this is why adaptation must happen on two levels. Businesses need to review and future-proof their strategies, while policymakers must ensure that new forms of AI intermediation do not undermine fair competition and market access. Agentic commerce should not become a development in which efficiency gains for some come at the cost of exclusion for others.
Yes. Agentic commerce will not affect all business models equally.
The most vulnerable models are those that depend heavily on being the place where consumers browse, compare, and decide. Businesses that rely on attention capture, browsing detours, customer inertia, or poorly structured product information are likely to face pressure if AI systems increasingly take over product discovery and comparison.
By contrast, businesses that offer high-quality structured data, reliable fulfilment, clear product information, strong trust signals, and interoperable systems are better positioned. In agentic commerce, those qualities become more valuable because AI systems are likely to compare merchants on exactly these criteria.
As Dara Kossok-Spieß puts it: ‘The winners will not necessarily be the loudest brands, but the businesses that are easiest for AI systems to understand and trust’.
This point also matters for SMEs. Smaller retailers are not automatically at a disadvantage. Where they offer strong product quality, specialisation, and clear data, AI-mediated environments may also create new opportunities for visibility beyond today's platform structures. That is why the debate should not be framed only in terms of risk, but also in terms of the conditions for fair access and discoverability.
The European digital framework is already highly complex, and agentic commerce adds another layer because it cuts across several regulatory categories at once: AI systems, platform intermediation, ranking, consumer-facing services, and market access.
The AI Act is a central pillar because it aims to create trust, safety, and legal certainty for AI systems. But from a retail perspective, many of the emerging challenges are not only about safety or risk classification. They are also about economic visibility, dependency, and access to customers.
The DSA improves transparency and accountability for digital platforms and intermediaries, which is important. However, AI-mediated commerce creates new dynamics around recommendation, prioritisation, and visibility that are only partly covered by a framework that was not designed specifically for autonomous commercial intermediation.
This is where the most critical gaps emerge. As Cathrin M. Daniel states: ‘The next regulatory challenge is not just AI safety. It is AI-mediated market access’.
From our point of view, three issues stand out in particular: transparency around commercial ranking and recommendation logic in AI environments, safeguards against discriminatory or self-preferencing treatment, and legal clarity on responsibilities where AI systems function as de facto gatekeepers between retailers and consumers. A further open question is how existing rules apply when commercial decisions are increasingly initiated, filtered, or executed by AI agents rather than directly by consumers themselves.
From our perspective, the DMA is the right starting point because it is specifically designed to address gatekeepers’ power and to preserve fair and contestable digital markets.
That logic becomes even more relevant in agentic commerce. If AI assistants and interfaces shape discovery, ranking, and purchasing decisions at scale, they may take on functions that closely resemble gatekeeping. In that sense, the DMA already offers a useful legal and conceptual basis.
At the same time, targeted clarification will likely be needed. As Cathrin M. Daniel says: ‘If AI systems become the new interface between retailers and consumers, the DMA must be able to address AI-mediated gatekeeping as clearly as platform gatekeeping today’.
In practical terms, this means ensuring that new AI-based intermediaries do not recreate old dependencies in a less transparent form. A more explicit focus on AI-mediated visibility, recommendation, and commercial self-preferencing would strengthen legal certainty for retailers and help safeguard competition within the Single Market. From an HDE point of view, the goal should be to ensure that future market access remains fair, contestable, and innovation-friendly.
Retailers should begin with a simple question: would an AI agent be able to find, understand, and trust my offer?
That means improving product data, ensuring accurate pricing and availability information, and making checkout and fulfilment processes as reliable and seamless as possible. In agentic commerce, structured data, operational quality, and interoperability will become even more important because AI systems are likely to compare merchants on exactly those factors.
Retailers should also review how dependent they are on direct traffic and traditional digital visibility. If product discoveries happen increasingly through AI-mediated interfaces, businesses need to rethink how they secure market access and customer relevance.
As Dara Kossok-Spieß puts it: ‘Retailers should prepare for AI not as a feature, but as a new market logic’.
At the same time, preparation should not be understood as a purely technical exercise. It is also strategic. Retailers should observe emerging best practices, exchange with peers and technology experts, and assess whether their current business model is robust enough for a more AI-mediated market environment. Finally, they should not navigate this shift alone. Industry associations and federations will remain important in ensuring that the future rules of AI-mediated commerce are fair, transparent, and workable for businesses of all sizes.

Dara Kossok-Spieß, Head of Internet Policy and Digitisation at the German Retail Federation (HDE), is a leading voice on digital transformation in retail. At the German Retail Federation (HDE), she works on the sector’s modernisation, from digital and platform policy to the practical integration of new technologies such as artificial intelligence. She also founded the retail sector’s Diversity Initiative and co-founded SWANS, an NGO supporting women from underrepresented backgrounds.

Cathrin M. Daniel, Junior Advisor Internet Policy and Digitisation at the German Retail Federation (HDE), works at the interface of digital policy, regulation, and technological transformation. At the German Retail Federation (HDE), she focuses on how emerging technologies reshape markets, competition, and regulation. She brings professional experience from Berlin and Brussels, including at the European Commission (EISMEA), as well as from management consulting and international business development.
The German Retail Federation (HDE) is the leading representative body of the German retail sector. It advocates for sustainable prosperity and represents retailers’ interests vis-à-vis policymakers at federal and EU level, the media, and the wider public. Backed by regional and sectoral associations, HDE works across economic and tax policy, legislation, quality standards, consumer protection, and environmental policy on behalf of a diverse and vital industry.
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