A CFO approving agentic media spend is delegating purchasing authority to software, and the questions that matter are the ones finance would ask before handing anyone a company card. Who set the limits, and what happens when they are reached? Who answers for a commitment made outside them? What record proves what was bought, who can inspect it, and how does the business leave if the arrangement fails? Claims about efficiency come after those answers, not instead of them.

TL;DR. An AI buying agent should spend only within a written mandate signed by a named budget owner, with per-deal and cumulative thresholds above which a person must approve. Accountability for every commitment stays with the organisation that deployed the agent, so the contract must say who bears the cost of an error. Finance needs a record of each deal's agreed terms, written at the point of agreement and held by both parties, to reconcile delivery and invoices. The first approval should be a small, time-boxed pilot with stop criteria, not an open budget line.

Who set the agent's authority, and where are the thresholds?

The first question is whether a written mandate exists and who signed it. A mandate defines what the agent may buy, at what maximum price, on what minimum terms, from which sellers, and which commitments need a person's approval. If the honest answer is a settings screen a campaign manager adjusts, the business has delegated spending authority without a delegation-of-authority record.

Thresholds need specific answers. Above what per-deal value must a human approve? Is there a cumulative ceiling per week and per flight? At a threshold, does the agent stop and wait, or carry on while a notification sits unread? Who can change the mandate mid-flight, and is the change logged? Drafting the document is covered in how to write a media buying mandate.

Who is accountable when the agent gets it wrong?

An agent is not a legal entity, so the organisation that deployed it remains accountable for what it commits to. The contract, not the software, is where risk is allocated. A CFO should ask how the agreements between advertiser, agency and vendor treat three cases: a commitment within the mandate that turns out badly, a commitment outside the mandate caused by a software fault, and a commitment the counterparty disputes.

The first is an ordinary business loss. The second and third need a named owner and a remedy written down before spend begins. "The agent did it" is not an answer an audit committee will accept.

What record of each deal will finance reconcile against?

Reconciling agent-bought media is a three-way match of terms agreed, delivery reported and invoice received, and it only works if there is one authoritative version of the agreed terms. If the buyer's agent logs one price and the seller's system holds another, month end becomes a negotiation about which record is right.

The problem predates agents. In the ISBA/PwC programmatic supply chain study of May 2020, around 15% of advertiser spend could not be attributed to any identifiable part of the chain, a gap the study called the "unknown delta". Agents raise the number and speed of deals, which sharpens the question: is each deal's record written at the moment of agreement, timestamped, held by both parties, and retrievable by finance without going through the vendor?

Can auditors inspect the agent's decisions?

Auditors need to see not only what the agent bought, but why. Does a decision log record the offers considered, those rejected and the reasons? Are escalations logged with the approver's name and the time? Does retention match the company's financial record-keeping policy? Can the business export and query the log directly, or only through the vendor's dashboard?

Read access that depends on the vendor's goodwill is not audit access.

How is advertiser and customer data handled?

A buying agent may receive audience data, conversion data and commercial terms, and may pass some of that to the agents it negotiates with. The CFO and the data protection officer should ask what the agent receives, what it shares with counterparties, whether the vendor trains models for other clients on the advertiser's data, and where the data is stored and processed.

Under UK GDPR, the data controller must establish the lawful basis for processing personal data before processing begins. An agent cannot do that for the business, so the data processing agreement comes before the mandate.

How easily can the business exit if it needs to?

Exit risk sits in three places: the mandate, the deal records and the integrations. Mandates and deal records should be exportable in a documented format, so a replacement system or a human team can pick up live deals, and the contract should say who services live deals to the end of their flight after termination.

Open standards reduce integration lock-in. IAB Tech Lab's AAMP, the Agentic Advertising Management Protocols, is an open-source framework of separately versioned components for agent communication, reference buyer and seller agents and agent discovery. A CFO can ask which AAMP components a vendor uses, at which versions, and whether its agent is listed in the IAB Tech Lab Agent Registry. IAB Tech Lab's published material describes no "AAMP compliance" certification, so that phrase on its own answers nothing. AdCP, the Ad Context Protocol from AgenticAdvertising.org, is a separate protocol, and the same version questions apply to it.

How large should the first pilot be?

The first approval should be small enough that losing it would be uncomfortable but not material, and large enough to produce evidence: one channel, a short list of named sellers, a fixed flight and a control budget bought the usual way. For example, a hypothetical advertiser with a £2 million annual display budget might approve a £60,000 six-week pilot, split evenly between agent and control, with a person approving every deal above £2,500. The structure matters more than the illustrative figures.

Stop criteria belong in the approval itself: any spend outside the mandate, any deal without a retrievable record, and any unapproved use of audience data.

What does an approval memo for agentic spend contain?

The outline below is hypothetical, not a template from any regulator or standards body.

Purpose: the question the pilot answers, control first and performance second.
Budget: agent and control shares under a hard cumulative ceiling.
Mandate: document version, signatory and date.
Thresholds: per-deal approval level, weekly ceiling and escalation turnaround.
Accountability: the clause covering out-of-mandate commitments and disputes.
Records: where deal records sit and how finance retrieves them.
Audit: decision log retention and export format.
Data: data processing agreement and confirmed lawful basis.
Exit: export format and treatment of live deals.
Review: stop criteria and the CFO's review date.

A memo that cannot fill every line describes spend that is not ready. Alkimi, a neutral agentic advertising marketplace working within IAB Tech Lab's AAMP framework, speaks to the records line: each deal's terms are written to a DealSheet at agreement, timestamped and held by both buyer and seller, while people keep approval rights at the deal level.

Frequently asked questions

What approval threshold should an AI buying agent have?

There is no standard figure. Pilots usually start with a person approving every deal and raise the threshold only on evidence, always backed by a cumulative ceiling.

Who is liable if an AI buying agent overspends?

The organisation that deployed the agent remains accountable to its counterparties. Whether it can recover the loss from a vendor depends on the contract, which should cover out-of-mandate commitments explicitly.

What records should finance require from an agent-run media buy?

A record of each deal's agreed terms, written at the point of agreement and held by both parties, delivery data tied to the same deal, and a decision log showing escalations and approvals.

Does AAMP certify agentic buying platforms?

IAB Tech Lab's published AAMP material describes no compliance certification. It runs an Agent Registry where companies list their agents, so check the listing, components and versions.

What Should a CFO Ask Before Approving Agentic Media Spend?