The top-up is not a renewal: What AI companies need to get European payments right
AI products are changing when and how customers pay. In Europe, each of those payments can fall under different rules, and your payment setup needs to know which is which.
OpenAI’s help page on prepaid API billing has a sentence every payments person should read twice: "When a prepaid account runs out of credits, API requests begin returning a billing error."
In other words, an empty balance switches the product off. For a developer halfway through a build, a failed payment doesn’t just stop a new purchase. It delays the work they’ve already started. That’s what makes payments for AI businesses different, and in Europe, a little harder.
One customer, four ways to pay
Many AI companies offer some mix of four options:
- A subscription for ongoing access or a monthly allowance
- Manual top-ups when customers need more
- Automatic recharges that refill the balance without a trip to checkout
- And enterprise contracts paid by invoice.
Now picture one developer over a few months. They start on a monthly plan. Then a big project eats their allowance, so they buy more credits. After the third time, they switch on automatic recharges. Later, their company moves to an invoiced contract, the kind our partner Kolleno lets customers pay from inside their finance workflow.
To them, it’s one service.
To the payments system, it’s four different kinds of payment.
Who starts the payment?
In card payments, few questions matter more and there are two ways of thinking about the answer.
A customer-initiated payment is one the customer makes by clicking "pay" or "top up", even with a saved card.
A merchant-initiated payment is one the business makes on the customer’s behalf, under an agreement the customer set up earlier, and each one has to carry a reference back to that agreement.
For AI credits, in particular, "Add €100 now" is customer-initiated, whereas "Add €100 whenever my balance falls below €20" sets up merchant-initiated recharges.
Under PSD2, the EU’s main payments law, payments the customer starts usually need strong customer authentication: two separate checks, such as a phone and a fingerprint, typically through 3D Secure. Payments the business starts under an agreed arrangement don’t, though setting that arrangement up online does.
But these rules are about to change.
The EU has agreed PSD3 and a new Payment Services Regulation to replace PSD2, with most rules expected to apply from around 2028. Charges under an agreement the customer set up will still generally skip the check, but the new rules add triggers, such as saving or replacing a stored card, and require options that don’t rely on a smartphone alone.
Separately, the European Commission is preparing a Digital Fairness Act that could make cancelling a subscription as easy as signing up.
Neither law yet deals directly with payments an AI agent makes on a customer’s behalf, which is where things are moving fastest. But what matters for AI companies today, it's that when customers switch plans, top up and cancel all the time, the payment setup has to keep up.
What I hear from AI companies
Still, when I sit down with AI companies selling into Europe, the conversation rarely starts with regulation. It starts with something that broke.
"Can we charge automatically when a balance runs low?"
Most AI companies run on recurring billing and yet many of the AI merchants I speak to don’t see themselves as subscription businesses at all. Their users burn through credits, and they want a refill to fire when the balance drops below a line the customer set. That works, as long as the customer clearly agreed and each recharge tells the bank so. The follow-up is always: if a customer disputes it, who pays? Because nobody authenticates that charge, usually the merchant. So, the agreement at sign-up is worth getting right.
"Our customers say they never signed up for a subscription."
One company told me many of its disputes weren’t fraud at all. Customers didn’t recognize an automatic top-up on their statement, because in their heads they’d bought credits, not a plan. A clear name on the statement and a short email before each recharge did more than any fraud tool.
"Can we just force 3D Secure on everything?"
I understand the instinct, usually after a bad month of fraud. Authenticated payments usually move any fraud liabilities to the bank, but every check is a moment the customer can walk away, and automatic recharges can’t be checked anyway. Small payments aren’t a free pass either: payments of €30 or less can skip the check, but the customer’s bank keeps a running tally across everything on that card, and you can’t see it. The goal is to check where the risk is and make it painless when it comes.
"Is banning the account enough?"
Digital goods attract a familiar form of abuse: use the service, then claim the charge was fraud. Stolen cards are worse, buying access that’s used up, and even resold, before anyone disputes it. Banning the account is sensible but often comes too late. Fast dispute alerts, and usage records you can send back as evidence, matter as much.
"Should we add iDEAL, Bancontact, Wero?"
Cards, Apple Pay and Google Pay go a long way, but local methods still decide conversion in markets like the Netherlands and Belgium, and Wero, Europe’s new wallet, is coming to online checkouts. Match the method to the payment: plenty suit a one-off top-up; fewer can carry an automatic one.
"We already accept European cards. Why rethink where our payments are processed?"
Accepting a card isn’t the same as being set up for a market. If a European card is processed outside Europe, the customer’s bank still follows European rules, and if it can’t run its usual check, it has to decide whether to block the payment or take on the risk itself. Banks have reason for caution: the EBA and ECB found card fraud was about 17 times higher when the business being paid was outside the European Economic Area. Processing inside Europe won’t guarantee approval, but it stops offshore processing being the weak link.
Where Nuvei fits
An AI company’s billing system owns usage, balances, recharge rules and access, whereas Nuvei handles the payment.
One service, different payments
Now let's back to that developer, working on hard deadlines, purchasing credits as they go. They want to keep working. Behind the screen, their renewal, top-ups, and automatic recharges are different payments. A good European payment setup knows the difference, so they never have to.
