The accountability gap in embedded finance
We’ve made payments almost invisible. You can split a dinner bill inside a delivery app, get instant credit at checkout, or settle a ride fare before you’ve even stepped out of the car. That’s embedded finance: smooth for the customer, powerful for the platform. Embedded finance already represents trillions in transactions. Bain estimated that embedded finance in the US alone processed $2.6tn in 2021 and is on track to reach $7tn by 2026. That means rather than a side trend, these methods of payment are the new rails.
But here’s the blind spot. When those payments go wrong, the disputes are anything but invisible. Who owns the problem? The merchant, the app, the lender, or the bank in the background? Right now, nobody does. And that is exactly why embedded finance needs to change.
The Accountability Gap
Disputes used to be simple. A cardholder called their bank, the bank called the merchant, and the process unfolded. Embedded finance has scrambled that logic. Now, payments can be split across multiple parties, and ownership is cloudy. For example, a shopper buys furniture on a marketplace using buy-now-pay-later (BNPL) credit. The merchant ships the product late. The BNPL provider handled the loan, the marketplace processed the checkout, and the bank issued the card.
When the shopper doesn’t receive their item on time and quickly disputes the charge, who should resolve it? Everyone points in different directions. The result is frustration, delays, and rising chargeback volumes. This is more than an operational headache; it’s a credibility problem. A customer who can’t figure out where to get help loses trust not just in the merchant but in the whole platform and payment method itself.
Designing Dispute Journeys Upfront
Here is the truth: no one is solving this yet. Dispute ownership in embedded finance is still left to chance, and that model will not last.
If embedded finance is going to be the future of payments, then it also has to own the moments when payments are questioned. Disputes should be built into the flow from the start, not added as an afterthought.
Think about ride-sharing. You tap a charge, hit “Help,” and the app instantly shows you who is accountable. That is the expectation customers already have. Embedded finance should follow the same playbook: visible ownership, instant routing, and simple paths to resolution. Regulators are already watching. The Consumer Financial Protection Bureau (CFPB) in the U.S. has already signaled concerns around BNPL disputes. Europe is doing the same with embedded finance oversight. Overall, clear accountability is coming under scrutiny.
Who Stands to Win
If embedded finance players step up and take control of disputes, everyone benefits.
● Platforms protect their brand when customers know where to turn.
● Merchants cut chargeback losses and avoid surprises.
● Banks and processors spend less time firefighting disputes they shouldn’t own.
● Customers get clarity instead of confusion. PwC describes embedded finance as “the future of financial services distribution”. If that’s true, dispute handling has to be part of the package, not bolted on later.
The Real Test of Trust
Trust isn’t built when everything goes smoothly. It is built when something breaks and you fix it quickly.
That is the test embedded finance faces today. Invisible payments are exciting until they collide with visible frustration. The companies that step up, clarify ownership, and make disputes part of their design will set the new standard.
The next phase of embedded finance isn’t about making money harder to see. It is about making accountability impossible to miss.

Monica Eaton is the founder and CEO of Chargebacks911 and Fi911, as well as chief information fficer of Global Risk Technologies. Monica has worked tirelessly to educate merchants and financial institutions about hidden threats in the rapidly changing payment fraud landscape. Leading Chargebacks911, was founded in Tampa Bay, Florida, expanding internationally also to become Europe’s first chargeback remediation specialist to tackle the chargeback fraud problem. In ten years, Chargebacks911 has successfully protected more than 10 billion online transactions and has recovered over $1bn in chargeback fraud.

