The Commercial Agent Exemption is a statutory regulation, which is defined in Section 2 para. 1 No. 2 of the German Payment Services Supervision Act (ZAG). According to this exemption, certain activities aren’t classified as payment services, although they technically fulfill all the necessary requirements.
A fitting example for this regulation is a gas station operator who accepts cash payments for the oil company whose fuels the operator sells. If the commercial agent exception applies, the commercial agent may provide payment services without a permit. In the case of the example, this would mean that the gas station operator doesn’t have to apply for a permit in order to accept cash payments for the oil company.