Decree No. 13.135/2026 replaces Decree No. 11.034/2022 and will govern the Consumer Service (SAC) starting November 2. There are 20 days between publication and effectiveness, with no transition rule.
For the financial market, the most relevant change concerns scope. The new decree expressly includes institutions supervised by the Central Bank that provide financial, payment or credit services through digital means. Virtual asset service providers are also covered. Entities supervised by SUSEP depend on the regulator's criteria, and digital marketplace, mobility and delivery platforms will have to report their customer service model to Senacon.
In practice:
- Human service every day, from 8 a.m. to 8 p.m., by telephone and electronic channels, with at least one electronic channel operating 24 hours. Artificial intelligence is permitted, provided that the consumer can opt for human service.
- Waiting time with an objective benchmark: 20 seconds for 80% of calls and 300 seconds for the rest. IVR and chatbots are limited to five levels, with a cancellation option and a human agent option at every level.
- Cancellation with immediate effect, accepted through any channel in which the product can be contracted. Improper charge or unsolicited service: suspension completed within 48 hours.
- Advertising is prohibited at any stage of the service, with no exception for consent. Chat conversations and voice messages must now be kept for 90 days.
- The minimum record retention period falls to 6 months, but the ombudsman and AML/CFT rules continue to require longer periods. Anyone who reduces retention by looking only at the decree creates a problem on another front.
With a 20-day deadline, the review must begin now: human service schedule, IVR and chatbot tree, removal of advertising from SAC channels, a 48-hour routine for improper charges, cancellation through all contracting channels, and contracts with outsourced call centers and regulated partners. In embedded finance, the point of attention is the contractual pass-through of these obligations between the platform and the regulated institution.
The carousel summarizes what has changed and what to review. Banks, payment institutions, credit fintechs, virtual asset service providers (PSAVs), insurers and platforms wishing to discuss compliance can speak with our team.
