Decree No. 13,135/2026 replaces Decree No. 11,034/2022 and will govern Customer Service (Serviço de Atendimento ao Consumidor – SAC) as of November 2. There are 20 days between publication and entry into force, with no transition rule.
For the financial market, the most relevant change is scope. The new decree expressly covers institutions supervised by the Central Bank of Brazil that provide financial, payment or credit services through digital channels. Virtual asset service providers (VASPs) are also covered. Entities supervised by SUSEP depend on the regulator's criteria, and digital marketplace, mobility and delivery platforms must now report their customer service model to Senacon.
In practice:
- 1.Human service every day, from 8 a.m. to 8 p.m., by phone and on electronic channels, with at least one electronic channel operating 24 hours a day. Artificial intelligence is allowed, provided the consumer can opt for a human agent.
- 2.Objective waiting-time benchmarks: 20 seconds for 80% of calls and 300 seconds for the rest. IVR and chatbot menus are limited to five levels, with a cancellation option and a human-agent option at every level.
- 3.Cancellation takes effect immediately and must be accepted through any channel in which the product can be contracted. Undue charges or unsolicited services: suspension completed within 48 hours.
- 4.Advertising is prohibited at any stage of customer service, with no exception for consent. Chat conversations and voice messages must now be kept for 90 days.
- 5.The minimum record-retention period drops to 6 months, but ombudsman and AML/CFT rules still require longer periods. Anyone who shortens retention based solely on the decree creates a problem on another front.
With a 20-day deadline, the review needs to start now: human-agent staffing, the IVR and chatbot tree, removal of advertising from SAC channels, a 48-hour routine for undue charges, cancellation across all contracting channels, and contracts with outsourced call centers and regulated partners. In embedded finance, the point of attention is the contractual allocation of these obligations between the platform and the regulated institution.
The carousel summarizes what changed and what to review. Banks, payment institutions, credit fintechs, VASPs, insurers and platforms wishing to discuss compliance can contact our team.
