The next year will require the ability to read a system that has matured, integrate areas and decide before conflict escalates
The year 2025 consolidated a silent change in the consumer environment. There was no legislative rupture, but the practical combination of four factors that began to act in an integrated manner: the complete digitalization of the consumer journey, the increase in demands, the consolidation of understandings in the higher courts and a more informed, connected and attentive consumer to the experience.
In this scenario, models that worked well for many years started to live in a more predictable, integrated and demanding environment. This is not about denying the past, but about recognizing the maturity of the system. And more mature systems require equally mature decisions.
Procons in 2025: consolidated protagonism and direct impact on litigation
Some time ago, Procons stopped being just a preliminary administrative step. They already have a direct impact on companies’ litigation and reputation, including through increasingly accessible public rankings, recidivism indicators and conduct history.
In 2025, this role has become even clearer. The Procons began to occupy a central position in the management of consumer conflicts, functioning as a relevant space for filtering, qualifying and, above all, resolving demands that, when mismanaged, tend to migrate to the Judiciary.
The reading is objective. Treating Procon as a priority arena for a solution is neither a concession nor institutional weakness. It is a rational governance decision. Resolving complaints at this stage reduces judicialization, reduces procedural costs, avoids the formation of repetitive liabilities and preserves reputational indicators that directly influence the perception of the market and control bodies.
More than responding well, the challenge became solving well, with consistency, traceability and demonstration of good faith. Companies that internalize this logic start to use Procon not only as a defensive channel, but as an effective instrument for risk management and economic efficiency, with a direct impact on the volume of shares, average cost per demand and predictability of liabilities.
STF and STJ: predictability as an ally, not a threat
If 2024 already indicated a trend, 2025 confirmed it. Predictability has increased. The STJ, by establishing theses on repetitive themes, reduced areas of uncertainty and expanded companies’ ability to plan risks more clearly.
In practice, this movement does not automate convictions or eliminate defensive strategies. It creates trails. And trails, for companies, are organizational opportunities. An example of this is the reaffirmation of guidelines on liability for product defects and extension of reimbursements within legal repair deadlines.
At the STF, discussions on civil liability in digital environments also gained density, especially on topics of general repercussion linked to the application of the CDC in intermediation and marketplace models.
The central point is simple. Predictability does not eliminate strategy. It changes the way you decide. Instead of depending on a “saving thesis”, management starts to rely on well-designed internal policies, clear criteria, coherence in action and consistency of evidence throughout the portfolio
Where everything converges: system maturity and more sophisticated management
With more structured Procons, higher courts stabilizing understandings and consumers with more complaint and reputation tools, consumer risk is no longer just a legal one. It also becomes operational, informational and governance, requiring integration between legal, service, compliance and business areas.
Public platforms and organized service bases reinforce this logic of transparency, monitoring and measurement. More mature environments require more mature decisions, which means treating consumption management as an executive topic, supported by integration, predictability and consistency
What 2026 tends to demand from companies
2026 should not reinvent the CDC. It must require companies to start seeing it as a governance instrument. In practice, four movements gain relevance:
1) Integrated view of consumption risk
The distance between SAC, Ombudsman, Procon, consumer.gov and litigation has decreased, requiring a unified reading of causes, recurrences and criticality.
2) Alignment between legal, operations and senior management
In scale sectors, litigation directly relates to provisions, efficiency and reputation. The legal department remains technically responsible, with an expanded mission of translating risk into executive decision.
3) Earlier decisions, based on precedents and facts
This is not about exchanging legal analysis for a spreadsheet, but about using precedents as a policy reference and operational data as a basis for responses.
4) Intelligent use of data in response management
Data serves to make better decisions, reduce noise, calibrate defenses and demonstrate diligence. Procons and public platforms start to function as thermometers of the system’s quality.
Evolving is not correcting, it is accompanying
What 2025 taught is that Consumer Law began to operate as an institutional language of trust. And confidence is linked to the ability to decide carefully on details.
More than correcting conduct, 2026 will require companies to be able to read a system that has matured, integrate areas and decide before conflict escalates. It is at this level that Consumer Law stops being a reaction and becomes management.
This article ends the column in 2025, in a period that coincides with the forensic recess. The following year will bring new challenges, and 2026 will be another space to deepen legal debates that directly impact business decisions.
*This text does not necessarily reflect the opinion of Jovem Pan.
