Comprehensive Reform of the National Consumer Arbitration System (SNAC)

Analysis of Disposition 892/2025

Ministry of Economy – Undersecretariat for Consumer Protection and Fair Trade
Date: 08/14/2025

Regulatory Context

This disposition falls within the framework of Consumer Protection Law No. 24,240 and its amendments, along with Decree 276/1998, which created the National Consumer Arbitration System (SNAC).
Its objective is to update and restructure the procedural rules of consumer arbitration, considering:

  • The evolution of national and international arbitration.

  • The need to digitize procedures (electronic arbitration as a principle).

  • Special attention to vulnerable consumers.

  • The incorporation of artificial intelligence and new technologies in conflict management.

Main Innovations Introduced

a) Digitalization and Electronic Arbitration

  • Arbitration will be electronic by default, in-person only as an exception (Art. 25).

  • Notifications and proceedings will preferably be carried out electronically, including through the TAD (Remote Procedures) system.

b) Vulnerable and Disadvantaged Consumers

  • A fast-track and urgent procedure is created (Arts. 50-58).

  • Shortened deadlines: notifications within 2 days, hearings within 5 days.

  • The process will primarily be conducted by a single arbitrator, except in complex cases.

c) Incorporation of New Technologies

  • Possibility of implementing artificial intelligence in case management and deadlines (Art. 19).

  • This seeks to improve efficiency and reduce system congestion.

d) Public Supplier Adhesion Offer

  • Suppliers may join SNAC through a binding public offer (Arts. 4-9).

  • They receive a digital badge to display across their communication channels.

  • Conditions of permanence, withdrawal, and exclusion are regulated.

e) Arbitrators and the Arbitral Tribunal

  • The tribunal may include institutional and sectoral arbitrators, who must meet training requirements in consumer law, arbitration, or commercial law.

  • The Emergency Arbitrator role is introduced (Art. 14).

  • The tribunal may be composed of a single arbitrator or a panel, depending on the case’s value or nature.

  • Grounds for excuse and recusal are established to ensure impartiality.

f) Special Proceedings

  • Tourism Arbitration: designed for urgent conflicts in tourism services (Arts. 59-69).

  • Proceedings for vulnerable consumers: extremely shortened deadlines and hearings to provide immediate responses.

g) Awards and Appeals

  • The arbitral award has res judicata effect (Art. 1).

  • Judicial enforcement may take place at the domicile of the consumer, the supplier, or SNAC’s headquarters (Art. 75).

  • An annulment action or appeal is allowed against awards (Arts. 76-79).

Expected Impact

  • Strengthening of SNAC: modernization of its functioning with procedural and technological tools.

  • Enhanced consumer protection: especially for vulnerable sectors, ensuring speed and accessibility.

  • Predictability for suppliers: the digital badge operates as a trust seal and may become a reputational tool.

Practical challenges include:

  • Implementing AI without compromising principles of impartiality and due process.

  • Ensuring digital connectivity in regions with lower technological access.

  • Guaranteeing that digitalization does not exclude those lacking digital skills.

Final Assessment

Disposition 892/2025 represents a significant step forward in modernizing consumer protection in Argentina. By establishing electronic arbitration as the rule, it introduces efficiency and reduces costs—an advantage in a country where litigation rates are typically high.

However, the introduction of artificial intelligence presents a challenge: it should be used as a tool for administrative management, not as a replacement for human legal judgment in case decisions, in order to avoid risks of algorithmic bias or denial of justice. Furthermore, the system’s success will depend on the training of arbitrators and officials, as well as the trust consumers place in the impartiality and effectiveness of the procedure.

In sum, this disposition elevates consumer arbitration as an agile, modern, and accessible mechanism, though its implementation will require strict oversight to ensure that technology enhances—rather than undermines—consumer rights.