Anything is possible, but I don't think this current time it takes for a transaction to get confirmed is too long to be patient for, depending on how the mempool is congested or less busy.
It can be a hurdle in some cases like when the buyer needs instant delivery but seller makes him wait till confirmed.
Which cases do you mean exactly?
I'm thinking, and I can't find a single situation where the buyer can't wait 10 minutes for the first confirmation of the transaction. Finally, the transaction confirmation helps the seller to be sure that his service has been paid for.