In sectors where the customer experience is built on dozens of micro-interactions, the quality of customer service can make all the difference. Law 10/2025 establishes, for the first time in Spain, a comprehensive framework for how companies must organize, provide, and demonstrate the quality of their customer service. Adapting to these new obligations poses significant challenges that must be addressed as a cross-functional initiative involving operations, sales, legal, quality, and technology departments.
Law 10/2025, of December 26, 2025, regulating customer service (the LSAC), effective as of December 28, 2025, though with differentiated implementation deadlines, establishes mandatory minimum quality standards and a control and evaluation system that requires many companies to review their processes, technology, and customer service teams. In doing so, the new law professionalizes customer service and turns best practices into mandatory standards with a direct impact on operations, technology, and internal organization.
The legislation also makes significant amendments to Royal Legislative Decree 1/2007 of November 16, 2007, approving the Revised General Consumer and User Protection Law (the TRLGDCU), establishing cross-cutting information obligations for any company offering goods and services to consumers.
Scope of application
The obligations regarding customer service are not enforceable against all companies. The LSAC applies, on the one hand, to certain basic services of general interest, including passenger transport operators regardless of their size; and, on the other hand, to the sale of goods and the provision of services primarily aimed at consumers in the case of large companies or groups of companies (within the meaning of article 42 of the Commercial Code) that, in the previous fiscal year, met any of the following criteria: 250 or more employees, an annual revenue exceeding 50 million euros, or an annual balance sheet total exceeding 43 million euros.
The LSAC applies regardless of the channel (in-person, telephone, electronic), of whether the service is provided internally or through a third party, and of where the point of contact is located (an aspect that may, however, be relevant in light of the language obligations laid down in the regulation).
In terms of timing, the transitional provision establishes a twelve-month adaptation period from the date of entry into force. The operational adjustment of customer service operations should be completed by December 28, 2026. This is not the case for the new information obligations under the TRLGDCU, introduced by the third final provision, which have been in force since December 28, 2025.
Key obligations regarding customer service
The LSAC requires that customer service be free, effective, accessible, and inclusive, imposing standards that directly affect tourism operations.
With regard to business hours, the service must align with the company’s business hours, with a specific rule for online businesses: business hours will be determined by the times during which transactions with consumers can be conducted.
Regarding the required communication channels, the LSAC imposes a multi-channel principle: the company must accept the same channel through which the contractual relationship was initiated and, in addition, at least via mail, telephone, and an electronic medium, ensuring universal accessibility. The regulation also directly addresses the use of automated systems. The use of answering machines or similar systems as the sole means of customer service is prohibited, and it requires that, if bots or telephone menus (expressly permitted) are used, the customer must be able to request personalized (human) assistance from the main menu at any point during the interaction, starting from the very beginning.
The LSAC also incorporates quantifiable requirements regarding wait times: 95% of requests for personalized assistance must be addressed, on average, within three minutes of the customer’s request.
The regulation adds other relevant operational safeguards: if the customer is dissatisfied with the operator’s service, they may request to be transferred to a supervisor or the quality department during the same call (or, if this is not possible within three minutes, to be contacted later on the same business day). And it is prohibited to end a call due to a long wait time.
Regarding resolution deadlines, the general rule is strict: inquiries, complaints, claims, and incidents must be resolved as soon as possible and, in any case, within a maximum of fifteen business days, with shorter deadlines for specific sectors (e.g., billing or improper charges). The reasons for the resolution in question must be stated, avoiding generic responses.
The LSAC has not overlooked the linguistic diversity in Spain either. Customers’ linguistic rights are guaranteed in various situations: when customer service is directed at customers located in autonomous communities with official language(s), any of the official or co-official languages may be used when submitting inquiries, complaints, claims, or incidents. Furthermore, at the request of the consumer in territories with multiple official languages, service must be provided in the requested official language (provided that the company provides services in that region and the language is official there). Accordingly, the company must equip its customer service department with sufficient human and technical resources, training, and organizational structure to guarantee these rights.
Practical implications for the sector
The impact of the LSAC lies not only in having a customer service channel, but in demonstrating compliance with measurable quality standards and doing so consistently across the entire network.
Companies will have to review the design of the contact experience and the channel architecture: not only will customer service and after-sales support need to be integrated into the same sales channel, but IVR menus, chatbots, web forms, and messaging channels must allow customers to request personalized assistance seamlessly from the start of the interaction and in a measurable way.
Furthermore, response time standards require a rethinking of staffing levels and training: to ensure an agent’s intervention when requested by the customer, compliance with the metric of responding to 95% of requests within three minutes, and the provision of service in one of Spain’s co-official languages.
The regulation also includes monitoring obligations that should not be underestimated: companies must implement an annual system to assess service quality, retain documentation for five years, make it available to the government, and publish it along with the audit report on their website. The audit must be conducted by an ENAC-accredited entity, with adjustments for companies below certain thresholds, based on the volume of communications.
Finally, the human dimension is key. The law does not only require technical resources; it mandates providing adequate human resources and ensuring training for staff who manage and design automated systems, including criteria for universal accessibility and support for vulnerable consumers. For the tourism sector, where diversity (age, abilities, languages, channels) is structural, this directly impacts brand standards and reputational risks.
New information obligations
The LSAC does not only incorporate customer service obligations. It also modifies the consumer information regime in several aspects of utmost relevance to the tourism and hospitality sector.
First, businesses are required to inform consumers of the full final price from the outset, with a breakdown of price increases, discounts, and additional fees, including potential processing fees.
It also introduces a transparency obligation when prices are personalized through automated decisions, with limits to prevent price increases in situations of urgency, risk, or necessity. In other words, the regulation requires transparency regarding the algorithms used to personalize prices, prohibiting price increases during the transaction.
Furthermore, subscription service providers are required to notify their customers, at least 15 days before charging for subscription renewal, of the consequences of failing to cancel the subscription. This obligation applies to fixed-term contracts subject to renewal, regardless of whether the subscription began as part of a promotional offer or through successive renewals of previous subscriptions.
The regulation of reviews deserves special mention: it must be disclosed whether or not it is guaranteed that the reviews come from consumers who have actually used or purchased the service, and transparency regarding their processing is required. Furthermore, reviews must refer to services used or purchased within the preceding thirty calendar days; the right of reply through the same channel is recognized, as is the possibility of requesting removal if the lack of authenticity or the deceptive nature of the review is reliably proven.
Finally, rules regarding telephone sales and marketing are being tightened: a contract entered into over the phone is presumed void if regulations on unsolicited calls are violated, and consent is deemed non-existent if it was not expressly obtained or renewed within the previous two years.
Penalty regime
The LSAC does not establish its own penalty regime but rather refers to the general penalty regime for consumer matters.
At the national level, the TRLGDCU classifies infringements as minor, serious, and very serious, with fines ranging from 150 to 10,000 euros (minor), 10,001 to 100,000 euros (serious), and 100,001 to 1,000,000 euros (very serious), with these amounts subject to increase based on the illicit profit, in addition to ancillary penalties such as publicizing the penalty or requiring rectification.
In short, customer service will no longer be measured solely by the availability of the service, but also by its accessibility, effective human interaction, and measurable wait times. Special attention should also be given to the new consumer information obligations regarding key aspects such as price personalization, subscription renewals, or reviews.
In practical terms, the takeaway is clear: customer service is no longer merely a reputational matter, but rather a matter of regulatory compliance that companies must be able to prove.
