Ley 10/2025, Spain's Customer Service Act, in force since 28 December 2025, gives companies until 28 December 2026 to adapt their customer service. It covers basic services and companies with 250 employees or over €50 M in turnover: a human agent on request, 95% of calls answered in under 3 minutes and replies within 15 working days.
What Ley 10/2025 is and why 28 December 2026 is the key date
Ley 10/2025 of 26 December, Spain's Customer Service Act, regulates customer service: it sets minimum quality levels and how they are evaluated. It was published in the BOE, Spain's Official State Gazette, on 27 December 2025 and came into force the next day, but its sole transitional provision gives companies twelve months to adapt their services. That period ends on 28 December 2026.
The law creates no new authority or register. It changes what counts as acceptable customer service and puts the burden of proof on the company (art. 4.7). If a customer or a consumer authority says the rules were not met, you have to prove otherwise. So rather than a new script for the call centre, the law requires records, deadlines and evidence for every enquiry, complaint and claim.
Who it applies to: basic services and large companies
The law applies to two groups of companies (art. 2):
| Group | Who | Nuance |
|---|---|---|
| Basic services of general interest (art. 2.1) | Water, gas and electricity supply; air, rail, sea and bus transport; postal services; electronic communications; financial services | Electronic communications and financial services are governed by their own sector rules, which take precedence. Public bodies providing these services to consumers are also included |
| Large companies (art. 2.2) | Those that sell goods or services mainly to consumers and, in the previous financial year, individually or as a group, had 250 or more employees, or over €50 million in turnover, or over €43 million on the balance sheet | The three thresholds are alternatives: exceeding one is enough |
The law is supplementary: where a sector-specific rule regulates customer service, that rule applies first (art. 2.4 to 2.6). For other companies that sell to consumers in Spain, the law does not impose these obligations, but it does set what the market will start to expect from good service.
What it requires, article by article
The obligations fall into seven blocks. This table lists the main ones with their article:
| Block | What it requires | Article |
|---|---|---|
| Channels | Accept complaints and claims through the channel used to sign the contract and, at a minimum, by post, phone and electronic means | 7.1 |
| Human agents | Automated systems cannot be the only option; on request, the customer is served by a person who identifies themselves; option to ask for a supervisor or a call-back on the same working day | 8.1, 8.2, 8.3 and 3.11 |
| Phone | Answer 95% of calls, on average, in under 3 minutes; never drop a call because of the wait; cost no higher than a standard call; a free number cannot redirect to a premium-rate one | 8.2, 8.4, 10.1, 10.3 and 10.4 |
| Receipt and records | An identification code for each complaint and a written receipt on a durable medium; recording or transcript of the call if the customer consents | 11 and 12.1 |
| Handling | At least 10 working days to complete an incomplete complaint; reply in the language of the complaint; if it is rejected, give details of alternative dispute resolution bodies; do not keep charging or cut off the service if the complaint moves to that route | 13.3, 13.6, 13.7 and 13.8 |
| Staff | Ongoing staff training, including Spain's co-official languages and accessibility | 9.2 |
| Satisfaction | A documented satisfaction system; surveys cannot be sent before the case is resolved | 18 |
In addition, the service must be free of charge, effective, universally accessible, inclusive, non-discriminatory and measurable (art. 4.1), and channel design must take accessibility into account (art. 15).
Response deadlines: 15 working days, 5 days and 2 hours
The general rule is that enquiries, complaints and claims must be resolved as soon as possible and within 15 working days at most from submission (art. 17.1), unless sector rules set a different deadline. There are two shorter deadlines:
| Type of request | Maximum deadline | Article |
|---|---|---|
| Enquiries, complaints and claims in general | 15 working days | 17.1 |
| Complaints about billing or undue charges | 5 days | 17.3 |
| Continuity incidents in continuously supplied basic services | 2 hours (and 24/7 service for those incidents) | 17.2 and 14.2 |
| Completing an incomplete complaint | The customer has at least 10 working days | 13.3 |
The practical problem is counting. Fifteen working days are not fifteen calendar days, the clock starts when the complaint is submitted (not when someone reads it), and the 5-day billing deadline runs alongside the general one. If complaints arrive by phone, email, web form and in store, and each channel logs them somewhere different, nobody knows how many fall due this week.
Annual evaluation, audit and penalties
The law is not satisfied with you complying: it asks you to measure it and have a third party verify it.
- Annual quality evaluation (art. 21): a documented system applied every year, with records kept for at least five years. The documentation must be available to the authority before the end of the first quarter of the following year and published on the company website.
- Annual audit (art. 22): it must confirm that the measurement error does not exceed 5% and is carried out by an auditor accredited by ENAC, Spain's National Accreditation Body.
- Smaller companies within scope: they may evaluate and audit every two years if they can justify it.
As for penalties, non-compliance is treated as a consumer protection offence and is handled under the general penalty regime of Spain's General Consumer Protection Act (texto refundido de la Ley General para la Defensa de los Consumidores y Usuarios) and regional legislation (art. 23). Sector penalties take precedence and data protection follows the GDPR and the LOPDGDD, Spain's data protection act; repeat offences are an aggravating factor and making good the damage is a mitigating one.
In operational terms: if you do not have every complaint logged with its submission date, reply date and outcome, you will be able neither to carry out the annual evaluation nor to pass the audit.
Chatbots and AI: what can be automated
The law does not ban chatbots, voice assistants or AI in customer service. What it bans is making them the only option (art. 8.1): customers have the right to be served by a person when they ask (arts. 3.11 and 8.2), and that request counts towards the 95%-in-under-three-minutes target.
A sensible split looks like this: automation logs, classifies, issues the receipt, calculates deadlines, sends alerts and suggests replies; a person takes over when the customer asks and decides in the cases that require it. It is the same principle we apply to governed AI agents within a process: AI does the repetitive work and the human step stays where the rules or the risk demand it.
Rule of thumb. If your customer cannot reach a person without hanging up and calling again, you do not comply with article 8. And if you cannot show how many complaints were resolved within 15 working days, you will not pass the article 22 audit.
Checklist to be ready by 28 December 2026
- Check whether you are in scope: a basic services sector or, based on the previous financial year, 250 employees, €50 million in turnover or €43 million on the balance sheet (individually or as a group).
- List the channels through which enquiries, complaints and claims arrive and add any that are missing (post, phone and electronic, plus the channel used to sign the contract).
- Review your phone system: option to speak to a person, wait-time measurement, call cost, and no calls dropped because of the wait.
- Centralise logging: an identification code per complaint and a written receipt on a durable medium sent automatically.
- Configure the deadlines: 15 working days by default, 5 days for billing, 2 hours for continuity incidents, and alerts before they fall due.
- Prepare rejection replies with information on alternative dispute resolution bodies.
- Design the satisfaction survey to be sent after the case is closed, not before.
- Define the indicators for the annual evaluation and who documents it, and hire an ENAC-accredited body for the audit.
- Train the team, including co-official languages and accessibility, and keep a record of the training.
How Dokuflex solves it: every complaint, a case with a deadline
Dokuflex, a low-code BPM platform with AI, is not a phone system: phone wait times are measured in your telephony system. What it does solve is everything that happens from the moment the enquiry, complaint or claim is logged until it is answered and evaluated, which is where the law demands evidence. Dokuflex has a ready-made customer service process template designed for Ley 10/2025:
- Logging from any channel: each request stores its entry channel, type (enquiry, complaint, claim or incident), affected product or service and contract, order or invoice reference. The customer is selected from a shared master record and their details fill in automatically.
- Public form with tracking code: customers can submit a complaint from a link without an account and receive a code to check its status.
- Automatic receipt: when the request is logged, an email acknowledgement goes out with the case reference and the reply deadline.
- Calculated deadline and escalation: the 15-working-day deadline is calculated automatically, the case shows whether it was answered within the legal deadline, and it can be escalated to another department or body with the reason.
- Language, accessibility and vulnerability: fields for the service language, adaptation needs and whether the person is in a vulnerable situation.
- Rating and dashboard: the customer's rating (1 to 5) is collected at closure, and the dashboard and kanban view show volume, statuses and on-time replies: the starting data for the annual evaluation.
As with every process in Dokuflex, each step is logged with who, what and when, and the workflow adapts without coding: adding the 5-day billing deadline or a legal review step before a rejection is configuration, not a project. Request a 20-minute session and we will show it to you with your own channels, or browse other ready-to-use process templates.
Frequently asked questions
When does Spain's Customer Service Act come into force?
Ley 10/2025 was published in the BOE on 27 December 2025 and came into force on 28 December 2025. Its sole transitional provision grants twelve months to adapt customer service operations, so the practical deadline is 28 December 2026, with some exceptions for non-profit organisations and certain electricity, gas and telephone providers.
Which companies does Ley 10/2025 apply to?
To companies providing basic services of general interest (water, gas, electricity, air, rail, sea and bus transport, postal services, electronic communications and financial services, the last two under their own sector rules) and to companies that sell mainly to consumers and, in the previous financial year, had 250 or more employees, over €50 million in turnover or over €43 million on the balance sheet, individually or as a group.
Is it mandatory to answer the phone in under 3 minutes?
The law requires 95% of calls to be answered, on average, in under three minutes (art. 10.3) and applies the same target to requests to speak to a person (art. 8.2). In addition, the call cannot be dropped because of the wait or cost more than a standard call to a landline or mobile number.
How long does a company have to reply to a complaint?
At most 15 working days from submission, unless sector rules set a different deadline (art. 17.1). Complaints about billing or undue charges must be answered within 5 days, and continuity incidents in continuously supplied basic services within 2 hours.
Can chatbots or AI be used in customer service?
Yes, but not as the only option. Article 8.1 prohibits automated systems from being the only channel, and customers have the right to be served by a person, who must identify themselves, when they ask. AI can log, classify, send the receipt, calculate deadlines and suggest replies; human service must be available.
What happens if I do not comply with Ley 10/2025?
Non-compliance is a consumer protection offence and is penalised under the general regime of Spain's General Consumer Protection Act and regional legislation, unless a specific sector regime applies. In addition, the burden of proof lies with the company (art. 4.7): if you cannot prove you replied on time, it is presumed you did not.
What is the annual customer service audit?
The law requires a documented system for evaluating service quality every year, with records kept for at least five years and published on the website, and an annual audit confirming that the measurement error does not exceed 5%, carried out by an ENAC-accredited auditor. Smaller companies within scope may do this every two years if they can justify it.
Sources
Checked on 6 November 2026. The articles cited refer to the consolidated text published in the BOE.
- Ley 10/2025, de 26 de diciembre, por la que se regulan los servicios de atención a la clientela: scope (art. 2), obligations (arts. 4 to 19), evaluation and audit (arts. 21 and 22), penalties (art. 23) and adaptation period (sole transitional provision).
- Texto refundido de la Ley General para la Defensa de los Consumidores y Usuarios: Spain's general penalty regime for consumer protection.
- PwC, Periscopio Fiscal y Legal: summary of the law and the adaptation period.
- KPMG Abogados, Legal Alert: analysis of the obligations for companies.
Reach 28 December with every complaint logged, dated and answered on time
Show us how complaints and claims reach you today (phone, email, web form, store) and in 20 minutes we show you the workflow with written receipts, calculated legal deadlines, escalation and the indicators for the annual evaluation.