Zero Sales During a Complaint: the Separation Required by the Customer Service Act in the Financial Sector

Imagine calling your bank to dispute a charge you do not recognize. You spend several minutes explaining the issue, the agent understands the situation… and suddenly offers you a discounted home insurance policy. Beyond being poor practice, this is now a legal breach. Law 10/2025 expressly prohibits it, and financial institutions must review their processes, incentives, and team training to ensure it does not happen.

At first glance, this requirement may seem secondary within the regulation. However, its organisational implications are significant, especially in a sector where customer service teams have spent years being trained to maximise the commercial value of every customer interaction.

What the law prohibits

Article 29.3 of the amended Law 44/2002, in connection with Article 13 of the Customer Service Act (LSAC), establishes two obligations that financial institutions must implement before 28 December 2026:

• Organisational separation between Customer Service Departments and commercial teams. Both structures cannot share sales targets or sales incentives.
• An express prohibition on making commercial offers while handling a complaint or claim, without exceptions.

This prohibition is not arbitrary. It is directly linked to the risk of mis-selling — selling an unsuitable product by taking advantage of a customer’s vulnerable position — a practice that has been under the scrutiny of the Bank of Spain and the CNMV for years. The Customer Service Act now turns this into a legal obligation with clear sanctions.

Separation of teams or separation of functions?

One of the most common questions raised by financial institutions is whether the law requires physically separate teams for customer service and sales, or whether a functional separation is sufficient. Consulting C3’s interpretation, aligned with the position held by the AERC, is that the regulation requires functional separation, not necessarily structural separation.

In practice, this means that while an agent is managing a complaint or claim, they cannot perform any commercial action. Incentives, targets, and scripts must all be designed to exclude any commercial component during those interactions. If an agent’s compensation includes sales-related variables, institutions must ensure these do not apply or generate incentives during complaint handling.

This also impacts CRM systems: if, during a complaint call, the agent’s screen automatically suggests products that could be offered to the customer, this functionality must be disabled while the interaction is classified as a complaint.

What about customer retention?

This is where one of the most interesting discussions arises: if a customer calls to cancel a service, can the institution attempt to retain them? Is this considered a prohibited commercial action or a legitimate customer relationship management activity?

According to the AERC’s interpretation, the key distinction lies in the approach. What the law prohibits is a purely commercial action: making a financial offer to prevent the customer from leaving. What could still be allowed is informing the customer about alternatives that genuinely address the issue they are experiencing.

The difference is subtle but crucial. If a customer wants to close their account because fees are too high, offering them a discount would be considered a prohibited commercial action. However, if the customer is experiencing a technical issue with a digital service and, while resolving it, the agent informs them that there is an improved version without that issue, the context is different. The underlying principle should always be the same: are we solving the customer’s problem, or are we taking advantage of their vulnerability to sell them something?

The controls that the law requires

Having a written policy is not enough. The regulation requires specific and documented controls:

• Review and update of scripts and customer service protocols to remove any commercial call-to-action during complaint or claim handling.
• Systematic call monitoring to detect and document potential breaches, together with corrective action plans.
• Specific and documented training for Customer Service agents regarding this functional separation, with particular emphasis on ambiguous scenarios such as customer retention.
• Review of incentive models to ensure that no commercial component influences complaint management.
• Interaction records available for audit by the Bank of Spain, the CNMV, or the DGSFP at any time.

If the Customer Service model is properly designed, complying with this requirement is easier than it may seem. The real challenge appears when organisations have spent years combining functions that the law now requires to be clearly separated. The deadline is approaching quickly, and the risk of inaction goes beyond regulatory sanctions: an institution that sells during a complaint process not only breaches the law, but also damages customer trust in a way that is difficult to repair.

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Bots, IVR and the SAC Law: automation can no longer be the only customer service option

The financial sector has spent years investing heavily in the digitalisation of customer service: conversational bots, sophisticated IVR systems, self-service apps, and virtual assistants. A model that has proven highly efficient. Until now.

Law 10/2025 introduces a principle that changes the rules: no customer can be trapped in an automated system if, at any point, they wish to speak with a human agent. The concept is simple, but its operational implications are far deeper than they may initially appear.

What the law says: the explicit right to human assistance

The amended Law 44/2002 establishes that financial institutions must guarantee access to a human agent for any customer who requests it, at any stage of the interaction. Chatbots and virtual assistants are considered complementary tools, never substitutes for customer service.

The regulation also establishes two mandatory minimum service channels: telephone support and at least one non-face-to-face channel. Institutions may add more channels, but they cannot eliminate these two or replace them with exclusively automated systems. The compliance deadline is 28 December 2026.

The real change: leaving the bot without leaving the channel

Until now, many institutions configured their automated systems so that if a customer wanted to speak with a person, they had to leave the channel — for example, exit the app chat and make a phone call. The SAC Law removes that option.

If a customer starts an interaction within an automated channel and requests human assistance, they must be able to receive it within that same channel, without needing to switch channels or start the process again.

This means reviewing all automated customer service flows and ensuring that there is always a functional and accessible route to a human agent. In many cases, this requires redesigning IVR decision trees, chatbot flows, and escalation processes within messaging and chat environments.

The practical question for technology teams is straightforward: if a customer is checking the status of a transfer through the app chatbot and writes, “I want to speak with a person”, what happens next? If the system simply provides a phone number and asks the customer to call, that flow is non-compliant.

24/7 service and its reasonable limits

The law specifically refers to 24/7 availability for essential services and urgent or irreversible situations. In the financial sector, this includes card blocking, fraud reporting, or urgent transfers: for these types of requests, human assistance must be available outside standard business hours.

The expectation is not that every service must have human agents available at all times. The key is identifying which parts of the operation are considered critical or urgent and guaranteeing coverage for those specific cases.

The challenge of data protection and vulnerable customer groups

Personalised customer service introduces another dimension that the law addresses directly: data protection. In telephone and digital interactions, it is not always possible to verify a customer’s identity or determine whether they belong to a specially protected group without asking questions that could compromise their privacy.

In April 2026, the AERC submitted a formal consultation to the Spanish Data Protection Agency (AEPD) seeking clarification on how to reconcile the right to personalised service with data protection obligations, particularly regarding customers with disabilities. The AEPD’s response is highly anticipated across the sector and, once published, will need to be incorporated into customer service protocols.

What your institution should review before year-end

• Audit all automated service flows (bots, IVR systems, apps, chatbots) and identify whether there is an option to transfer the interaction to a human agent within the same channel.

• Verify that this transfer is fully functional during all hours in which the channel is operational.

• Review customer identification protocols to ensure data protection compliance in personalised interactions, particularly for vulnerable groups.

• Document the mandatory minimum service channels (telephone + non-face-to-face channel) and confirm that no process excludes their use.

• Define which services are considered urgent or critical and therefore require human assistance coverage outside normal business hours.

Digital transformation is irreversible, and the SAC Law is not intended to stop it. What it demands is that technology remains aligned with customer needs. Consulting C3 and MST Holding work with financial institutions to redesign these operations efficiently: preserving what already works, adapting what the regulation requires, and documenting everything necessary to successfully pass an audit.

The 3-Minute Limit on Customer Service Calls: What Your Financial Institution Needs to Know

Law 10/2025 on Customer Service sets a clear countdown for all financial institutions: they have until December 28, 2026, to adapt their operations. One of the requirements raising the most questions among operations teams is the new waiting time limit for inbound customer service calls, as it directly impacts workforce planning, technology, and the service model itself.

During the executive webinar organized by Consulting C3 together with the Spanish Association of Customer Relationship Experts (AERC), this was the topic that generated the highest number of questions. And for good reason: the nuances that separate compliance from non-compliance are significant.

What does the law say?

The amendment to Law 44/2002 is clear: 95% of inbound Customer Service (SAC) calls must be answered within a maximum of 3 minutes. This threshold is measured on an annual basis, meaning that not every individual call is required to meet the target, but the overall yearly average must comply.

Achieving this 95% target has major operational implications. Those managing customer service centers know that reaching this level effectively means maintaining an abandonment rate between 1% and 2%, which requires a complete review of workforce management and capacity planning models.

When does the waiting time start counting?

This detail directly affects how measurement systems must be configured. The law distinguishes between two scenarios:

• If the customer calls the Customer Service department directly without going through any automated system, the timer starts from the very first second of the call.

• If the customer first accesses an IVR or any other self-service system, the timer starts the moment the customer explicitly requests to speak with a human agent.

This second point is especially relevant for institutions already operating IVR systems: the clock does not start when the customer dials the number, but when they request human assistance. The contact center platform must accurately and audibly register that moment, as an approximate estimation will not be sufficient.

Callback: a safety valve with conditions

The law allows institutions to offer a callback service when waiting times are expected to exceed the limit. However, offering a callback does not exempt the institution from complying with the KPI. The metric still measures the actual waiting time, regardless of whether the customer accepted a deferred call.

Callback cannot become a systematic workaround. If an institution relies on it massively and takes hours — or even days — to return calls, it creates clear evidence of non-compliance that can easily be detected during an audit. The law requires real responsiveness and the ability to prove it with data. The UNE Committee is currently working on clarifying whether a callback offered before exceeding the threshold counts as KPI compliance.

Example: if service hours end at 10:00 PM and a customer accepts a callback at 9:55 PM, that call cannot simply be postponed until the following day. Responsiveness remains an enforceable criterion even if it is not quantified with the same level of detail as the main KPI.

Measurement, logging, and reporting obligations

Complying with the KPI is not enough: institutions must also be able to demonstrate compliance. Financial entities are required to maintain systematic KPI records available for regulatory audit at any time. This involves periodic reporting with data broken down by time slot, channel, and service type, properly stored and preserved.

The calculation is annual, but supervision may occur at any moment. And oversight will not only come from regulators: customers who believe they were not assisted within the required timeframe will be able to file complaints with Consumer Protection Authorities starting January 1, 2027.

What should your institution be doing right now?

• Measure current waiting times and calculate how far you are from the 95% within 3 minutes threshold. Without real data, there is no baseline.

• Review telephone service capacity planning: shifts, demand peaks, and agent-to-call volume ratios.

• Assess the role of callback within the customer service model. If you already use it, make sure response times and records are properly documented.

• Confirm that the technology platform accurately detects and logs the exact moment a customer requests human assistance through the IVR.

• Prepare regulatory reporting processes: format, frequency, and data custody chain.

Consulting C3 and MST Holding have been working for months with financial institutions on diagnostics and adaptation plans for the SAC Law. As members of the UNE Committee, we provide our clients with the most up-to-date interpretation of every regulatory requirement.

SAC Law in the Financial Sector: What Your Institution Needs to Know (and Do)

The Customer Service Law (SAC Law) is now a reality. And although many financial institutions have been hearing about it for months, one question still raises more doubts than expected: what actually applies to us?

Banks, insurers, asset managers, credit institutions… the financial sector operates under its own regulatory layer, which does not always fit neatly with a general law. And that is precisely where interpretation issues begin.

In this article, we explain what the SAC Law means for the financial sector, which changes are unavoidable, and where the main adaptation challenges currently lie.

What is the SAC Law and why it matters now

The Customer Service Law (SAC Law) establishes a new framework of obligations for all companies providing services in Spain, with the aim of ensuring high-quality, accessible, and effective customer service.

Its main pillars include the prohibition of automated systems as the sole customer service channel, the obligation to resolve complaints within specific timeframes, the right to be assisted by a human agent, and the need to implement service quality monitoring and control systems.

So far, nothing new for those who have been following regulatory developments. The real challenge arises when a financial institution tries to apply this law on top of an already existing regulatory structure: MiFID II, Solvency II, Bank of Spain regulations, CNMV requirements… overlap is inevitable, and it is not always clear which rules take precedence.

The financial sector has its own rules. Now what?

One of the key complexities of applying the SAC Law in banking and insurance is that these institutions are already subject to very specific obligations regarding customer service and complaint management. The Bank of Spain, the CNMV, and the DGSFP have long required formal procedures, defined timelines, and documented records.

So, does the SAC Law add another layer on top, or does it simply reinforce what already exists?

The answer is not straightforward—and that is exactly what creates uncertainty within compliance and operations teams. Some obligations, if already covered by sector-specific regulations, may be considered compliant with the SAC Law. However, others require specific review, as the new law goes beyond what financial regulation has required so far.

Some concrete examples:

  • Complaint resolution deadlines under the SAC Law may differ from those set by financial supervisors. Which one prevails?
  • The right to human assistance is a new requirement that not all institutions fully guarantee across their current channels.
  • Service quality monitoring requires metrics and indicators that many organizations have not yet sufficiently formalized.

The three real challenges of adaptation for financial institutions

Beyond theory, in practice there are three areas where the impact of the SAC Law is most evident:

1. Customer service models
Institutions operating with highly digital channels or strong reliance on automated systems will need to assess whether they comply with the requirement for access to human assistance. It is not just about having a phone line—it must function according to the standards set by the law.

2. Complaint management
This is likely the area with the greatest impact. The SAC Law tightens deadlines and requires a more robust tracking system. For the financial sector, which already has established processes, the challenge lies in identifying where current procedures fall short.

3. Customer experience as a strategic lever
This is where the SAC Law stops being just a compliance issue and becomes an opportunity. Institutions that use this adaptation to genuinely improve their service model will not only meet regulatory requirements, but also gain in customer satisfaction, loyalty, and reputation.

What is your organization’s level of compliance?

This is the key question every financial institution should be asking right now. And answering it properly requires more than just reading the law—it requires aligning it with real operations, internal processes, and existing sector regulations.

This analysis is not simple. But it is necessary. And the sooner it is done, the more room there is for structured and well-planned adaptation.

How to adapt the SAC Law in banking and insurance: from regulation to action plan

One thing is becoming clear in the financial sector: the real challenge is not understanding the SAC Law, but implementing it. Many organizations are familiar with the regulation but still struggle to translate it into concrete changes in their customer service and complaint management models.

The difference between compliance and effective compliance lies precisely there: in how the law is embedded into daily operations. Which processes need adjustment, which channels require redesign, and how to measure true alignment with the new requirements.

With this objective in mind, MST Holding has developed a dedicated session for banking and insurance, designed to help organizations move from interpretation to execution.

On May 13th, we will host a webinar where we will address, in a practical way, what the SAC Law specifically requires in the financial sector, how to adapt customer service and complaint models step by step, and how to assess the real level of compliance through a structured self-diagnosis.

In addition, attendees will gain access to materials designed to facilitate this transition, including a practical guide focused on transforming customer service models and an express diagnostic tool to clearly identify each organization’s starting point.

The session will feature Patricia Guerrero Castro, Operations Director at Consulting C3, and José Francisco Rodríguez, President of the AEERC, providing expert insight from both operational and industry perspectives.

The event will be held online via Teams, is completely free of charge, and includes access to the recording for those unable to attend live. Places are limited.

MST Holding: expertise and knowledge serving the financial sector

At MST Holding, we have spent more than 30 years designing and implementing customer service models for companies in the financial, insurance, and services sectors. We understand the regulations—but more importantly, we understand operations: real processes, bottlenecks, and the points where compliance meets day-to-day reality.

That is why, when we support an organization in adapting to the SAC Law, we do not start from scratch—we build on what already works.

If your institution is currently assessing the impact of the SAC Law or needs a clear roadmap for adaptation, now is the time to approach it with the right criteria.

www.mstholding.com

Calendar Figures: MST’s solution to optimize capacity in banking contact centers

Capacity management in banking contact centers is one of the most complex operational challenges in the financial sector. Demand is neither constant nor predictable in the short term: it concentrates around very specific calendar dates, creating contact peaks that traditional planning models struggle to absorb without incurring high costs or compromising service quality.

In response to this reality, MST has developed its own solution: the calendar figure. A model that is not based on improvisation, but on years of analyzing banking customer behavior and an advanced Workforce Management vision.

The problem: seasonal demand with a rigid workforce structure

Banking has a distinctive characteristic that sets it apart from other sectors: demand is highly predictable at a macro level, yet very irregular in day-to-day operations. Pension payments, payroll cycles, tax campaigns, or regulatory changes generate intense contact peaks within very short timeframes.

The issue is not a lack of data. The information exists and is recurring. The real challenge lies in the mismatch between demand structure and workforce structure. Sizing a banking operation based solely on average volume inevitably leads to two undesirable scenarios: either overstaffing to absorb occasional peaks, or accepting service level degradation on critical days.

Both options carry real costs. And both are avoidable.

The calendar figure: structured capacity, not improvised

The calendar figure is a flexible capacity planning solution specifically designed to cover days with abnormal yet predictable behavior. These are not last-minute reinforcements or multi-skilled agents deployed without criteria. They are profiles integrated into the annual service planning, with activation days identified in advance by the Workforce Management team.

These agents work exclusively on pre-classified high-criticality days. Their deployment does not respond to forecast deviations, but to strategic decisions made in advance, based on historical analysis and business objectives.

Capacity is no longer treated as a homogeneous mass. It is structured into two complementary layers: a base capacity for regular demand, and a seasonal capacity activated at specific points in the calendar. Each layer has its own rules, cost structure, and performance indicators.

Economic impact: from fixed costs to controlled variable costs

This is where the model delivers one of its greatest values. In banking, cost per contact and cost per FTE are constantly under scrutiny. The ability to align capacity with actual demand—without overstaffing or degrading service—has a direct and measurable impact on the P&L.

Calendar figures enable MST to transform fixed costs into controlled variable costs. Every worked hour responds to a specific need and is backed by a clear business case. There are no idle hours tied to peaks that never materialize, nor capacity shortages on the most critical days.

The economic impact goes beyond direct costs. By reducing pressure on the core workforce during peak demand periods, several positive effects are triggered:

  • Reduced absenteeism: less extraordinary workload means fewer stress- or fatigue-related absences.
  • Lower attrition: teams that are not consistently overwhelmed are more stable and less likely to leave.
  • Reduced overtime: additional capacity is planned in advance, not generated reactively.

These three factors carry significant indirect costs in the medium term. In the contact center industry, attrition and absenteeism are two major drivers of economic inefficiency. The calendar figure model directly addresses both.

Additionally, the model’s transparency enhances executive decision-making. Each activation of calendar figures is justified, budgeted, and linked to a specific banking calendar event. This improves operational efficiency while simplifying financial planning.

WFM as the engine of the model

Deploying the calendar figure is not possible without a mature, strategically oriented Workforce Management function. At MST, WFM goes beyond volume forecasting: it interprets the banking calendar as a map of risks and opportunities, models scenarios, defines safety margins, and orchestrates capacity activation with precision.

Erlang C models, the standard tool for contact center sizing, find a key ally in the calendar figure. By avoiding the need to overstaff the base workforce to cover occasional peaks, Erlang can be applied more realistically, with tighter buffers and more reliable outcomes.

The result: economic efficiency and customer experience aligned

The calendar figure demonstrates that economic efficiency and service quality are not opposing goals. When capacity is properly planned, service levels (SLAs) remain stable even on the most demanding days, while operational costs are sustainably optimized.

For banking customers—who are often managing critical financial moments during these seasonal peaks—the difference is clear: shorter waiting times, more agile service, and an experience aligned with expectations.

MST has proven that it is possible to build a flexible, efficient, and sustainable banking operations model. The calendar figure is not a temporary fix. It is a planned competitive advantage.

www.mstholding.com

The SAC Law in the Financial Sector: Understanding the Nuance That Changes Everything

The entry into force of the new Customer Service Law (SAC Law) has opened a new chapter in the relationship between companies and their customers. However, in the financial sector, its impact cannot be interpreted in the same way as in other industries.

And that is precisely where much of the confusion begins.

While in other sectors the SAC Law acts as the main regulatory framework, in financial services its role is different. More technical, more constrained, and above all, more dependent on the existing regulatory environment. For this reason, the key lies not so much in what the law says, but in how it should be interpreted within this specific sector.

A Law That Does Not Replace, but Complements

The first point that needs to be clarified is that the SAC Law is not the primary regulation in the financial sector. Its role is supplementary.

This means that sector-specific regulation (covering transparency, customer protection, and the functioning of complaint handling services) remains the priority. The law itself makes this clear in Article 2, where it defines its scope and establishes that sectoral regulation prevails over the general framework.

In practical terms, this means that the SAC Law only comes into play where financial regulation does not already cover a specific aspect. It does not replace what already exists; it complements it.

This nuance is critical, as it fundamentally changes how the law should be approached. The objective is not to “implement the SAC Law” as a standalone framework, but to understand how it fits into an already regulated (and highly demanding) model.

A Deeper Impact Than It May Seem

Despite its supplementary nature, the impact of the law on the financial sector is significant. This is because it does not merely complement the existing framework; it also modifies it.

Specifically, the SAC Law introduces changes to Law 44/2002, strengthening the requirements for customer service functions. This results in increased expectations around accessibility, service quality, and personalization.

For example, there is now a stronger obligation to ensure that customer service is:

  • accessible to all customer profiles
  • delivered by human agents when required
  • adapted to vulnerable groups

This is not a change in the model itself, but it clearly raises the bar in terms of execution.

The Exclusions: Understanding What Does Not Apply

One of the most relevant (and most frequently misunderstood) aspects of the law concerns the articles that do not apply to the financial sector.

The law explicitly excludes certain provisions, including Article 13.8 and Articles 18, 19, 21, 22, and 23. However, beyond simply listing them, it is essential to understand what these articles regulate and why they are excluded.

For instance, Article 22 establishes the obligation to conduct an annual external audit of the customer service quality system. While this is a key requirement in other sectors, it does not apply in financial services because such controls are already in place through sector supervisors and internal compliance frameworks.

A similar situation applies to Article 21, which regulates service quality evaluation systems, and Article 18, which requires the implementation of customer satisfaction measurement systems. In the financial sector, these mechanisms are already embedded within the operational and regulatory model.

Article 19, which promotes collaboration with consumer associations, and Article 23, which defines the general sanctioning regime, are also excluded because the financial sector already operates under its own supervisory and enforcement system, managed by institutions such as the Bank of Spain or the CNMV.

Even Article 13.8, which regulates the suspension of services when a complaint escalates to external bodies, is excluded, as these processes are already specifically defined within financial regulation.

The conclusion is clear: these aspects do not disappear; they are already covered under a different framework —and that framework remains the primary one.

What Still Applies… with an Adapted Interpretation

Alongside these exclusions, there are other provisions that do remain applicable, although always subject to sector-specific regulation.

This is the case with Article 4, which defines the general principles of customer service, stating that it must be free of charge, accessible, inclusive, and effective. It also includes Article 13 (in its applicable sections), which requires that complaints be resolved with clear, reasoned, and comprehensive responses that address all issues raised by the customer.

These provisions reinforce the model, but they do not replace it. In the financial sector, they must always be interpreted under the principle of specialization: if there is any conflict, sector-specific regulation prevails.

A Model That Was Already Strong… Now Under Greater Scrutiny

The financial sector does not start from scratch. For years, it has operated with a structured customer service model built around multiple layers.

There is a first level of service, more operational in nature and linked to branches or commercial channels. A second level, consisting of formal customer service departments responsible for handling complaints. And a third level, represented by sector supervisors.

The SAC Law does not alter this structure. What it does is reinforce it, introducing greater rigor in service quality, complaint traceability, and customer protection —particularly in cases involving vulnerable individuals.

Beyond Compliance: Operational Consistency

The real impact of the law lies not in theory, but in day-to-day operations.

Financial sector contact centers will need to evolve toward more consistent models, where quality is not measured solely through SLAs or processes, but through the consistency of the customer experience. Where personalization is no longer a differentiator, but a structural requirement. And where channels and service levels operate as a fully integrated system.

The challenge is not to add more layers, but to ensure that everything works together more effectively.

The Key Lies in Interpretation

In this context, the greatest risk is not non-compliance —it is misinterpretation.

Applying the SAC Law as a general framework can lead to duplication, inefficiencies, or even conflicts with sector-specific regulation. On the other hand, understanding its supplementary nature allows it to be integrated logically into the existing model.

An Opportunity to Raise the Bar

Beyond regulatory compliance, the SAC Law represents an opportunity to further professionalize customer service in the financial sector.

It is not just about complying —it is about doing so with judgment.

At MST, we work precisely at this intersection between regulation and operations, helping organizations translate complex regulatory frameworks into robust, efficient models aligned with real customer needs.

Because in this new scenario, the difference will not be made by those who simply know the law.

It will be made by those who know how to interpret it… and apply it with purpose.

www.mstholding.com

New Customer Service Law: how to adapt without losing operational efficiency

Keys to complying with the regulation while improving response times, experience, and cost control in the service model

The new Customer Service Law represents a significant shift in how companies must manage their relationship with customers. It is no longer just about offering a service channel, but about ensuring that this service is accessible, agile, traceable, and measurable.

In this context, many organizations are already working on adapting. However, the real challenge lies not in understanding the regulation, but in implementing it without creating operational strain or unnecessary cost increases.

Who does this new regulation apply to? Industries affected by the new Customer Service Law

The new regulation broadly impacts the business landscape. It applies to both public and private entities that provide services considered essential for citizens, regardless of their size, as well as large companies operating in the consumer market in Spain.

In the latter case, the law targets organizations with a significant structure—those exceeding 250 employees and reaching certain economic thresholds, either in annual turnover or balance sheet figures.

It is important to understand that this law does not replace existing regulations. Its application is complementary, meaning it coexists with general consumer protection laws and with sector-specific regulations. This is particularly relevant in industries such as banking or telecommunications, where specific regulatory frameworks already exist and continue to take precedence.

What is considered a service of general interest?

The scope of the law includes services that have a direct impact on citizens’ daily lives and whose continuity and quality are essential.

These include energy and water supply and distribution services, as well as different transport models—air, rail, maritime, and road. Postal services and telecommunications are also included, although in the latter case, sector-specific regulations remain predominant.

The financial sector is also within the scope of the law, although it acts in a complementary manner to existing financial regulation.

Public Administrations are also affected from a dual perspective: as service providers in a consumer relationship and as entities responsible for safeguarding consumer rights.

What really changes in customer service: requirements of the new law

The Customer Service Law introduces a set of specific measures aimed at improving efficiency, accessibility, and personalization in customer service. These requirements build on existing consumer protection regulations, raising the level of demand for companies.

Among the most relevant aspects is the obligation to always guarantee the possibility of personalized service. Automated systems cannot be the only contact channel. In addition, a clear service target is established: at least 95% of personalized service requests must be resolved within an average time of under 3 minutes.

Regarding channels, companies must offer full omnichannel service. This includes, in addition to the contracting channel, telephone support, postal service, and at least one electronic channel that enables agile interaction.

The regulation also requires service to be provided in the official languages of each autonomous community, reinforcing accessibility.

Another key point is traceability. Every query, complaint, claim, or incident must have an identifier that allows customers to track the status of their request clearly and at any time.

In terms of availability, the law differentiates depending on the type of service. For services of general interest, support must be available 24/7 throughout the year. In other cases, service must align with business hours, unless contracting is available without time restrictions, in which case support must also be continuously available.

The need to ensure accessible and inclusive service is also reinforced, including specific support measures for vulnerable groups such as the elderly or people with disabilities.

The law also requires the implementation of customer satisfaction measurement systems, as well as quality control and evaluation mechanisms, which may include external audits.

Additionally, limitations are introduced on the commercial use of service channels. Interactions related to queries, incidents, or complaints cannot be used to offer products or services unless the customer has given explicit consent. Service channels must also be clearly differentiated from commercial activities.

Regarding resolution times, the regulation establishes specific deadlines. As a general rule, requests must be resolved within a maximum of 15 working days. This is reduced to 5 working days for billing-related complaints. In cases of массов incidents, companies must respond within a maximum of 2 hours, at least in terms of informing customers about the situation.

A level of demand that requires reviewing the model

This set of measures represents a significant increase in operational requirements. It is not just about meeting specific criteria, but about ensuring that the entire service model can respond with agility, consistency, and control.

For many organizations, this implies a real transformation. Failing to act in time may not only lead to financial penalties but also to a direct impact on reputation and customer experience.

The key lies in adapting the model structurally, not incrementally. In this new context, compliance is not enough—it must be achieved efficiently.

Where inefficiencies usually lie

From MST HOLDING’s experience, these inefficiencies often have a structural origin. In many cases, the classification of interactions does not allow proper prioritization, making it difficult to route cases effectively from the outset. This is compounded by internal workflows with too many handoffs, which extend resolution times and increase operational workload.

Additionally, there is often a lack of real visibility into the cost of each interaction or case type, preventing informed decisions on where to optimize.

Adapting without increasing costs: the real approach

In this scenario, adapting to the law should not be based on adding more resources, but on deeply reviewing the operating model.

This involves rethinking how interactions are classified, how cases are assigned, and how internal workflows are managed. The goal is not to do more, but to do it better: reducing rework, simplifying processes, and improving first-contact resolution.

When approached from this perspective, it is possible to comply with the regulation while simultaneously improving efficiency.

The role of technology and the hybrid model

Technology plays a key role in this process, especially in automating tasks and improving traceability. However, the new regulatory framework makes it clear that service cannot rely solely on automated systems.

Therefore, the most effective model is one that combines intelligent automation with specialized human intervention. Technology helps organize, classify, and streamline processes, while people provide resolution capability and quality in interactions.

An opportunity beyond regulation

Although many companies are approaching this change from a compliance perspective, the Customer Service Law actually presents a clear opportunity to transform the service model.

Organizations that are using this moment to redesign their processes are not only adapting but also improving efficiency, reducing costs, and delivering a better customer experience.

How can MST HOLDING help you?

Adapting to the Customer Service Law is not just a matter of regulatory compliance—it is fundamentally an operating model challenge.

At MST HOLDING, we support organizations through this process with a comprehensive approach, combining operational expertise, technology, and business vision. Our focus is not on adding more resources, but on redesigning how interactions are managed to improve efficiency.

We work on the areas that truly impact results: refining classification to enhance prioritization, optimizing workflows to reduce handoffs and rework, and providing visibility into the real cost of each type of interaction. This enables organizations not only to meet new requirements but to do so with greater control and sustainability.

We also help integrate technology and automation in a practical way, ensuring a balanced model where operational efficiency coexists with high-quality personalized service, as required by the regulation.

The result is a more agile, traceable, and efficient service model, ready to meet SLAs without straining the structure or increasing unnecessary costs.

Because adapting to the law is mandatory.
But doing it right is what makes the difference.

www.mstholding.com

MST participates in the UNE Standardization Committee Working Group for the upcoming SAC Law Standard

The approval of the new Customer Service Law (SAC) is marking a turning point in how organizations manage their customer relationships. Beyond regulatory compliance, this law introduces a new framework that promotes service professionalization, operational transparency, and the need to measure quality in an objective way.

In this context, MST has reinforced its commitment to continuous improvement by actively participating in the forums where these new standards are being defined. As such, we are part of the UNE (Spanish Association for Standardization) Standardization Committee Working Group, promoted together with AEERC (Spanish Association of Customer Relationship Experts), which will be responsible for developing the standard that will enable auditing compliance with the SAC Law.

This working group brings together some of the leading companies in the sector, with the aim of establishing a common framework that ensures consistency, rigor, and practical applicability of the regulation. The goal is not only to define theoretical requirements, but to build a standard that can be effectively implemented in day-to-day customer service operations.

The committee plays a key role in this process: translating the principles of the law into clear, measurable, and auditable operational criteria. To achieve this, work is being carried out across three main areas that will be critical in the coming years.

First, defining the technical criteria and requirements that organizations must meet. This includes establishing the conditions that customer service operations must fulfill in terms of structure, capabilities, processes, and technology. Not all companies start from the same level of maturity, so the standard must be demanding enough to raise the bar across the sector, while remaining realistic to allow for progressive adoption.

Second, designing customer service evaluation systems. One of the sector’s longstanding challenges has been the lack of homogeneous models for measuring quality. The new standard aims to move towards more structured evaluation frameworks that combine operational indicators, customer experience metrics, and internal control mechanisms. This will enable a shift from subjective or one-off assessments to continuous and comparable evaluation systems.

Finally, the committee is defining which aspects will be subject to audit and under which metrics they will be assessed. This is particularly relevant, as it introduces an external verification component that will require organizations to objectively demonstrate the quality level of their services. Audits will no longer focus solely on formal compliance but will also incorporate elements such as operational efficiency, process traceability, and consistency in customer experience.

The new standard represents an opportunity to address existing inefficiencies from a structural perspective. It is not just about meeting SLAs or adding new service channels, but about redesigning operating models to ensure they are sustainable, measurable, and aligned with customer expectations.

Moreover, participating in this process allows us to anticipate upcoming regulatory frameworks and prepare our clients for their implementation. In an environment where regulation is evolving rapidly, the ability to anticipate becomes a key differentiator. It is not enough to react once the regulation comes into force; organizations must understand where the model is heading and adapt their operations accordingly.

Another key aspect introduced by this new scenario is the importance of certifiable quality. Organizations will not only need to deliver good service, but also demonstrate it through metrics, audits, and recognized standards. This represents a significant shift in how quality is managed, moving from an internal focus to becoming a trust factor for clients, regulators, and the market.

In this regard, the development of common standards will also contribute to greater transparency across the sector. Having homogeneous criteria will enable benchmarking, identification of best practices, and an overall improvement in customer service performance.

At MST, we believe this is the path towards a more mature and sustainable model—one where customer experience does not rely on isolated initiatives, but on solid structures, well-defined processes, and data-driven management.

We will continue working to ensure that regulation is not just an obligation, but a lever for transformation—an opportunity to drive sector professionalization, improve operational efficiency, and deliver a consistent, measurable customer experience aligned with best practices.

www.mstholding.com

The banking sector no longer debates whether to adopt Artificial Intelligence

The real challenge is doing it right and with the right partner

For years, digital transformation in banking was approached as a project. A plan with a beginning and an end. A set of technological milestones that made it possible to modernize systems, optimize processes, and gain efficiency for a reasonable period of time. Today, that logic is behind us.

Modern banking operates in a state of permanent transformation. Regulatory pressure, rising customer expectations, competition from new players, and the need to protect margins force financial institutions to continuously reassess how they operate. In this context, Artificial Intelligence has moved from being a promise to becoming a necessary condition for remaining competitive.

However, adopting AI is not enough. In fact, adopting it without clear criteria can create more problems than solutions. The real difference is no longer who adopts AI first, but who does it better— with a realistic, responsible vision and supported by the right expertise.

From technological fascination to responsible decision-making

In recent years, AI has taken center stage in speeches, presentations, and strategic plans. Predictive models, automation, intelligent assistants, advanced analytics—everything seems essential. But when these ideas are brought into real operational environments, reality proves far more demanding.

AI does not generate value on its own. It does so when applied to real processes, using reliable data, within regulated environments, and in line with the logic of the banking business. Many initiatives fail not because of a lack of technology, but because of a lack of understanding of the context in which they are deployed.

Banking does not need generic solutions or platforms designed for “any industry.” It needs a partner specialized in banking, with proprietary technology and no dependency on third parties—one capable of understanding the operational, regulatory, and commercial complexity of financial institutions and translating AI into tangible, sustainable results.

Regulatory and operational pressure as the real starting point

If there is one thing all financial institutions share today, regardless of size or business model, it is a constant sense of pressure. Regulatory pressure, operational pressure, and pressure to maintain ever-higher service levels with structures that do not always grow at the same pace.

Banking does not operate in a flexible environment. It operates within a supervised, audited, and highly regulated framework, where every process has legal, reputational, and financial implications. And paradoxically, many of these critical processes still rely heavily on manual tasks, human validations, and poorly optimized workflows.

It is in this context that Artificial Intelligence begins to play a key role—but also where many reasonable concerns arise among service buyers. Because not all AI is suitable for banking, and not all automation adds security.

From continuous work with financial institutions, it is clear that the biggest bottlenecks are often not found in core systems, but in back-office operations and cross-functional processes that connect areas, people, and decisions. Power-of-attorney validations that take longer than expected, claims that pile up without clear prioritization, low-quality fraud alerts that overwhelm teams, or mortgage files delayed due to a lack of structured information.

These inefficiencies do not only impact costs. They affect customer perception, team workloads, and operational risk. And this is where one of the greatest fears of financial institutions emerges: applying AI without losing control.

That is why today’s banking service buyers seek more than innovation. They seek certainty. The assurance that solutions comply with regulatory frameworks, integrate with existing systems, and do not create unnecessary dependencies. They look for partners who understand that, in banking, automation cannot be opaque or uncontrollable.

AI applied to the financial environment must be explainable, traceable, and governable. It must allow institutions to understand why a decision is made, how a case is prioritized, or which criteria are applied in a risk analysis. And above all, it must adapt to each institution’s internal policies—not the other way around.

Business Banking Innovation: innovation born from practice

Business Banking Innovation (BBI) emerges precisely from this reality. Not as a conventional technology unit, but as a specialized vertical designed to address the real challenges of modern banking.

BBI has been built on a deep understanding of day-to-day banking operations, shaped by the continuous work of a team with first-hand knowledge of the dynamics, requirements, and challenges financial institutions face today. This vision is led by professionals with prior experience in different roles and responsibilities within banking, enabling the design of solutions aligned with the sector’s reality—not from theory, but from years of accumulated practical experience.

This approach to innovation marks a clear difference. Solutions are not conceived in a technology lab, but from a thorough understanding of processes, bottlenecks, and real business priorities.

Proprietary technology as a strategic advantage

One of BBI’s key differentiators is the use of proprietary technology, developed specifically for the banking environment and without reliance on external vendors. This independence is not a technical detail—it is a strategic advantage.

It enables each solution to be adapted to an institution’s internal policies, integrated smoothly with legacy systems, evolved without technological lock-in, and managed with full control over data and processes. In an environment where technological sovereignty and regulatory compliance are increasingly critical, this adaptability is essential.

BBI does not offer closed products. It delivers configurable, evolving solutions aligned with the reality of each bank.

SwiftBankOps: operational efficiency with banking expertise

Within the BBI ecosystem, SwiftBankOps provides a direct response to one of banking’s biggest challenges: operational overload. For years, many administrative processes have grown in complexity without becoming smarter, consuming resources and diverting focus from core business.

SwiftBankOps enables end-to-end automation of banking processes by integrating technology, business rules, and AI into a single operational layer. The goal is not to replace people, but to free teams so they can focus on higher-value tasks.

The platform covers key processes such as account opening and closure, banking and corporate document control, arrears management, international transfers and trade finance, full probate processes, and mortgage management with a focus on post-signing customer loyalty and associated cross-selling.

All of this is delivered with full traceability, control, and alignment with each institution’s internal policies.

Automating without losing control

The value of SwiftBankOps lies not only in what it does, but in how it does it. Its modular architecture allows each process to be scaled and customized without rigidity.

Advanced OCR digitizes documentation and accurately extracts key information. Configurable business rules define validations, workflows, and exceptions based on internal criteria. Intelligent alerts anticipate incidents and deadlines, enabling proactive management.

The result is a more agile operation, fewer errors, greater control, and a more consistent and predictable customer experience.

BBI Services: AI applied to concrete problems

The evolution of BBI has led to specialized services that address highly specific challenges within the financial sector.

BBI ClaimOptimizer transforms claims management through AI applied to case classification, prioritization, and resolution, reducing claims traffic by up to 80% in a systematic, planned, and transparent way.

BBI FraudShield applies AI to early fraud pattern detection and intelligent alert analysis, strengthening security without compromising customer experience or daily operations.

BBI SmartScore improves information quality in financing processes by structuring and packaging customer data to act as an initial filter for personal loans, leasing, automotive financing, mortgages, and cards.

BBI Bastantia automates power-of-attorney and legal document validation, eliminating one of the major bottlenecks in banking back-office operations.

Choosing the right path for AI adoption

When adopting AI, many institutions face a strategic decision: develop internally, acquire generic solutions, or rely on a specialized partner. Experience shows that the latter is the most efficient option when the partner understands banking and provides proprietary technology.

A banking-specialized partner with proprietary, third-party-independent technology accelerates AI adoption without unnecessary risk, avoids external dependencies, and ensures adaptation to each institution’s regulatory and operational context.

BBI does not sell tools. It takes ownership of processes. It supports institutions from problem identification through daily operations, combining technology, services, and strategic vision.

AI as the invisible infrastructure of future banking

In the medium term, the real transformation AI will bring to banking will not be visible to the end customer. It will not appear as a new feature or a radical change in channels. Instead, it will become an invisible infrastructure, seamlessly integrated into internal processes, supporting daily operations without friction.

Institutions that move in this direction will not necessarily be those that talk the most about AI, but those whose processes work better quietly—resolving claims faster, managing risk more accurately, reducing operational times without losing control, and delivering a consistent customer experience over time.

In this scenario, AI ceases to be a differentiator and becomes a basic requirement. Just as no one today questions the need for robust core systems or strong regulatory controls, tomorrow intelligent, process-driven automation will simply be part of the operational standard.

That is why having a specialized banking partner with proprietary, third-party-independent technology from the outset is not only a short-term competitive advantage. It is a way to ensure that innovation becomes a solid foundation for future growth—without compromising control, quality, or trust.

A clear conclusion

Banking no longer asks whether it should adopt Artificial Intelligence. That decision has already been made. The real difference lies in how—and with whom—that journey is taken. Because AI, when applied without sector knowledge, can become a source of complexity. Applied with banking expertise, it becomes a lever for efficiency, control, and sustainable growth.

BBI represents this approach to innovation: specialization, proprietary technology, and real-world experience. Because in modern banking, innovation is not about experimentation. It is about making the right decisions.

Author: Javier Sáez – BBI Director

MST HOLDING sponsors the 5th Contact Center Congress 2026, the key meeting point for the industry

The Contact Center Congress 2026 will once again bring together the leading leaders, executives, and experts in the sector at an event that has already established itself as a benchmark within the customer service ecosystem in Spain. In this fifth edition, MST HOLDING will participate once again as a sponsoring company, reaffirming its commitment to innovation, operational excellence, and the development of sustainable, future-oriented customer relationship models.

Organized by the CEX Association and the AEERC Association, the Contact Center Congress celebrates its fifth consecutive year with a conference designed to inspire industry leaders, share best practices, and strengthen the transformation of a key sector for business competitiveness and customer experience.

An established event as a platform for knowledge and transformation

Throughout its five editions, the Contact Center Congress has proven to be much more than an industry gathering. It has become a unique platform for knowledge exchange, where trends, emerging technologies, and strategies converge to drive continuous improvement in customer service models.

The essence of the congress has remained intact since its inception: to create an open and strategic dialogue environment that encourages executives to rethink customer relationships, raise service standards, and anticipate the challenges of an increasingly demanding, digital, and regulated market.

In this context, MST HOLDING’s participation as a sponsor reinforces its positioning as a group committed to the evolution of the sector and to the creation of long-term value through well-founded strategic decisions.

Under the slogan “Caring for our Customers, Caring for our Future,” the event focuses on the importance of building close relationships, practicing genuine active listening, and designing hyper-personalized services capable of meeting the expectations of an increasingly informed and demanding customer.

This approach directly aligns with MST HOLDING’s vision, which understands the customer not merely as a recipient of services, but as the central axis of business strategy and a driver of sustainable growth.

The role of MST HOLDING in the evolution of the Contact Center ecosystem

MST HOLDING’s sponsorship of this fifth edition of the Contact Center Congress responds to a clear conviction: the future of business growth lies in excellent customer relationship management, supported by technology but always guided by a human and strategic vision.

MST HOLDING is committed to business models that integrate innovation, efficiency, and proximity, understanding that digital transformation only makes sense when it improves customer experience and generates a positive impact on organizations.

Active participation in a forum of this nature allows MST HOLDING to contribute to industry debate, share strategic vision, and learn from other key players in an environment designed to promote informed and sustainable decision-making.

A space to rethink the future of customer service

The Contact Center Congress 2026 once again presents itself as a privileged space to reflect on the future of customer service in a context marked by accelerated digitalization, artificial intelligence, and increasing regulatory complexity.

Beyond technological trends, the event emphasizes the responsibility of organizations to build trustworthy, transparent, and long-lasting relationships with their customers. This vision fully aligns with MST HOLDING’s philosophy and its commitment to responsible, long-term-oriented growth.

On February 26, 2026, Madrid will once again become the meeting point for those who understand that caring for the customer means caring for the future of organizations—a future that is built today through strategic decisions, responsible innovation, and a people-centered vision.

www.mstholding.com