Customer Service in Catalan, Valencian, Basque, and Galician: What the Customer Service Law Requires from the Financial Sector

If a customer calls their bank in Basque and the agent does not understand the language, what happens? Until now, financial sector regulation required institutions to respond to written complaints in the same language in which they had been submitted. It was a limited right and relatively easy to manage. Law 10/2025 significantly expands this right, with much broader practical implications for customer service teams.

This is currently one of the areas with the highest level of interpretative ambiguity, but precisely for that reason it deserves detailed analysis: financial institutions need guidance in order to start taking action.

What Already Existed: The Right to Receive a Response in the Language of the Complaint

Sector-specific regulation already established that customers have the right to submit complaints in Spanish or in any co-official language of the territory where they reside (Catalan, Basque, Galician, or Valencian) and to receive the response in that same language. This right applied to formal written complaints managed under the regulatory framework supervised by the Bank of Spain, the CNMV, and the DGSFP.

To manage this requirement, many institutions relied on specialized teams or translation services. The volume was manageable because it was limited to a specific type of communication.

What the Customer Service Law Adds: Language Throughout the Entire Interaction

Law 10/2025 goes much further. Its approach is that linguistic criteria should not be limited to formal complaints: they must apply to the entire interaction with the Customer Service department, including phone calls, live chats, emails, messaging services, and any other communication channel.

If an institution operates in a territory with a co-official language, it must be able to assist and respond in that language whenever requested by the customer, both orally and in writing. Customer service teams must also be trained accordingly.

Articles 29 ter.2 and 29 septies.4 of the amended Law 44/2002 establish this linguistic framework. The regulation does not state that every call must be handled in a co-official language. It states that when a customer requests it, the institution must be able to respond. But that “must be able to” carries very specific organizational implications.

The Operational Challenge: People, Training, and Availability

Having agents capable of providing fluent support in Catalan, Basque, Galician, and Valencian across all shifts and all channels is not easy, especially for medium-sized institutions or national organizations whose customer service centers are located in a single site.

The market for professionals fluent in some of these languages (particularly Basque) is limited. Geographic dispersion of customers adds further complexity: an institution may simultaneously serve customers in the Basque Country, Catalonia, and Galicia, each with different language needs during the same working shift.

The law does not establish specific availability thresholds, but this does not exempt institutions from compliance. What it does require is a structural customer service model, not merely occasional solutions.

Can Technology Be the Solution?

The answer is nuanced but encouraging. The law does not rule out the use of language assistance technology or AI-powered real-time translation systems, provided that service quality is guaranteed. This opens the door to real-time support tools for agents who do not fully master the language: systems capable of transcribing and translating conversations, allowing agents to understand customers and respond coherently.

However, technology does not eliminate responsibility for service quality. If the system makes translation errors that affect the proper resolution of the request, responsibility still lies with the institution. In addition, the system must be auditable.

Callback as a Temporary Solution, Not a Structural One

If, at a specific moment, no agent is available in the requested language, offering a callback from a qualified agent may be a valid solution. But with the same limitations applicable to waiting-time KPIs: it cannot become the standard approach. The institution must be able to demonstrate that it has a structural model for providing support in co-official languages, and that callbacks are only used exceptionally.

The Risk of Inaction

Co-official languages are considered a high-priority issue by Consumer Protection Authorities, especially in Catalonia, the Basque Country, and Galicia. The likelihood of receiving a complaint or undergoing an inspection in this area is higher than for many other regulatory requirements, partly because it is a right that citizens know and value, and partly because it is relatively easy for inspectors to verify whether an institution can provide service in a co-official language.

Institutions operating in these territories should include this issue in their compliance risk map and develop an action plan supported by documented evidence: who provides support in each language, what training agents have received, how demand is managed when immediate availability is not possible, and what technology is used as support.

Consulting C3 and MST Holding actively participate in the UNE Committee responsible for defining the audit standard for the Customer Service Law and maintain ongoing contact with the AERC to communicate the sector’s concerns to the organizations responsible for clarifying them.

MST and Costa Cruises Awarded for Their Employee Experience Strategy

Recognition for Our Approach to Employee Experience

At MST, we are celebrating. Together with our client Costa Cruises, we have won the award for Best Employee Experience Strategy in Contact Center at the 17th edition of the Platinum Customer Experience Awards.

This recognition fills us with pride because it validates a principle we strongly believe in: to deliver an outstanding customer experience, we must first take care of the people who make it possible every day.

In an environment as demanding as the Contact Center industry, people are the true driving force behind service excellence. That is why, together with Costa Cruises, we have developed an Employee Experience strategy focused on employee well-being, motivation, professional development, communication, and recognition.

People at the Heart of Our Strategy

This award recognizes a way of working built on listening, continuous improvement, and shared commitment. We have implemented initiatives designed to create a more positive, collaborative, and goal-oriented work environment.

Behind this project lies a comprehensive approach that includes training, coaching, close leadership, management tools, engagement initiatives, and a strong team culture that supports continuous growth.

We firmly believe that when professionals feel supported, valued, and empowered, they are able to deliver their very best in every customer interaction. This directly translates into an enhanced Customer Experience.

Employee Experience and Customer Experience: Two Paths Moving Forward Together

For us, Employee Experience and Customer Experience are deeply interconnected. One cannot exist without the other.

A motivated, well-trained, and engaged team is better equipped to create more meaningful conversations, effectively address customer needs, and build stronger relationships based on trust.

This recognition, achieved together with Costa Cruises, confirms that investing in people not only improves the workplace environment but also drives service quality, operational efficiency, and business results.

An Award Shared with the Entire Team

This Platinum Customer Experience Award is, above all, a recognition of the people who make this project possible every day.

To all the teams involved in delivering the Costa Cruises service, thank you for your dedication, positive attitude, and ability to turn every challenge into an opportunity for improvement.

As our CEO states:

“This award recognizes much more than a strategy. It recognizes the hard work, passion, and commitment of the people who make our project possible every day. At MST, we are convinced that taking care of our teams is the best way to take care of our customers. We proudly share this recognition with Costa Cruises and with all the professionals who have contributed to making it possible.”

Moving Forward

Winning this award motivates us to continue working with the same enthusiasm and sense of responsibility. We understand that Employee Experience is constantly evolving, just as customer expectations continue to change.

For this reason, we will continue to invest in innovation, active listening, training, employee well-being, and continuous improvement as the foundations for building workplaces where people can grow, create value, and feel part of something meaningful.

At MST, we would like to thank Costa Cruises for their trust and for sharing our vision of a people-centered customer experience.

This recognition reinforces our commitment to a way of working where Employee Experience, Customer Experience, and Operational Excellence advance together.

www.mstholding.com

Resolution Deadlines for Complaints: The Financial Sector Moves from Two Months to One

If there is one aspect of Law 10/2025 that will directly impact the day-to-day operations of customer service teams in the financial sector, it is the new framework for complaint resolution deadlines. The maximum response time is reduced from two months to one. Half the time to resolve complaints, while maintaining the same quality standards in responses and with the obligation to document everything. For many institutions, this is not a minor adjustment: it is a complete process redesign.

However, there are important nuances. The Customer Service Law (Ley SAC) does not establish a single deadline for all complaints in the financial sector. Instead, it introduces a distinction by type of service, requiring each complaint to be classified from the very moment it is registered.

The New Deadline Framework

Once the law comes into force, financial institutions must manage complaints according to the following differentiated structure:

• General complaints: maximum of 1 month from the formal submission of the complaint until the reasoned response is communicated to the customer. This specific deadline applies to the financial sector under sector-specific regulations, which take precedence over the general Customer Service Law. For all other sectors, the general deadline remains 15 business days.

• Payment services (payments, transfers, cards): maximum of 15 days. The shorter deadline already established under PSD2 remains in place. In this case, sector-specific regulation is stricter, not more flexible.

Previous regulation treated complaints in a generic manner, with a single two-month deadline for all cases. The Customer Service Law breaks this uniformity and introduces the need to classify and categorize each complaint according to the nature of the service involved. This has a direct impact on management systems, workflows, and agent training.

Why Accurate Classification from the First Contact Is Essential

If the deadline for a complaint related to a bank transfer is 15 days, while a complaint regarding a life insurance product allows one month, the system must identify the type of complaint from the very first registration and activate the correct deadline counter. Without this automatic or guided classification, the risk of non-compliance increases significantly, especially during periods of high volume.

This requires reviewing intake forms, categorization systems, escalation workflows, and automatic alerts for the teams responsible for each type of complaint. An issue related to an unauthorized card charge cannot be managed under the same deadline structure as a complaint concerning mortgage conditions.

Correct classification from the start provides another key advantage: prioritization. In high-volume environments, understanding that some complaints must be resolved within 15 days while others allow one month enables a far more efficient distribution of workload.

The Real Impact on Internal Processes

Cutting resolution times in half without reducing response quality requires identifying the real operational bottlenecks. Based on Consulting C3’s experience working with financial institutions, the most common issues are:

• The number of internal escalations required to resolve a complaint, as each escalation adds delays.

• Dependence on other departments (product, risk, legal) to obtain the necessary information. If these departments do not operate under internal SLAs aligned with the new regulatory deadline, the Customer Service department will not be able to comply.

• Agents’ ability to draft high-quality reasoned responses without always depending on higher-level validation.

• Internal approval times for responses, especially in complex or high-value complaints.

Evidence and Documentation: What Regulators Will Require

Compliance alone is not enough: institutions must also be able to prove it. Companies must maintain clear records of the exact time each complaint was received, its classification, the applicable deadline, and the date on which the response was communicated. This documentary traceability is what protects institutions during inspections or in the event of direct customer claims.

One particularly sensitive point is the starting moment of the deadline. The law establishes that the countdown begins from the formal submission of the complaint. Does the customer receive an automatic acknowledgment with date and time? Does that acknowledgment specify the applicable maximum response time? These are questions that must already be answered before the regulation comes into force.

What Financial Institutions Should Be Doing Now

• Review the current complaint management process and identify where the greatest delays occur.

• Implement an automatic or guided complaint classification system by service type, activating the corresponding deadline from the first registration.

• Align the internal SLAs of support departments (product, risk, legal) with the new one-month regulatory deadline.

• Ensure customers receive an automatic acknowledgment including the start date and maximum response deadline.

• Review alert systems so teams are notified when a complaint is approaching its deadline.

The shift from two months to one is not impossible to manage, but it requires a deliberate redesign of processes. It is not enough to do the same work in less time: it must be done differently.

www.mstholding.com

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.

www.mstholding.com

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

Exit mobile version