A customer calls to check their account balance. Another sends a WhatsApp message to change a hotel booking. Someone else wants to schedule an appointment at a car repair shop. In all three cases, it is increasingly likely that the response will come not from a person, but from a virtual assistant.

And since 2 August 2026, there is a legal obligation that many companies have yet to fully address: customers need to know when they are interacting with AI.

This requirement comes from Article 50 of the European Union’s Artificial Intelligence Act (AI Act). In our conversations with clients across different industries, we repeatedly come across the same misconceptions. Let’s debunk them one by one.

Myth 1: “I use AI to assist people, not replace them, so this doesn’t apply to me”

This is often the first assumption, and it is a mistake.

The regulation does not distinguish between “AI that replaces people” and “AI that helps provide better customer service”. What matters is one thing: if an AI system interacts directly with a customer, the customer must be informed that they are interacting with a machine, unless this is obvious from the context.

It does not matter if the chatbot only identifies the reason for the enquiry before transferring the customer to a human agent. If it interacts with the customer, it counts.

Myth 2: “The legal department can solve this by adding a clause”

Not quite.

Article 50 is not something that can be addressed simply by signing a document once and considering the matter closed. It is a requirement that needs to be embedded in the customer experience itself: in the welcome message of a voicebot, in the first message of a chat conversation, and in the way a WhatsApp assistant introduces itself.

In practice, this means reviewing scripts, conversational flows and automatically generated content, such as call summaries or semi-automated email responses, that reaches customers without making it clear that AI has been involved in producing it.

Myth 3: “If my BPO provider manages the channel, the responsibility is theirs”

It depends, and this is where many operations are caught by surprise.

The responsibility for informing customers lies with the party deploying the technology in front of the end customer. If you outsource customer service operations, this responsibility should already be clearly reflected in your contracts and SLAs with your BPO provider, rather than simply being assumed.

What Does This Look Like Across Different Industries?

Managing this requirement in banking is not the same as managing it in tourism. Here are some examples of where problems commonly arise:

• Banking: virtual assistants handling balance or transaction enquiries, where the initial AI disclosure may be buried within an options menu.
• Travel and tourism: chatbots managing bookings and travel changes, particularly during peak periods when the bot may handle the entire conversation without clearly identifying itself as AI.
• Automotive: workshop appointment assistants that often rely on legacy scripts created before this obligation existed.
• Healthcare and pharmaceuticals: bots used to schedule appointments or answer basic queries, a particularly sensitive area given the nature of the information involved.

The same pattern appears across all these industries: the technology was originally deployed to reduce waiting times, while the “I’m a virtual assistant” disclosure was treated as a minor design detail.

The Real Issue Is Not the Fine

Penalties exist, but what we see in many operational audits is a more fundamental problem: many companies do not have a clear inventory of every customer touchpoint where AI is interacting with customers.

Without that map, there is no way to guarantee compliance with the regulation, no matter how good the company’s intentions may be.

Before December Arrives

Generative AI systems that were already in operation before August 2026 have until December to adjust their technical labelling. However, this deadline should not be confused with the obligation to inform users, which is already enforceable.

There are two questions we usually ask when we begin working with an operation:

Have you mapped every touchpoint where AI interacts with your customers?

Do your contracts with BPO providers clearly define who is responsible for meeting this obligation?

If you do not have a clear answer, this is often the starting point for our CX Consulting and AI Technology projects at MST Holding: identifying where AI is being used across your operation, how this is communicated to customers, and how it is documented.

Do You Know Whether Your Operation Falls Within the Scope of Article 50?

Talk to our CX Consulting and AI Technology team and find out how to assess your customer service operation against the requirements of the EU AI Act.

It has probably happened to you before: your phone rings, you see a number you don’t recognize, you think it might be a family member or something urgent… and it turns out to be a sales call. Sometimes it’s even worse: a scam attempt. That moment of uncertainty will soon disappear in Spain, as the Government has approved a new measure that completely changes the rules for commercial calls.

What the New Regulation Actually Says

Spain’s Ministry for Digital Transformation and the Civil Service has published a resolution establishing that, from October, all commercial calls must be made from a nine-digit number beginning with the 400 prefix.

The idea is straightforward: as soon as you see a number starting with 400 on your screen, you’ll immediately know that a business is calling you for commercial purposes.

There is one important detail to understand: these numbers will be one-way only. In other words, customers will be able to receive calls from these numbers but will not be able to call them back. This is no coincidence—it is designed to reduce the risk of fraud that occurs when people return calls to unknown numbers, a common tactic used in telephone scams.

One point worth noting is that an earlier draft of the regulation, published in February, proposed making these numbers two-way. However, the final version approved in April changed this approach and established them as one-way numbers. If you’ve read otherwise elsewhere, it was most likely referring to the earlier draft.

When Will It Become Mandatory?

The new numbering range will become operational within six months of the publication of the resolution. From October 2026, telecommunications operators will begin blocking commercial calls that do not use the 400 range.

From that point onward, any commercial call made from a number other than one beginning with 400 may be blocked directly by the telecom operator, without the user having to take any action.

This measure does not come out of nowhere. It implements the Customer Service Act (Ley SAC), approved in December 2025, which already required commercial calls to use a dedicated numbering code so they could be clearly identified.

What About Customer Service Calls?

This is where some confusion often arises, so it’s worth clarifying.

The 400 prefix is exclusively for commercial calls—those made by a company to sell products or services or acquire new customers.

Customer service calls—those related to an existing contract, support request or incident—follow different rules. These may only be made from specifically assigned short numbers, the free 800 and 900 ranges, or standard geographic numbers.

This requirement was already established by the ministerial order aimed at preventing caller ID spoofing, which came into force in March 2025 and also prohibited the use of mobile numbers for this type of customer service call.

In short:

• Sales calls will come from a 400 number.
• Customer service calls will come from an 800, 900, or geographic number.
• They should never come from a standard mobile number.

Why Has the Government Introduced This Measure?

The objective is clear: to combat telephone fraud.

Digital Transformation Minister Óscar López summed it up well by saying that everyone has answered a call believing it was someone they knew, only to discover it was a commercial call.

The new numbering system forms part of a broader national strategy against telephone fraud. According to the latest official figures, since the plan was introduced in March 2025 it has enabled operators to block 192 million fraudulent calls and 17 million fraudulent SMS messages. These numbers illustrate the scale of the problem the Government is seeking to address.

What Does This Mean for Companies That Make Commercial Calls?

This is where the new regulation directly impacts contact centers, telesales teams and any organization running outbound telemarketing campaigns.

The change involves far more than simply replacing a phone number. Businesses will need to review their outbound calling infrastructure, adapt their dialing platforms and ensure that every commercial campaign is carried out exclusively using numbers within the new 400 range.

The industry has already expressed concerns. The Spanish Contact Center Association (AEERC), which represents a large part of the sector, has warned that the implementation period is shorter than originally anticipated under the Customer Service Act.

For companies operating outbound campaigns, this means a genuine technical transition: coordinating with telecommunications operators, updating automatic dialing systems and verifying that every commercial line has been correctly assigned to the new numbering range before October. The sooner this migration begins, the lower the risk of campaigns being blocked once the regulation takes effect.

What Can You Do If You Receive a Non-Compliant Commercial Call?

If, from October onward, a company calls you from a number that does not begin with 400, you may report the call to the Telecommunications User Assistance Office (OAUT) or to Spain’s National Commission on Markets and Competition (CNMC).

This provides an additional layer of consumer protection by placing responsibility on the organization making the call rather than on the person receiving it.

Conclusion

The introduction of the 400 prefix is much more than a simple numbering change. It represents another step toward a more transparent relationship between businesses and consumers while strengthening the fight against telephone fraud.

For consumers, it means being able to decide at a glance whether to answer a call.

For businesses, it means that technological and operational adaptation can no longer be postponed. October is closer than it seems.

www.mstholding.com

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

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

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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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

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 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.

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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

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