At MST, we have spent three decades in this industry. We have seen fax, CRM, live chat, WhatsApp Business… and with every wave, someone said, “This time, it really will change everything.” With artificial intelligence, for the first time, we have to agree. But not for the reasons most people think.

AI is not replacing the contact center. It is forcing it to rethink itself from the ground up. And for those of us working in customer service, that is far more interesting news than “robots are going to take our jobs.”

What the numbers tell us (and what they don’t)

Let’s start with the data, because there is plenty of talk about AI in this industry, but far less scrutiny.

In Spain, the contact center industry generated €2.025 billion in revenue, up 0.94% on the previous year, according to the CEX Association’s 2025 Market Study. That figure is interesting in itself, but another catches our attention even more: technology investment as a share of company costs rose by seven percentage points to 68%. Companies are not talking about AI simply because it is fashionable; they are committing real budgets to it.

And where is that investment going? According to the same study, robotic process automation (RPA) and artificial intelligence have already been implemented in 89% of CEX member companies. That is a remarkably high figure, and it confirms something we repeat in every meeting with our clients at MST: AI is no longer a pilot project tucked away in an innovation department. It is core infrastructure for the modern contact center.

At the national level, a 2026 AWS study indicates that 61% of Spanish companies have already implemented an AI solution, eleven percentage points more than the previous year. According to the report, Spain is seven percentage points above the European average for adoption.

So far, it all sounds very promising. And this is where, with 30 years of experience behind us, we need to hit the brakes for a moment.

The figure hardly anyone mentions: investing is not the same as getting results

A recent study reported by MuyCanal, examining more than $250 billion in global AI investment in 2025, reveals that only a quarter of companies say they have achieved a significant business impact from that investment. It bears repeating: three out of four companies invested in AI without seeing a meaningful impact.

Why does this happen? Because many companies treat AI as a patch added to existing processes, rather than redesigning those processes from scratch around how AI and people will work together. In a contact center, that distinction makes all the difference. There is no point putting a chatbot in front of a poorly designed process: all you achieve is automating customer frustration, not eliminating it.

This is exactly what we keep saying at MST: technology does not fix a bad process; it amplifies it. Before automating, you need to truly understand the customer journey.

From trend to strategic decision

What is genuinely changing in 2026 is the role of conversational AI within organizations. It is no longer solely the responsibility of the innovation department: it has become a leadership decision, with a direct impact on customer experience, operations and business results, according to PwC’s 2025 Contact Center Trends Study, published by FUNDAE.

The difference between companies that benefit from AI and those that do not is no longer whether they have a bot. It is whether that technology is part of a coherent conversational architecture: one where voice, WhatsApp, web chat and social media stop operating in silos and start sharing customer history and context in real time.

For us, that is the real revolution. It is not that a machine can speak like a person. It is that customers finally no longer have to repeat their problem three times across three different channels.

Will AI replace human agents?

This is the question we are asked most often, and the short answer is: not in the way most people fear.

What is happening is a real redesign of the agent’s role. AI is increasingly handling repetitive, low-value tasks first: balance inquiries, appointment changes and frequently asked questions. This frees human agents to focus on what truly requires judgment, empathy and decision-making: complex interactions, sensitive complaints and customers who need to feel truly heard.

Gartner predicts that by 2029, agentic AI could autonomously resolve up to 80% of routine customer service inquiries. This deserves to be stated clearly: it is a forecast, not an established fact, and as with any prediction looking several years ahead, we treat it with some caution.

What is already clear today is that the model delivering results is a hybrid one: AI for volume and repetition, people for judgment and emotional connection. Neither entirely human nor fully automated.

How to avoid becoming part of the 75% that sees no results

With all of this in mind, at MST we sum up our recommendations in four principles:

• Start with the process, not the tool. Map the actual customer journey before deciding what to automate.
• Measure from day one. Track first-contact resolution, waiting times and customer satisfaction, not just cost savings.
• Train your people for their new role. Agents handling complex complaints today need different tools and training from those they needed five years ago.
• Do not buy technology out of fear of falling behind. According to several recent studies, technology FOMO is one of the main reasons AI investment fails to generate a return.

A final thought

Thirty years in this industry have taught us one thing: technology trends come and go, but what endures is the quality of the conversation between a company and its customers. AI does not change that fundamental truth. What it does is force us to decide, far more clearly than before, which parts of that conversation are worth automating and which unquestionably need to remain human.

*Note: All figures are verifiable as of this article’s publication date (September 2026).

www.mstholding.com

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.

www.mstholding.com

The date is already marked on the calendar, and this year we are looking forward to it more than ever. MST HOLDING will once again be taking part in Expo Relación Cliente 2026, Spain’s leading customer experience event, taking place on 7 and 8 October at Kinépolis Ciudad de la Imagen in Madrid. And, as always, we will be bringing plenty of new developments with us.

If you have been following our journey, you already know that standing still is not really our thing. So get ready, because this article will tell you everything you need to know about our participation: where to find us, what you will discover at our stand, and why this year’s edition promises to be different from all the previous ones.

An event that sets the pace for the industry

For years, Expo Relación Cliente has been one of Spain’s leading events for everything related to customer experience and the contact center industry. Each edition brings together leading companies, brands and professionals to share trends, technology and real success stories.

This year’s edition comes with a highly relevant theme focused on how artificial intelligence is rewriting the rules of the relationship between brands and people. Artificial intelligence in customer service is no longer a promise for the future: it is already transforming, here and now, the way companies communicate with their customers.

For us, this is nothing new. We have been working for some time to ensure that technology serves people, not the other way around. And at Expo Relación Cliente 2026, we will be showing exactly what that means.

What everyone will be talking about this year: AI, data and people

If there is one topic set to define this year’s event, it is the conversation around artificial intelligence applied to customer experience. Not as a passing trend, but as a real tool that is already changing very specific aspects of customer service: how issues are resolved, how quickly customers receive a response, and how companies can anticipate their needs before they even express them.

But there is something we firmly believe, and something you will also be able to see at our stand: technology alone does not solve anything. AI works when it is supported by well-designed processes, well-trained teams and a clear strategy for continuous improvement. This is precisely where our consulting pillar comes into play, ensuring that every technological advance translates into better service, rather than simply more automation.

Find us at Stand 48

Our participation in Expo Relación Cliente 2026 will also be an opportunity to share our vision of where the industry is heading.

Throughout the two-day event, the MST HOLDING team will be at Stand 48, a space designed to meet with clients, partners and professionals interested in discovering how we are addressing the new challenges facing customer experience.

In addition, Jessica Barceló, CEO of MST HOLDING, will be attending this year’s event, joining the team and sharing our vision of how an industry undergoing one of the most significant transformations in recent years is evolving.

As co-sponsors of Expo Relación Cliente 2026, we want to once again play an active role in this space for conversation, knowledge sharing and innovation.

Because events such as ExpoRC are not just about discovering new technologies. They are also an opportunity to share real experiences, listen to different perspectives and, above all, talk about the challenges that organisations need to solve today.

More than three decades listening to customers

We have been working in this industry for more than 33 years, and if there is one thing that has remained unchanged throughout that time, it is the way we understand our business: the customer always comes first. What has changed — and significantly — is the technology we use to make that possible.

This consistency and our commitment to doing things well have earned us recognition that makes us extremely proud, including being recently recognised as one of the leading contact centers in the industry. But what truly motivates us is not the awards themselves; it is continuing to improve the experience we deliver every single day.

Would you like to join us at Expo Relación Cliente 2026?

If you want to discover first-hand the trends transforming customer experience, learn about the latest developments in the industry and meet the MST HOLDING team, you can register for Expo Relación Cliente 2026 through this link: https://ifaes.credoffice.net/vCongress/landingForm?eid=7&atid=22&puid=de6aa444-8495-488f-b678-0a11243c7d5f&pid=147&lg=es

Book your place and come and visit us.

7–8 October 2026 | Kinépolis Ciudad de la Imagen, Madrid | Stand 48

See you at ExpoRC26.

www.mstholding.com

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.

www.mstholding.com

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.

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