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.