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.