The CSA Act grants companies a twelve‑month adaptation period, ending on December 28, 2026, to adjust their systems, procedures and customer service channels to the new legal requirements. Given the broad scope of application, the regulation will have a significant impact on both large companies and entities providing essential services of general interest.

Below are the main aspects of the SAC Law that must be considered to ensure its proper application and compliance.

Objectives and purpose of the “CSA” Act

The primary objective of the CSA Act is to reinforce consumer protection, ensuring that customer service is effective, accessible, inclusive, and measurable. To that end, it establishes a common legal framework of minimum quality standards, applicable across various economic sectors.

The regulation responds to the growing relevance of customer service in a context marked by digitalisation, the increase in remote commercial interactions, and the complexity of communication channels. It also seeks to harmonise existing criteria and levels of requirement across sectors, reducing prior regulatory fragmentation.

Scope of application: which companies are obliged

The CSA Act has a broad subjective scope of application. First, it applies to companies providing essential services of general interest within Spanish territory, including:

• water, gas and electricity supply and distribution;
• passenger transport (air, rail, maritime and road);
• postal services;
• electronic communications services;
• financial services.

In addition, the Law applies to companies and corporate groups that provide services or sell products primarily to consumers and users, operating in Spain and meeting at least one of the following thresholds in the preceding financial year:

(i) an average workforce of 250 or more employees;
(ii) an annual turnover exceeding 50 million euros; or
(iii) an annual total balance sheet exceeding 43 million euros.

The CSA Act is supplementary to specific sectoral regulations, which prevail where they provide an equal or higher level of protection. It also applies to public entities when acting under market conditions comparable to private companies.

General principles of customer service

Obligated companies must provide customer service that is free of charge, effective, universally accessible, inclusive and measurable. Key obligations include:

• enabling the submission of inquiries, complaints and claims, providing an identification code and proof of submission on a durable medium;
• guaranteeing a prompt and reasoned resolution, including the right to reimbursement or compensation where applicable;
• providing adapted service to vulnerable consumers, particularly persons with disabilities or over 65 years of age;
• not suspending ongoing services due to the filing of a claim, except in legally established cases;
• informing customers immediately of any incident affecting service provision.

Service channels and minimum quality parameters

The CSA Act requires that customer service be provided, at minimum, through the same channels used for contracting, in addition to postal, telephone and electronic channels. The exclusive use of automated systems or robots is expressly prohibited, ensuring that personalised assistance is provided by a physical person within a reasonable timeframe.

Consumers are also granted the right to receive assistance in the co‑official languages of their Autonomous Community, when requested.

Operating hours, accessibility and priority assistance

Customer service hours must align with the company’s business hours, regardless of whether the activity is conducted in person or electronically. For essential services of general interest provided on a continuous basis, customer service must be available 24 hours a day, every day of the year, for the communication of incidents.

Universal accessibility is a central pillar of the Law. A simple declaration of vulnerability by the consumer is sufficient to activate the applicable enhanced support measures, with no additional documentation required.

Telephone assistance and resolution deadlines

Companies must provide a telephone service at no higher cost than a standard call. If special‑rate numbers are used, a geographic or mobile alternative must be offered free of charge, along with clear information on applicable tariffs.

Regarding timelines, the general resolution period is fifteen working days, reduced to five days for billing incidents. For essential services of general interest, incidents affecting service continuity must be addressed within a maximum of two hours.

Evaluation, audit and penalty regime

The CSA Act requires the implementation of annual customer service quality assessment systems, which must be audited by accredited entities. Resulting information must be retained for five years and published on the company’s website.

Noncompliance with the Law may result in consumer protection infringements, sanctionable under the General Law for the Defence of Consumers and Users, without prejudice to any related liabilities in the area of personal data protection.

Conclusion: The importance of early adaptation

The CSA Act represents a structural change in the management of customer service, with significant organisational, technological and legal implications. Given the adaptation period and the planned penalty regime, it is advisable for affected companies to analyse the adequacy of their systems and procedures in advance, in order to ensure regulatory compliance before December 2026 and minimise legal and reputational risks.