Customer Service Act: Key Aspects and Implications for Financial Institutions
Act 10/2025 of 26 December on Customer Service introduces a reference regulatory framework that strengthens consumer and user protection standards in Spain, with a direct and significant impact on the financial sector. Among its most relevant implications is the extension of the subjective scope of Act 44/2002, which broadens the obligation to have a Customer Service Department to new entities —including payment institutions, management companies of collective investment undertakings, insurance brokers, real estate lenders and credit intermediaries— as well as the incorporation of enhanced requirements relating to accessibility, free‑of‑charge service provision, support for vulnerable persons and functional separation from commercial areas.
Entities subject to the Act have a 12‑month adaptation period from its entry into force —expiring on 28 December 2026— to adjust their internal structures, customer service channels, complaints‑handling procedures and transparency obligations to the requirements of the Customer Service Act. In this context, specialised legal advice is essential to ensure full regulatory compliance, minimise supervisory risk and anticipate the implications arising from the future establishment of the Financial Customer Protection Authority.
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