Ley 10/2025: from mandatory cost to competitive advantage
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Almost every conversation about Spain’s Ley 10/2025 starts in the same place: how much it will cost. It is a fair question and it has an answer (the deadlines, mandatory channels and annual audit are detailed in exactly what Ley 10/2025 requires), but it is the small question.
The big one is this: you have just been handed, by law, the budget and the mandate to rebuild your customer service before 28 December 2026. Under normal conditions, a project like that takes years to get approved. And you will not reopen it for the next five.
What you choose to build in that window is what separates the companies that will spend the money on compliance from those that will spend the same money on compliance and come out with an advantage.
Why does compliance alone give you no advantage?
Because compliance is a floor, not a ceiling. Every company in your sector that falls within the law’s scope will reach exactly the same standard, on the same date, backed by the same ENAC-accredited audit. A floor everyone stands on sets no one apart.
The risk is not failing to comply: it is complying badly. Gartner found that nearly half the time, the desired results from new customer service technology do not materialise. The fastest way to end up in that half is to buy against a list of legal requirements instead of a redesign of the experience: you cut waiting times, you pass the audit, and the customer is just as fed up as before.
And the spending is coming anyway. Gartner also predicts that more than half of customer service organisations will double their technology spend by 2028. The question is not whether you will invest. It is what you will invest in.
What does the law force you to build?
This is the part almost nobody is looking at. Every requirement in Ley 10/2025 forces you to set up a piece of infrastructure that, once in place, helps you sell.
| Legal requirement | Asset you keep |
|---|---|
| A reference code per case, with trackable status | A unified history per customer, the foundation of any personalisation |
| Support on the channel where the contract was signed | True omnichannel: one case, one identifier, one thread |
| Ban on machine-only customer service | AI with escalation to a person: automation that does not burn customers |
| 24/7 for continuity incidents | The ability to always respond, including out of hours |
| Annual evaluation with objective indicators and an audit | Per-conversation measurement: the step before attributing revenue |
Seen this way, the project changes nature. You are not building a faster complaints center: you are laying the wiring conversational commerce needs (history, a continuous channel, automation with a safety net and per-conversation measurement). It is the same infrastructure. The law just makes you pay for it sooner.
Where is the return?
In two different places, and it pays not to mix them up, because each one is defended before the leadership team with different arguments.
The cost to serve goes down. The law’s most expensive deadline is the phone one: 95% of calls answered in under three minutes, on average. Sustaining that with people working a queue is the fastest-growing cost line, because you have to staff for the peak and pay for it all year round. Every conversation resolved on an asynchronous channel the customer already uses, or answered by a voice agent on the first ring, is a call that never enters that queue.
Revenue per conversation goes up. A support channel with full history, and with a person on the other end at the moment the customer has a question, is literally the point of peak customer attention. WhatsApp has a 98% open rate compared with the typical 20-25% for email, and in abandoned cart recovery our ecommerce customers see around 23%, compared with the usual 5-10% by email. Customer service stops being a cost center and becomes a commercial surface: not by selling during a complaint, which would be the worst possible mistake, but by being available where the customer already is.
What about people?
The lazy reading of this law is “we need more people on the phones”. The correct reading is that the law bans automation without a human way out, not automation itself.
That distinction has headcount consequences. 91% of customer service leaders are under pressure to implement AI in 2026, and the temptation is to use it to cut staff. Under this law, the use that pays off is the opposite: AI absorbs the repetitive volume (order status, duplicate invoices, appointments, cancellations) and frees people for the cases that need judgement, which are exactly the ones that decide whether the customer stays.
The team does not shrink: it moves up the value chain. And along the way you meet the guaranteed human interaction requirement with people who have the time to do it well.
How do you deliver it without paying for the project twice?
The most expensive scheduling mistake would be treating this as two projects: one for compliance now and another for customer experience in 2028. The compliance budget would go on tools chosen against a legal checklist, and two years later they would have to be replaced.
It is a single project, and the selection criterion is that the platform serves both agendas at once. In practice, that means:
- A case that survives a change of channel. If the identifier breaks when the customer moves from WhatsApp to the phone, you do not comply with the law and you have no history to make use of either.
- Automation with handover to a person in the same thread, with orders, previous conversations and CRM data in front of them. Without it, mandatory escalation turns into repeating everything from scratch.
- Measurement per conversation, not just per SLA. The law’s indicators are a subset of what you need: if you measure times but not outcomes, you have an audit but not a business.
- Data residency and documented retention, because records are kept for five years and your DPO will ask where.
Where Spoki fits
Spoki is a Customer Engagement Management platform built on Meta’s official WhatsApp Business API, with AI, voice, SMS and email in a single inbox, which, not by chance, is the shape of the list above.
AI agents handle the repetitive volume and hand over to a person in the same thread when needed. Spoki Voice covers the phone side, which is the expensive SLA, and 24/7 availability. Every conversation carries an identifier, timestamp, channel, agent and status, and with WhatsApp CRM and more than 100 native integrations the case also lives in your system of record. We are an official Meta Tech Partner with EU data residency.
And as we say in the other article: Spoki does not give you the postal channel, does not replace a phone line staffed by people and does not carry out your ENAC audit. What it does is make sure the project the law forces you to pay for leaves you with more than a certificate. See customer care solutions.
Three decisions before you sign off the project
- Who owns it. If customer service leads the project alone, you will get a compliance project. The 2-hour and 5-day deadlines belong to operations and billing, and the return belongs to marketing and sales: the leadership team has to be in the room from the start.
- Which metrics get approved. On top of the indicators the law requires, set two business metrics (cost per resolved conversation and conversion per conversation) and measure them from day one. Without a baseline, in December 2027 nobody will be able to say whether it worked.
- What gets automated and what does not. Decide it explicitly and in writing, before you buy. That is what separates “AI that helps” from “AI the customer dodges by asking to speak to a person”.
Frequently asked questions
Is Ley 10/2025 just a cost, or can it deliver a return?
It is a mandatory cost that leaves reusable infrastructure behind. The requirements for a unique identifier per case, support on the channel used to sign the contract, escalation to a person and measurement with objective indicators are the same building blocks any customer experience and conversational commerce strategy needs. The return shows up on two fronts: a lower cost to serve by shifting volume away from the phone channel, and higher revenue per conversation by serving customers where they already are.
Does complying with the law set me apart from my competitors?
Not on its own. Every company within scope will reach the same standard on the same date, so compliance is a shared floor. Differentiation comes from what you build on top of it during the same project.
Can I use AI to cut headcount and comply with the law at the same time?
The law prohibits using automated systems as the only channel and requires direct human interaction to be guaranteed at the customer’s request, so aggressive headcount cuts clash with that requirement. The approach that works is reallocation: AI absorbs the repetitive volume and people focus on the cases that require judgement.
How much time is left to make the most of this window?
The adaptation period ends on 28 December 2026. To get there with room for the audit, platform decisions should be made during autumn 2026. The full detail of deadlines and obligations is in what Ley 10/2025 requires.
The window closes in December
There are two ways to spend this budget. One ends with a certificate in a drawer. The other ends with the same audit passed, plus a unified customer history, a continuous channel, automation that does not scare anyone away and per-conversation data.
They cost practically the same, and you only get to decide once.
The phone requirement (95% of calls answered in under three minutes) is the one that will take the biggest share of the budget and the one fewest people have calculated. If you want to hear what an AI voice agent covering it sounds like before deciding anything, download the Spoki Voice playbook below and request a demo call: the agent calls you.
Sources
- Ley 10/2025, de 26 de diciembre, por la que se regulan los servicios de atención a la clientela, consolidated text: BOE-A-2025-26698
- Gartner: over 50% of customer service organizations will double their technology spend by 2028 (31 March 2026)
- Gartner: nearly half the time, desired results from new customer service technology don’t materialize (8 July 2025)
- Gartner: 91% of customer service leaders are under pressure to implement AI in 2026 (18 February 2026)
WhatsApp performance figures (98% open rate, ~23% cart recovery) are average metrics across Spoki’s customer base and vary by sector and use case.
This article is for information purposes only and does not constitute legal or financial advice.
Last updated: 29 September 2026.
