Here’s what organisations should assess across their CRM, customer service processes and technology to prepare for compliance.
The new Spanish Customer Service Law will come into force in January 2027. For affected organisations, the challenge is no longer simply understanding what the legislation requires. It is knowing whether their current processes and systems can support those requirements — and provide evidence that they are being met.
Customer service compliance is not solely a Legal or Compliance issue. While those teams may identify the regulatory requirements, meeting them will also involve Customer Service, Operations, IT and CRM teams.
This raises an important question:
Is your CRM ready to support the requirements of Spain’s new Customer Service Law?
In this article, we look at the key technology implications of the legislation and what organisations should review ahead of January 2027.
Note: This article looks at the legislation from an operational and technology perspective. Whether your organisation falls within its scope, and which specific requirements apply, should be confirmed with your legal team.
The new Customer Service Law establishes minimum standards for customer service, with requirements covering areas such as accessibility, transparency, personalised support and the management of complaints.
Among other requirements, the legislation addresses:
For affected organisations, this has an important implication:
Customer service information needs to be traceable, accessible and demonstrable.
That makes the CRM and wider customer service technology ecosystem an important part of the compliance picture.
The legislation applies, among other cases, to certain organisations providing essential services in Spain and to companies that sell goods or services that meet specific size thresholds.
These include organisations that meet at least one of the following criteria:
The exact application of the law depends on factors such as the organisation’s activity, sector and any specific sector regulation that may apply.
The first step should therefore be to confirm with your legal team whether your organisation falls within the scope of the legislation and which requirements apply to you.
If you need to understand the legislation in more detail, you can read our previous analysis of Spain’s new Customer Service Law.
But once you know the law applies, the next question is:
What needs to change in our customer service model and technology to be ready?
There is no single “CRM that complies with the law”.
Compliance depends on how your processes are designed, what information is captured, how systems are connected and whether your organisation can control and demonstrate what happens throughout the customer service journey.
Before considering a platform change, organisations should therefore assess whether their existing technology ecosystem can support the required processes.
One of the biggest challenges will be being able to reconstruct the journey of an enquiry, complaint or claim.
Your systems should allow you to understand, at a minimum:
This requires more than simply storing customer information.
It requires a consistent interaction history linked to the relevant case or complaint.
This is where organisations with fragmented customer service models can face difficulties: calls may sit in one platform, emails in another, web forms somewhere else, while internal processes are managed manually.
If this information is not connected, reconstructing the history of a case can become difficult — particularly when evidence is required.
The legislation introduces specific requirements around the management of enquiries, complaints and claims.
From a technology perspective, this means your CRM should support the full lifecycle of a case:
Receipt → identification → classification → assignment → management → response → follow-up → resolution → closure
Each stage should be recorded and accessible.
When a complaint requires input from other departments, the system should also support coordination between Customer Service, Operations, Billing, IT and any other teams involved.
A CRM that records the initial customer contact but provides limited visibility of what happens afterwards can create a significant gap between the process you have defined and your ability to demonstrate how a complaint was actually handled.
The legislation introduces requirements relating to customer service and resolution times.
This means manually tracking response times or producing reports retrospectively may not be enough.
Your technology should allow you to:
The objective should not simply be to know how long a case took.
It should be possible to identify early when a case is at risk of missing a required timeframe.
Another important consideration is the requirement to provide customers with appropriate evidence of their interactions and complaints.
From a technology perspective, this raises some straightforward questions:
Does the system generate supporting documentation automatically?
Is it linked to the relevant case?
Can it be retrieved later?
Can you clearly demonstrate what was communicated and when?
When these processes depend on an agent manually saving an email, downloading a document or updating a record, the risk of errors and missing information increases.
Automation can help reduce this dependency on manual tasks and create a more consistent process.
This could be one of the most significant changes for many organisations.
The legislation includes requirements around customer service quality assessment and auditing. As a result, it is not enough to manage customer interactions correctly — organisations need to be able to demonstrate this through reliable data.
Your CRM and wider Customer Service ecosystem should provide visibility into areas such as:
But there is an important difference between having dashboards and having auditable information.
A dashboard might tell you that the average response time is X hours.
An audit-ready environment should allow you to understand where that figure came from, which cases were included and how it was calculated.
Before making technology changes, we recommend carrying out a structured assessment of your current operating model.
These questions are a useful starting point.
If you answer “no” or “not sure” to several of these questions, there may be gaps worth addressing before the legislation comes into force.
Identifying a gap does not necessarily mean replacing your CRM. An assessment may reveal structural limitations in the existing platform or technology architecture.
That is why we recommend a structured approach:
Work with Legal and Compliance to establish which requirements apply to your organisation.
Understand how enquiries and complaints are currently received, managed, escalated and resolved.
Identify which platforms are involved and how information moves between them.
Compare your current capabilities with what is required to meet and demonstrate compliance.
Not all gaps carry the same level of risk. Prioritise those that directly affect traceability, deadlines, evidence and auditability.
Determine what can be addressed through your existing technology, what requires integrations or process changes, and what may require longer-term investment.
The new Customer Service Law should not be treated as a technology project alone.
It requires coordination between Legal, Customer Service, Operations, IT and CRM.
Technology can make traceability easier, automate controls and provide the evidence needed to demonstrate compliance — but only when the processes and data behind it are properly designed.
That is why, before January 2027, the question should not simply be whether your CRM has the right features.
The question is whether you can demonstrate that your customer service model is working as it should.
If you do not have a clear answer yet, an audit can be a useful starting point to identify the gaps and define what needs to change before the legislation comes into force.
