Spain's customer service law: what dealer groups must fix before 28 December

Ley 10/2025 allows AI on every call. It also requires a person within three minutes. What that means for dealer groups and importers, plus a ten-week plan to get ready.

For two years, the conversation about AI in Spanish car retail has been about speed. How fast the agent answers, how many calls it absorbs, what each contact costs. On 28 December 2026, a second question becomes a legal one: how fast can a customer reach a person?

Ley 10/2025, Spain's new customer service law, entered into force on 28 December 2025 with a twelve-month adaptation period for large companies. The law allows AI systems on the line and prohibits automated answering as the exclusive channel. It also puts a number on the human alternative: on average, 95% of calls answered within three minutes, with the same standard applied when a customer asks for a person.

Most of the coverage so far has focused on telecoms and banks, the sectors the law names directly. Dealer groups have largely assumed it is somebody else's problem. For many of them that assumption is wrong, and the deadline is ten weeks away.

This piece covers who is in scope, what the law actually says about AI, the obligations that sit beyond the phone line, and a practical plan for the weeks left.

Who is in scope, and why most dealer groups are

The law covers two groups of companies. The first is basic general-interest services, such as energy and telecoms, regardless of size. The second is any large company serving consumers in Spain, whatever it sells.

"Large" follows the standard EU thresholds: 250 or more employees, more than €50 million in turnover, or more than €43 million on the balance sheet, assessed individually or at group level. Legal summaries differ slightly on how the thresholds combine, so confirm your position with counsel. For a dealer group, it rarely changes the answer.

The turnover maths is short. A group selling 2,000 new cars a year at an average transaction price of €30,000 is already at €60 million before used cars or aftersales. Consolidated at group level, a multi-brand group with a handful of sites around Madrid or Barcelona clears the line comfortably. Spanish importers and OEM national sales companies are in scope almost by definition.

The harder question is which calls count. The law regulates customer service: queries, complaints, claims and incidents. Workshop bookings, warranty disputes and delivery delays sit squarely inside it. A first enquiry about a test drive is less clear-cut. The practical problem is that most dealers run one phone number. The voice agent or switchboard that picks up a sales enquiry at 11:00 on a Saturday also picks up the customer whose car has been in the workshop for nine days. You can't design the line for one caller and not the other, so design it to the stricter standard.

What the law actually says about AI

Read the text and the AI question is narrower than the headlines suggest. Companies can use artificial intelligence. What they can't do is make automated answering the only means of customer service.

On the phone, speaking to a trained person must be available as a menu option, and that person has to identify themselves when the call starts. If the customer is unhappy with the answer, they can ask to be transferred to a supervisor or the quality team. When that transfer can't happen within three minutes, the company may call back the same business day. Hanging up on a customer because the queue is long is prohibited.

Very little of this is aimed at modern AI. Many of the automated systems the law has in mind are IVR trees from 2009 that press-one-press-two customers into giving up. A voice agent that understands "quiero hablar con una persona" on the first attempt, and acts on it, is closer to the intent of the law than most of what it replaces.

We used to frame the risk here as AI against humans. Reading the text, the real exposure is smaller and easier to find: an AI with no exit, or an exit that ends in a voicemail. That is the configuration to hunt for in your current setup.

The three-minute rule is a staffing problem

The headline figure is 95% of calls answered within three minutes on average. The detail most teams miss is that the same standard applies to requests for personalised attention. The clock doesn't stop when the AI picks up. It starts again the moment the customer asks for a person.

That moves the pressure to a different place. In a typical Spanish dealership, the person who "takes over" is a salesperson between appointments or a service advisor at the reception desk. On a Saturday morning, or the Monday after a long weekend, neither of them is three minutes away.

The designs that work route the handoff to a shared pool of people. That can be a central BDC for the group, a brand-level contact centre run by the importer, remote product experts taking live voice or video handoffs across sites, or an external contact centre partner. What matters is that someone with context is free when the request lands. An agent who picks up with the conversation history in front of them resolves the call faster than one who opens with "how can I help you?", and that shortens the wait for the next customer in the queue.

The law also gives two groups priority on the phone channel: people aged 65 or over and people with disabilities. Your routing needs a way to recognise and prioritise them. Most dealer switchboards have nothing of the kind today.

The obligations beyond the phone line

The three-minute rule gets the attention. Four other requirements are more likely to catch a dealer group out, because nobody owns them.

• Channels. Customers must be able to raise queries and complaints through the channel they used to buy, and at minimum by phone and post plus one electronic channel. Businesses with physical premises, owned or franchised, must also accept complaints in person. That last point lands on every showroom in an OEM network.

• Languages and accessibility. Customers have the right to be served in Castilian, and in regions with a co-official language they can choose that language instead. For a group with sites in Catalonia, Valencia, Galicia or the Basque Country, an AI agent that only works in Castilian creates a gap on day one. Deaf and hard-of-hearing customers are also entitled to an accessible alternative, supplemented by instant messaging or sign-language video interpretation if they choose.

• Deadlines and records. Complaints must be resolved within 15 business days unless sector rules say otherwise, and customers are entitled to a receipt in durable form. A WhatsApp thread with no reference number and no owner will not hold up when a regional consumer authority asks for the record.

• Measurement. Large companies must evaluate the quality of their customer service every year and have an accredited external auditor verify the measurements. Both documents are published on the company website, and a customer satisfaction measurement system has to sit behind them. If your call data lives in four different tools across six sites, the audit is where you will find out.

Where AI helps you comply, and where it creates exposure

Handled well, AI is the most practical way to hit the three-minute target. It answers instantly, resolves routine requests such as opening hours or a service slot, and keeps people free for the conversations that need them. If an agent resolves six in ten routine calls, the remaining four reach people who are actually available. When every call rings a salesperson's mobile, the maths never works.

The exposure comes from four failure patterns we see repeatedly in audits of existing setups.

• The loop. The agent doesn't recognise a request for a person, or only recognises it on the third attempt. Under the new law, every repetition counts against you.

• The dead end. The handoff goes to a voicemail, an unanswered extension or a web form. Technically a human option exists. In practice nobody is there.

• The blank restart. A person picks up with no context, and the customer repeats everything. Handle time goes up, and so does the wait for everyone behind them.

• The missing record. The conversation isn't logged with a reference, so the 15-day complaint clock and the annual audit can't be evidenced.

In last week's Onlive Radar our CEO wrote about CarMax moving AI voice onto all of its inbound calls. The interesting part for Spain is the design behind it: the agent answers, and what it can't solve goes to the right associate. That is how we built Onlive. The AI qualifies the request and books the test drive or service slot, and when the buyer wants a person it hands over live on voice or video with the full conversation attached. Spain has now turned that design choice into a legal requirement.

A ten-week plan to 28 December

Ten weeks is enough if the work starts now. Here is the sequence we would follow for a multi-site group.

Weeks 1 and 2: map every entry point. List every published phone number, WhatsApp line, web chat and contact form, site by site. Note who answers each one, at which hours, and what happens after hours. Most groups find numbers they had forgotten existed.

Weeks 3 and 4: confirm scope and measure the baseline. Get a legal view on the thresholds at group level. Then pull real answer times and time-to-human from your phone system logs, split by site and by day of the week. Saturday mornings will tell you most of what you need to know.

Weeks 5 and 6: design the handoff. Add the "speak to a person" option to every phone menu. Make sure your AI agent recognises that request in Castilian and in the co-official languages you serve. Route handoffs to a staffed pool with priority rules for customers over 65 and customers with disabilities, and pass the full conversation across.

Weeks 7 and 8: fix the records. Every complaint gets a reference and a durable receipt. Set up tracking against the 15-day deadline and a single data source the external auditor can work from.

Weeks 9 and 10: test like a customer. Run mystery calls on a Saturday morning. Ask for a person in Catalan. Complain about a workshop delay and time how long it takes to reach someone who can help. Fix what breaks, then document it.

This article summarises Ley 10/2025 for planning purposes and is not legal advice. Check the obligations that apply to your group with your legal team.

From 28 December, your AI can answer every call in Spain. A person has to be three minutes behind it.