Side by side
| Matter | Portugal | Spain |
|---|---|---|
| Waiting time | Sixty seconds to a human operator, from the menu selection | 95 % of calls answered on average in under three minutes |
| How it is expressed | A ceiling per call | A percentage over an average — a statistical obligation, measured differently |
| Human attention | One of five initial menu options must be contact with a professional | Exclusively automated service prohibited; operator available from the main menu |
| Escalation | Transfer within sixty seconds where it occurs | Right to a supervisor or quality department within three minutes |
| Response deadlines | Immediate or within three working days | Fifteen working days; two hours for continuity incidents; five days for billing |
| Connecting factor | Establishment | Territory served |
The measurement problem
The two obligations are not merely different in level; they are different in kind. The Portuguese rule is a ceiling per call, breached by any single call that exceeds it. The Spanish rule is statistical, expressed as a percentage over an average, and is breached only by the distribution as a whole.
An operation can therefore satisfy one and fail the other on the same day, and a single reporting metric cannot express both. The practical consequence is that queues serving the two markets must be measured separately, whatever their physical arrangement.
Which queue serves which market
The first thing to establish is rarely documented: which queues actually receive calls originating in Spanish territory. In consolidated operations this is frequently unclear, because routing is by language rather than by market and Spanish-language calls may originate anywhere.
Language is not the connecting factor. Territory is.
Article 24-bis of Decreto-Legge 83/2012 requires prior notification of offshoring, disclosure of the country from which the call originates, and the right to be transferred to an operator located in Italy or in the Union during the same call. It is a disclosure and choice regime rather than a quality regime — which means an operation compliant in Spain may still be exposed in Italy, on entirely different grounds.
Apply this to your operation
A general framework is no substitute for a concrete assessment. The diagnostic determines what applies to your operation.