Answers to the questions that arise most often, with the article cited alongside wherever the answer follows from a rule.
Questions and answers
We serve Spanish customers from Portugal. Does Spanish law apply to us?
Very likely. Ley 10/2025 of 26 December applies to undertakings established in Spain or in another State, provided they operate in Spanish territory. It covers providers of services of general interest and all large undertakings — 250 or more employees, turnover above €50 million or a balance sheet above €43 million. It has been fully enforceable since 28 December 2026 and its waiting-time and human-attention requirements are markedly more demanding than the Portuguese ones.
Ley 10/2025 (Spain)
Our customer service is outsourced. Who is responsible?
The undertaking that offers the service to the consumer. Outsourcing distributes execution, not liability to the consumer, without prejudice to any allocation of liability agreed between the parties. Where personal data is processed, the outsourcing provider is generally a processor and a contract under article 28 of the General Data Protection Regulation is required.
Article 28 of Regulation (EU) 2016/679
When does the sixty-second period start running?
In Portugal, from the moment the caller selects the option for contact with a professional in the menu, not from the moment the call is connected. Where there is no menu, it runs from connection. The rule is in article 6(2) and (3) of Decree-Law 134/2009 of 2 June.
Article 6(2) and (3) of Decree-Law 134/2009
How many regimes apply to a contact centre?
Six, and they do not cross-refer. The national customer service regime, where one exists; the rules on the cost of consumer contact lines; consumer law as it applies to service and to distance contracting; data protection, as regards recording, logging and unsolicited communications; accessibility of support services; and transparency of automated interaction systems. Each layer has its own instrument, its own timetable and its own authority, and none of them refers to the others.
What does it take to demonstrate that we comply?
Evidence organised by obligation. Complying and being able to show that you comply are different things, and before an authority or a contracting party only the second one counts. The practice that solves it is easy to state and laborious to execute: for each applicable obligation, identify the document, record or measurement that demonstrates it, check whether it exists, produce what is missing, and name who keeps it current. That matrix, not good intentions, is what gets produced in an inspection.
Your question is not here
Put it directly. Recurring questions are added to this page.