After a long period in which consumer rules operated in a fragmented, scattered way, the recent approval of Law 10/2025, of 26 December, regulating customer-service functions (LSAC), marks a paradigm shift in how providers of essential services relate to their customers. Customer service ceases to be conceived as a mere administrative channel and becomes a determining parameter of service quality.
This approach is particularly relevant in the energy sector, as basic services of general interest. Here, the LSAC fits into an already consolidated sector framework, led by Law 24/2013, of 26 December, on the Electricity Sector (LSE) and Royal Decree 1955/2000, of 1 December, regulating the transmission, distribution, retail, supply and authorisation procedures for electricity installations (RD 1955/2000), creating a much more complex legal regime that requires both electricity distributors and retailers to comprehensively adapt their operational processes for handling and managing queries, complaints, claims and incidents.
The LSAC sets an adaptation period of twelve months from its entry into force (28 December 2025) and expressly enshrines the principle of speciality, so that the electricity-sector rules will continue to apply on a preferential basis in those aspects specifically regulated therein.
Scope: obliged parties and protected parties
The LSAC applies mandatorily to all companies providing basic services of general interest, regardless of their size. It expressly includes the supply and distribution of electricity, thereby placing electricity retailers and distributors within its subjective scope.
The rule does, however, provide for a more flexible regime for smaller cooperatives and specific exemptions for small retailers that meet certain size requirements (not qualifying as a large company) and have a market share below 5%.
From the perspective of the protected parties, the LSAC adopts a broad notion of “customer”, which is not limited to the final consumer with a current contract but also includes those who have received personalised commercial offers or who are affected by incidents such as non-consented sign-ups, improper billing or continuity of supply after requesting cancellation.
Protection of the most vulnerable consumers is also reinforced, imposing enhanced obligations on accessibility, information and personalised service.
The Customer Service (SAC)
The Customer Service (SAC) is defined as the set of material and human resources that the company makes available to its customers to manage any matter related to the contracted service. This service must be effective, free of charge, inclusive, non-discriminatory, measurable and universally accessible, and clearly identified and differentiated from the company’s other activities; it may be provided directly or through third parties.
These requirements translate into the obligation to guarantee personalised, multi-channel service, allowing customers to use at least the same channel through which the contractual relationship began. In any event, service must be ensured, as a minimum, by post, telephone and electronic means.
The various service channels must be free of charge, easily accessible and universally comprehensible, and their information must appear clearly and prominently in contracts, bills and on the corporate website. In the electricity sector, these obligations are coordinated with those already provided for in the LSE, which requires distributors and retailers to make free service telephone lines and permanent services available for managing incidents related to continuity of supply.
Another of the most relevant aspects of the LSAC is the reinforcement of the customer’s right to personalised service, provided by a human operator with appropriate training in the sector. Automated systems, such as answering machines or chatbots, cannot be the sole means of service and must always offer the possibility of reaching a human operator.
The law also strengthens customers’ linguistic rights, an aspect especially relevant for companies operating in autonomous communities with their own official language. In these cases, the handling, processing and resolution of queries, complaints, claims and incidents must be carried out in the language in which the customer began the communication, both in oral and written interactions.
In telephone service, the LSAC introduces particularly demanding quality standards, notably the so-called 95/3 rule, under which 95% of calls must be answered by a human operator within less than three minutes.
To this are added other relevant obligations, such as the prohibition on cutting off communications owing to long waiting times, the customer’s right to request transfer to a supervisor during the same call, the prohibition on diverting calls to premium-rate numbers, the limitation of the call cost to a basic rate, and 24-hour, 365-day availability for incidents relating to the continuity of electricity supply.
Handling and resolution of queries, complaints, claims and incidents
The LSAC introduces a strengthened regime on handling and resolution deadlines, which in the energy sector must be interpreted systematically alongside the electricity-sector rules set out in Royal Decree 1955/2000.
As a general rule, queries, complaints, claims and incidents submitted by customers must be the subject of an express, reasoned and complete resolution within a maximum of fifteen working days from submission, with generic or standardised responses being expressly prohibited.
In particular, claims relating to billing or improper charges are subject to a resolution period of 5 working days, while queries relating to continuity of electricity supply are subject to an immediate-service regime of 2 hours. In these cases, distributors and retailers must provide the customer with sufficient information on the causes of the interruption or incident and the estimated time for restoring supply.
Likewise, in situations of mass incidents affecting a significant number of users, the LSAC reinforces the information obligation, requiring it to be provided simultaneously, in an updated and accessible manner, to all affected customers, through the company’s usual communication channels and guaranteeing, in any case, alternative formats for users who do not use digital means.
SAC evaluation, audit and control systems
The LSAC imposes the obligation to implement an annual system for evaluating the quality level of the SAC, which must be duly documented, kept for a minimum of five years and subjected to periodic audits carried out by entities accredited by ENAC, in order to verify the reliability of the measurements and ensure that the margin of error does not exceed 5%.
The results of these evaluations and their corresponding audit reports must be public and accessible through the company’s corporate website. For smaller companies, the evaluation and audit may be carried out every two years.
Penalty regime
Non-compliance with the obligations under the LSAC is generally penalised as a consumer-law infringement. However, where the same conduct is punishable under both the LSAC and the electricity-sector rules, the Electricity Sector Act applies on a preferential basis, with its penalties for serious or very serious infringements reaching amounts of up to 60 million euros, far exceeding the general limits of consumer rules.
Conclusion
The LSAC thus transforms the Customer Service from an administrative cost centre into a strategic pillar of technical quality and regulatory compliance. For electricity retailers and distributors, adapting to this new framework requires a profound rethink of operational processes, integrating personalised service, traceability and accessibility as key performance indicators (KPIs) subject to control and audit.
Beyond regulatory compliance and the mitigation of penalty risk, an effective implementation of these standards represents a real competitive opportunity in an increasingly demanding energy market, reinforcing trust, corporate reputation and customer loyalty.
