Banks, EFCs, payment institutions, EMIs, investment firms, SGIICs and insurers must have a customer service department that resolves complaints within one month (Art. 29 of Law 44/2002, as rewritten by Law 10/2025). The deadline to adapt it ends on December 28, 2026. We get it ready for the supervisor.
Does your SAC comply with Law 10/2025? Free assessment
Tell us what type of entity you are and how you handle complaints today, and we will tell you what you need to change.
Since December 28, 2025, the rules for the financial-sector SAC have been in the new Art. 29 of Law 44/2002, and several articles of Order ECO/734/2004 have been repealed. We review your service from end to end.
We check whether your entity is on the list in Art. 29 of Law 44/2002, including the entities covered by Arts. 14 and 15 of Royal Decree-law 19/2018, and compare your current SAC with the new requirements.
We update the regulations your board approves (Art. 8 of Order ECO/734/2004) to the deadlines and procedure in Arts. 29 bis–29 septies, and prepare them for verification by the supervisor.
We review your in-person, telephone and online channels: service by a real person, no answering machines as the only option, call cost and accessibility.
We design the workflow: written acknowledgment of receipt, an identification code to follow the file, correction of deficiencies within ten days, a reasoned inadmissibility decision and resolution within one month.
We place the SAC in your organization chart so that it decides autonomously, separate from the sales and operational areas, as Art. 29(3) and the Bank of Spain guide require.
We prepare the report the SAC submits to the board in the first quarter and the specialized training plan for its staff, including for serving vulnerable customers.
The obligation depends on the type of entity, not its size. These are the moments when the SAC cannot wait.
Law 10/2025 gives twelve months from its entry into force, on December 28, 2025, to adapt customer service departments.
New entities notify the supervisor of the head of their SAC, together with a report on the service, and submit their regulations for the supervisor to verify.
Entities covered by Arts. 14 and 15 of Royal Decree-law 19/2018 are also on the Art. 29 list: the simplified registration does not exempt you from having a SAC.
Before complaining to the Bank of Spain, the CNMV or the DGSFP, the customer must go through your SAC: the supervisor will see how you responded.
Data from Art. 29 et seq. of Law 44/2002 (as rewritten by Law 10/2025) and from Royal Decree-law 19/2018.
Maximum deadline to resolve the complaint or claim from the date it is filed with the entity.
Deadline for payment services; in exceptional cases, a provisional response and a final one within one month at most.
Deadline to correct deficiencies if the customer’s identity is missing or the facts are unclear; it interrupts the count of the deadline to resolve.
Deadline to notify the decision, in writing or on a durable medium and in the language of the complaint.
Maximum time for the supervisor’s complaints service if the customer pursues the matter after the SAC.
Adaptation period from the law’s entry into force on December 28, 2025.
We review your regulations, channels and deadlines and give you the list of changes in order of urgency.
Those listed in Art. 29(1) of Law 44/2002: credit institutions, financial credit establishments, payment institutions and those covered by Arts. 14 and 15 of Royal Decree-law 19/2018, electronic money institutions, SGIICs, insurance brokerage firms and insurance brokers, pension fund managers, real estate lenders that are not credit institutions, credit intermediaries operating in more than one autonomous community, financial entities under the free provision of services, insurers, investment firms and branches in Spain of foreign entities.
It rewrites Art. 29 of Law 44/2002 and adds Arts. 29 bis–29 septies with the procedure. The general deadline to resolve becomes one month; the entity must acknowledge receipt and give a code to follow the complaint; telephone or electronic service must let customers speak to a person; and the service must be free of charge, accessible and inclusive. It also repeals Arts. 6 and 9–16 of Order ECO/734/2004.
The sole transitional provision of Law 10/2025 gives twelve months from its entry into force. The law entered into force on December 28, 2025, so the deadline ends on December 28, 2026. Note: the new Art. 30 of Law 44/2002 is already in force, and the customer can go to the supervisor if they have not received a response within one month.
Yes. Art. 29(1) expressly includes the entities covered by Arts. 14 and 15 of Royal Decree-law 19/2018: payment institutions exempt by volume (up to a monthly average of €3 million) and those that provide only the account information service. Order ECO/734/2004 already included them from July 1, 2020.
Payment services are governed by Art. 69 of Royal Decree-law 19/2018: a response on paper or on another agreed durable medium within a maximum of 15 business days. If that is not possible for reasons beyond the entity’s control, a provisional response explaining the delay is sent, and the final one cannot exceed one month.
Yes. Entities in the same economic group may have a single customer service department (Art. 29(1) of Law 44/2002). The Bank of Spain guide adds that, in that case, the SAC should be located in a supervised financial entity of the group.
No. The customer ombudsman is voluntary: entities may appoint one, individually or jointly. If you have one, it must be an independent entity or expert of recognized standing, and its decisions in the customer’s favor are binding on the entity.
They can go to the complaints service of the Bank of Spain, the CNMV or the DGSFP. To do so, they must show that they complained to your SAC first and that one month has passed without a response, or that their complaint was declared inadmissible or rejected. If the SAC’s decision goes against the customer, the entity must inform them of this route and how to use it.
A well-run SAC shows in the first complaint and the first supervisory review: deadlines met, reasoned responses and traceability.
Your type of entity, your payment services and your group determine the deadlines, the supervisor and whether you can have a single SAC.
Acknowledgment, code, correction of deficiencies, reasoned decision and notification: each step with its deadline and its record.
The verified regulations, the annual report to the board and the internal audit review show that the SAC works.
Source: Law 44/2002 (Arts. 29–31, as rewritten by Law 10/2025), Royal Decree-law 19/2018 (Art. 69) and Order ECO/734/2004 (Arts. 5, 8 and 17).
These terms appear in Law 44/2002, in Order ECO/734/2004 and in any supervisory review.
Specialized department or service that handles and resolves customers’ complaints and claims.
A person of commercial and professional good repute with adequate knowledge, appointed by the board.
Independent entity or expert of recognized standing that resolves the complaints assigned to it by the regulations.
Internal rules governing the SAC and the ombudsman; approved by the board and verified by the supervisor.
Any statement about defective provision of the service or breach of the offer, regardless of how the entity classifies it.
Code assigned to each complaint and communicated to the customer so they can follow its handling.
Written confirmation, or on a durable medium, stating the content and the date and time of filing.
Mandatory step before going to the complaints service of the Bank of Spain, the CNMV or the DGSFP.
Report with statistics, decisions, criteria and recommendations, presented to the board in the first quarter.
Entity SAC: yes, for all entities in Art. 29(1).
Customer ombudsman: no: it is voluntary and complementary.
Entity SAC: the board of directors or equivalent body.
Customer ombudsman: the board, with possible ratification by the general meeting depending on the bylaws.
Entity SAC: separate from the sales and operational areas.
Customer ombudsman: external to the entity’s organization.
Entity SAC: if unfavorable, the customer can go to the supervisor.
Customer ombudsman: if favorable to the customer, it binds the entity.
Entity SAC: can be a single SAC for the whole economic group.
Customer ombudsman: can be appointed together with other entities.
These are failings that show up as soon as a sample of complaints is reviewed.
Tell us what type of entity you are, who runs your SAC today and how you receive complaints, and we will tell you what to change before December 28, 2026.
Updated October 15, 2026
Law 10/2025 of December 26, which regulates customer service departments, refers financial services to their sector-specific rules and, in particular, to Law 44/2002. Its second final provision rewrites Art. 29 of that law and adds a complete complaints and claims procedure (Arts. 29 bis–29 septies).
Credit institutions, financial credit establishments, payment institutions (including those covered by Arts. 14 and 15 of Royal Decree-law 19/2018), electronic money institutions, SGIICs, insurance brokerage firms and insurance brokers, pension fund managers, real estate lenders, credit intermediaries operating in more than one autonomous community, entities under the free provision of services, insurers, investment firms and branches of foreign entities. Entities in the same group can share a single SAC.
The service must be free of charge, effective, universally accessible, inclusive, non-discriminatory and measurable, and be provided during business hours, with round-the-clock (24-hour) service where the service concerned requires it. It must offer in-person, telephone or online channels with personalized service, cannot use answering machines as the sole means, must be separate from the sales and operational departments and needs specialized resources and training. For credit cooperatives and savings banks, the law provides for a flexible application to be established by regulation (Art. 29(6)).
The entity has one month to resolve, except in payment services, where Art. 69 of Royal Decree-law 19/2018 applies (15 business days). It must acknowledge receipt, assign a code, request correction of deficiencies within ten calendar days when data is missing, give reasons for its decision and notify it within ten calendar days. If the decision is unfavorable, it must inform the customer that they can go to the Bank of Spain, the CNMV or the DGSFP, which resolve within a maximum of 90 calendar days.
Law 10/2025 repeals Arts. 6 and 9–16 of the Order, but still in force, among others, are the requirements for the head of the SAC and for the customer ombudsman (Arts. 5 and 7), the customer protection regulations verified by the supervisor (Art. 8) and the annual report to the board (Art. 17). The Bank of Spain also applies its guide on the organization and operating criteria for SACs.
The SAC is the prior step for complaints before the CNMV and before the Bank of Spain, and one piece of the entity’s financial compliance. If you have questions about who should head it, see our page on the SAC head and the customer ombudsman.