From care to accreditation: The SAC Act is now in effect

On December 27, 2025, Law 10/2025 on Customer Care Services (SAC Law) was published in the Official State Gazette (BOE). This law does not redefine how customer services should be organized. It redefines something else: who assumes the risk when there is a dispute. The answer is clear: the company.

The rule introduces a silent but profound change. Faced with a complaint, an inspection or a consumer proceeding, It is no longer enough to state that one acted in accordance with the law. It must be proven. With objective evidence. With full traceability. With lasting support. And, above all, with the capacity to resist third parties. If it cannot be proven, the substance of the matter loses relevance.

In addition, if the company does not comply with this evidentiary capacity before December 28, 2026, it may face heavy fines and a loss of credibility with its customers that is difficult to quantify.

The Law does not discriminate by channel. It makes no difference whether the interaction takes place by telephone, e-mail, web, instant messaging or in person. The legislator did not want to regulate means, but legal consequences. Each query, complaint, claim or incident becomes a potentially probative fact. And as such, it must leave a verifiable record of its content, date and time. It must generate a supporting document for the consumer. And it must be kept in its entirety until the complete resolution of the file.

The pain for companies is clear. The burden of proof is on the company. It is not a doctrinal interpretation or a self-serving reading. It is an express obligation. From now on, when something is wrong, it is not discussed who is right. It is examined who can prove it.

The impact is immediate in sectors with high regulatory and litigation exposure. Telecommunications, energy, water, transportation and postal services. already operate under constant supervision. But the scope is not limited to traditionally regulated sectors. The Act also applies to large B2C companies by volume, regardless of their activity. In banking and insurance, sector-specific regulations continue to take precedence, but the standard of proof is not relaxed. It is raised. The logic is the same: more requirements, more documentation, more pressure in the pre-litigation phase.

Outsourcing the customer service does not alter this scenario. Subcontracting does not shift liability. The risk remains with the main operator. The file remains yours. And so does the proof.

Many organizations believe they are compliant because “everything is recorded in the system”. A CRM. An internal ticket. An email history. A stored recording. That approach is no longer sufficient.

A CRM is not proof. An ordinary email is not proof. A recording without certification is not proof either. They are internal records, with no technical guarantees of integrity or unalterability against third parties. They work as long as they are not challenged. The moment they are challenged, their value weakens. In consumer proceedings, they fall easily. In arbitration, too. In court, even more so.

The SAC Act does not require documentary efficiency. It requires defensible evidence. Solving this problem does not involve turning companies into digital testing specialists. It involves assuming that testing is part of the compliance infrastructure. And that infrastructure already exists in the ecosystem of trusted services.

This is where MailComms Group is positioned, as a trusted service provider qualified in certified electronic delivery and soon in signature and seal preservation (QPRES) in compliance with eIDAS. Not as a service channel provider, but as an expert in personalized omnichannel communication and provider of evidence with legal value.

Certified electronic notifications allow to certify, in an irrefutable manner, that a communication was sent, made available, received, or attempted, with full content and time stamped. Resolutions of claims. Reasoned responses. Contractual notices. Communications relevant to the file. Certified email, certified SMS, certified WhatsApp or online burofax comply with the requirement of proof on a durable medium and drastically reduce the evidentiary conflict.

The Act is not limited to individual communications. Many information obligations are fulfilled through websites, customer portals or private areas. In such cases, the certification of web publications makes it possible to prove what information was available, when it was available and under what conditions. It is not about archiving the website. It is about being able to test it when it is no longer convenient.

In this context, QPRES fulfills a precise and often misunderstood function. It is neither a general electronic archiving service nor a document preservation service with independent legal effects. Its value lies in the qualified preservation of evidence already generated. Time stamps and electronic signatures, proof of delivery and receipt. QPRES ensures that this evidence remains intact, accessible and verifiable throughout the life cycle of the file, even when the conflict is no longer operational, but legal.

Does not add new effects. It prevents existing ones from being degraded. The requirement of motivation and consistency in the resolutions adds an additional layer. It is not enough to respond. It must be possible to prove who decided, when they decided and with what content. The electronic signature and time stamping close that point. They do not improve the care process. They shield its outcome from third parties.

The change that many organizations have not yet embraced is conceptual. This is not about customer experience. It’s about legal cost. Every claim without solid evidence today is a weakness tomorrow. Every poorly documented file is unnecessary exposure. SAC 10/2025 does not sanction poor care, it sanctions the failure to demonstrate compliant care.

The standard is already in force and the adaptation period is running (until December 28, 2026). The evidentiary standard has already changed, so companies that understand now that the problem is not to communicate, but to prove, will gain margin. The others will understand this when the discussion ceases to be operational and becomes legal.

MailComms Group is not a substitute for customer service. It allows you to prove that you delivered. And from now on, that difference matters.