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Customer service chatbot or assistant in Spain: related rules

Text or voice conversational assistants that serve customers on websites, apps, WhatsApp or call centers. They are already regulated: users must be told they are talking to AI and, in several countries, offered the option of reaching a person.

Risk classification

JurisdictionLevelDateNote
European UnionTransparencyAugust 2, 2026Art. 50(1): people must be told they are interacting with AI unless it is obvious.
SpainSector rulesDecember 28, 2026Customer Service Law 10/2025: large companies and basic services must allow reaching a human agent; adaptation until Dec 28, 2026.

Obligations related to this use case

Offer human service whenever the customer asks

Law 10/2025Ley 10/2025, arts. 2, 3.11, 8, 9.2 y 10.3; disposición transitoria únicaAdopted, applies later

Applies from December 28, 2026

When it relates
If you serve consumers with chatbots, voicebots or agents and you are a basic service company (utilities, telecom, passenger transport, postal, financial) or a large company. Mid-size firms above EUR 50M turnover or EUR 43M balance sheet are also covered.
What the rule provides
  • Do not use automated systems as the only service channel.
  • Allow customers to request personal service from the start and at any point in the bot conversation.
  • The person must answer in real time and identify themselves at the start; 95% of requests must be answered, on average, in under three minutes.
  • Properly train staff who design and manage automated tools.
  • In financial services sector rules apply first and this law applies as a supplement.
Typical evidence
  • Escalation-to-human protocol with target times.
  • Response-time metrics.
  • Training records for the team managing the bots.
Verification
Verified in the official source on November 2, 2026Checked in the BOE. Note: the preamble mentions six months, but the sole transitional provision sets twelve months from entry into force; the operative text prevails (Dec 28, 2026). Insurance is assumed to fall under financial services; confirm case by case.

Provider transparency: disclose AI interaction and mark synthetic content

AI ActReglamento (UE) 2024/1689, art. 50(1)-(2) y art. 111(4)In force

Applies from August 2, 2026

When it relates
If you build or sell under your own name a chatbot, agent, voice assistant or a system that generates text, images, audio or video. If you build your own chatbot on a third-party model and put it into service under your brand, you are usually the provider.
What the rule provides
  • Design systems that interact with people so those people know they are dealing with AI, unless it is obvious.
  • Mark generated or manipulated audio, images, video and text in a machine-readable format, using effective and interoperable techniques.
  • Generative systems placed on the market before Aug 2, 2026: complete technical marking by Dec 2, 2026 at the latest.
  • The Commission's Code of Practice on transparency of AI-generated content can serve as a reference.
Typical evidence
  • Wording and placement of the AI-interaction notice in each channel.
  • Technical specification of marking (watermarks, metadata) and detection tests.
Verification
Verified in the official source on November 2, 2026Dates checked against the consolidated AI Act text published by the European Commission's AI Act Service Desk (version as of Jul 27, 2026, including the Regulation (EU) 2026/1744 amendments): Articles 113 and 111.

Deployer transparency: deepfakes, public-interest text and emotion recognition

AI ActReglamento (UE) 2024/1689, art. 50(3)-(4)In force

Applies from August 2, 2026

When it relates
If you use chatbots, agents, generated marketing content, voice or likeness cloning, or emotion recognition or biometric categorization.
What the rule provides
  • Clearly disclose that an image, audio or video is a deepfake (content that imitates real people, places or events). For artistic or satirical works a disclosure that does not spoil the work is enough.
  • Disclose that text published to inform the public on matters of public interest was AI-generated, unless it went through human editorial review with someone accountable.
  • Inform people exposed to emotion recognition or biometric categorization.
  • Check that any third-party chatbot or agent you use discloses that it is AI; if you configure and publish it under your brand, take on the provider duties.
Typical evidence
  • Synthetic-content labeling procedure with approved examples.
  • Screenshots of notices on web, app, phone and social media.
  • Log of AI-assisted published pieces and their labels.
Verification
Verified in the official source on November 2, 2026Dates checked against the consolidated AI Act text published by the European Commission's AI Act Service Desk (version as of Jul 27, 2026, including the Regulation (EU) 2026/1744 amendments): Articles 113 and 111.

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