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Cross-border

Serving twelve markets from one centre means twelve regimes, not one

A pan-European operation is not subject to a European regime. It is subject to as many national regimes as the markets it serves — and to at least one that reaches it from outside its own borders.

The economics of contact centres push towards consolidation: one location, several languages, many markets. The law pushes the other way, because the obligations attach to the market served and not to the place of establishment.

The clearest illustration is Spanish. Ley 10/2025 applies to undertakings established in Spain or in any other State, provided they operate in Spanish territory. An operation in Lisbon serving Spanish customers is within its scope, and its requirements — 95 % of calls answered on average in under three minutes, a prohibition on exclusively automated service, escalation to a supervisor within three minutes — are markedly more demanding than the Portuguese ones.

National regimes identified

Member StateInstrumentNature
SpainLey 10/2025 of 26 DecemberGeneral — service quality, waiting time, human attention, response deadlines. Fully enforceable since 28 December 2026, with an express extraterritorial clause
PortugalDecree-Law 134/2009 of 2 JuneGeneral — legal regime for customer telephone relationship centres; sixty seconds to a human operator; in force since 2009
FranceLoi 2025-594, of 30 June 2025, and its implementing decree of 23 July 2026Telephone canvassing — prior express consent required in all sectors since 11 August 2026
ItalyArticle 24-bis of Decreto-Legge 83/2012, and the public objection registerPartial — offshoring notification, origin disclosure, right to an EU-based operator; monthly consultation of the register and before each campaign
Other Member StatesNo general customer service regime identifiedOnly the harmonised layers, national telemarketing rules and sector obligations
The counter-intuitive finding

It is not the existence of national regimes that generates compliance work — it is their absence, combined with a small number of very demanding exceptions. An operation serving all twenty-seven markets faces one extraterritorial Spanish regime, a French consent regime, an Italian disclosure duty, a Portuguese regime in force since 2009, and, for the rest, no clear rule at all.

No clear rule is not the same as no obligation. It means the operation carries uncertainty it cannot resolve by reading a statute — which is precisely why the exposure has to be mapped rather than assumed.

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