By Neil Fernandez, Operations Manager at Callnovo.ai

A company that sells into several countries usually runs one customer service operation for all of them: one phone system, one chatbot, one set of scripts. In 2026 that got harder. Three large consumer markets changed what a business must do when a customer calls, or when it calls the customer, and the three changes pull on different parts of the operation.

None of the three is a technology law. Each one lands on the support desk anyway. Spain set a service standard and asked companies to prove they meet it. France restricted the calls a business may place. Japan made protecting frontline staff from abusive customers an employer’s duty.

Summary chart of the three rules: who is covered, what the rule says, and what a company must be able to show

Spain: a number to hit, and a person on request

Spain’s Law 10/2025 on customer service took effect on December 28, 2025, and gives the companies it covers twelve months from that date to adapt. Twelve months from that date falls in late December 2026.

Who it covers

The law doesn’t apply to everyone. Under Article 2 it covers providers of basic services: water, gas and electricity, passenger transport, postal services, electronic communications and financial services, with the last two governed first by their own sector rules. It also covers companies and groups that sell mainly to consumers and that, in the previous financial year, employed at least 250 people, or had annual turnover above 50 million euros, or a balance sheet above 43 million euros. A smaller online seller of ordinary goods is outside its scope.

What it asks for

For companies inside it, the requirements are specific:

Answer time. 95% of calls received must be answered, on average, in under three minutes (Article 10.3). The same article says a call doesn’t count as answered if the customer wasn’t able to explain why they were calling and ask for a person.
No bot-only service. Automated answering systems can’t be the only means of customer service (Article 8.1). A customer must be able to ask for a person at any point in the interaction, and 95% of those requests must be met, on average, within three minutes of the request (Article 8.2).
A reference for every case. The company must give the customer an identifying key for each complaint, claim or incident, and for a query when it needs follow-up (Article 11.1).
As a general rule, complaints and claims must be resolved within a maximum of 15 working days (Article 17.1). Complaints about billing or undue charges have a maximum of five days (Article 17.3).
The reply goes out in the same language the customer used, among Spain’s official languages (Article 13.6).
The company carries the burden of proving it met its obligations (Article 4.7). It must commission an annual audit of the figures it publishes (Article 22.1) and keep the supporting documentation for at least five years (Article 21.2).

The law applies whatever the channel, and whether the service is run by the company itself or sits in a third party’s organization (Article 2.3). Outsourcing the phones doesn’t move a company out of scope.

What it means in practice

The practical question for an operations team is whether its phone system can produce the evidence. Whether 95% of calls were answered in three minutes depends on when the clock starts and whether abandoned calls are counted. Take 1,000 calls: 900 answered inside three minutes, 40 answered later, 60 abandoned. Measured against answered calls, that’s 95.7%. Measured against calls received, which is the wording the law uses, it’s 90%. Both the starting point and the denominator are settings in call routing software, not facts of nature.

The bot rule has a similar test. Call your own line, say you want to speak to a person, and count the steps.

France: outbound calls now need a yes first

France went the other way around and regulated the calls a business makes. According to the Institut national de la consommation, the French public consumer institute, the rules on telephone canvassing changed on August 11, 2026. A business must now have the consumer’s prior consent, which the institute describes as explicit, free and informed, before calling to sell. Without it, canvassing by phone for commercial prospecting is prohibited. The institute adds that consumers can report a breach on the government’s SignalConso platform.

The change also ended Bloctel, the opt-out list French consumers used to block sales calls. The logic has flipped. Before, a business could call unless the consumer had objected. Now it can’t call unless the consumer has agreed.

The same page states the exception: calls linked to a contract in progress, such as an existing subscription.

That exception is why most service calls are unaffected. A callback about a repair or a delivery belongs to an existing contract. The exposure is where service and sales share a desk. A support agent who also phones customers about renewals or upgrades is making a different kind of call. Three things follow for a team that dials French numbers:

Split the lists. Service callbacks and sales calls shouldn’t come out of the same dialing list.
Record consent as data. A consent field with a date and a source, attached to the customer record, not a note in a free-text box.
Filter before dialing. The sales list should be built only from numbers that carry that field.

Japan: the employer’s duty runs the other way

Japan’s change protects the people answering. The Ministry of Health, Labour and Welfare states that under a law promulgated on June 11, 2025, measures to prevent customer harassment become an obligation for employers from October 1, 2026. The ministry published its guidelines on February 26, 2026.

Customer harassment, known in Japan as kasuhara, is defined in the ministry’s leaflet by three elements that must all be present, among them conduct that goes beyond what is socially acceptable and that harms the worker’s working environment. Three points in the leaflet matter for a support operation:

Phone and online conduct counts. The leaflet says conduct by telephone and on the internet, including social media, is included. Chat and email aren’t a safe distance.
A complaint isn’t harassment. The leaflet states that not every customer complaint amounts to customer harassment. A team can’t use the rule to stop listening to angry customers.
Nobody handles it alone. Among the example measures, the leaflet lists not leaving one worker to deal with the conduct alone, and reporting conduct that may be criminal to the police.

For a foreign company selling into Japan, that means asking how its support team is covered, and what its systems record when a conversation turns abusive: the time, what was said, who took over, and when a supervisor stepped in. A handover that leaves no trace is hard to show afterward.

If you outsource your support

Many cross-border sellers don’t employ the people who answer. That doesn’t make the three rules someone else’s problem, but it changes who holds which duty.

Spain: the law says it applies when the service sits in a third party’s organization. The company in scope still has to produce the figures, so its contract with the provider needs to say who measures, who keeps the records, and who pays for the audit.
France: ask your provider which of the calls it makes on your behalf are service calls and which are sales calls, and where consent for the second kind is stored.
Japan: the duty sits with the employer of the staff. Ask your provider what measures it has in place, and what it will tell you when one of your customers crosses the line.

Where the law doesn’t spell out how responsibility is shared between a brand and its provider, that’s a question for counsel, not for a contact center manager.

One desk, three settings

Each rule turns something that used to be a management preference into something a company has to be able to show.

In Spain, it’s a report: how many calls, answered how fast, counted from which moment.
In France, it’s a field in the customer record: consent, with a date.
In Japan, it’s a history: what happened in a difficult conversation and who was brought in.

A team that serves these markets from one desk needs all three, and needs them per market. The Spanish answer-time figure means little if French, Spanish and Japanese calls sit in one queue with one report. A consent field that exists only in the French sales tool doesn’t help the support agent who’s about to place a callback. And an escalation path that works at 3 p.m. in Madrid has to work at 3 a.m. in Madrid too, when the customer is in Osaka.

Spain’s language rule also assumes someone can actually reply in the customer’s language, which is a staffing question before it’s a software one. It’s the problem that multilingual call center services exist to solve. At Callnovo.ai, where human agents handle support in more than 65 languages, it’s the first thing we ask a new client: which languages, in which markets, at which hours.

Eight checks for this quarter

For Spain, does your company or group meet any of the Article 2 thresholds? If not, the figures are a benchmark for you, not a legal duty.
Can you export last month’s answer times for Spanish callers alone, and does the report say when the clock starts and what’s in the denominator?
A way out of the bot. From your Spanish phone line and chat, how many steps does it take to reach a person?
Does every Spanish complaint get an identifying key without the customer asking?
For every French number your team dials to sell or renew, where is the consent recorded, and with what date?
Are French service callbacks and sales calls built from separate lists?
When a conversation with a customer in Japan turns abusive, what does your system keep, and who is told?
If a provider answers for you, does the contract say who measures, who stores and who reports in each of the three markets?

This article summarizes public sources and is not legal advice. The Spanish law is published in the Boletín Oficial del Estado as BOE-A-2025-26698. The French rules are explained by the Institut national de la consommation, and the Japanese measures by the Ministry of Health, Labour and Welfare. Check the official texts and your own counsel before changing a process.