Last week we opened the doors of our headquarters in Barcelona to host the fourth edition of the CX Brunch. A gathering that, given the growing legal challenges in the sector, has become essential for understanding the regulations and learning how to respond.
This event was made possible thanks to our co‑organisers, Webpilots Spain — specialists in permission marketing — and Magnetron, official distributor of EPOS and Sennheiser among other leading brands. We also had the support of the AEERC (Spanish Association of Customer Relationship Experts) and our media partners Contact Center Hub and Relación Cliente.
Below we review the topics that shaped the day — updates from the AEPD, critical points of the ‘Stop Publicidad’ List, the impact of the anti‑telephone‑fraud regulation, changes to the Law on Customer Service Provision and updates to the framework for AI in Customer Experience (CX) — with insights from Daniel Vidal, lawyer and Legal Director at Webpilots Spain.
THE WELCOME THAT ALIGNED US
Luís A. González kicked off the morning with a sincere thank‑you to attendees, collaborators and the press. With a brief and clear address, he emphasised the goal of CX Brunch: a space born from the joint desire to contribute and drive forward our sector.
Luís A. González, Head of CCaaS Sales at Enreach, welcoming the attendees of the 4th edition of CX Brunch by Enreach.
FIVE LEGAL CHALLENGES WE TACKLED AT CX BRUNCH IV
With professional precision and flawless delivery, Daniel Vidal focused his presentation on five key challenges currently driving the pace of the contact‑centre industry.
1. AEPD UPDATES: A BREATH OF FRESH AIR (AND A FASTER PACE)
The big news: the change in leadership at the AEPD (Spanish Data‑Protection Agency). Lorenzo Cotino, Professor of Constitutional Law with experience in AI, has taken office and launched a new strategic plan for 2025‑2030.
“We can say it’s the first strategic plan to be implemented in such a short timescale and that, furthermore, brings hope to the sector.”
Daniel Vidal, Lawyer and Legal Director at Webpilots Spain
The plan, structured around seven pillars, gives the Agency’s role in industry a distinctly different tone. Particularly noteworthy is the third pillar: supporting and guiding regulatory compliance.
Another pertinent change: the AEPD will cease issuing annual reports and instead publish on a semi‑annual basis. The upside is timelier data; the downside, the loss of year‑on‑year comparison.
Vidal presented the latest semi‑annual report covering December 2024 to May 2025 and highlighted three trends:
- Complaints: up by nearly 30%. Possibly due to new types of complaints included since December.
- Satisfactory resolutions: down by 34%. Everything suggests the Agency is applying a different criterion when assessing outcomes.
- Investigations and sanctions: investigations up by around 40% and sanctions up by 18%.
“Once again I’m showing the same chart that illustrates the disproportion of sanctions in Spain compared to other European countries.”
Daniel Vidal, Lawyer and Legal Director at Webpilots Spain
2. STOP PUBLICIDAD LIST: SIGNIFICANT OPERATIONAL GAPS
Despite four appeals and several amendments, a second exclusion list has finally been published. And here lies the paradox: although this list isn’t yet operational, the Agency requires the sector to consult it.
Furthermore, the interaction between the ‘Stop Publicidad’ List (LSP) and the Lista Robinson remains unclear. Which takes precedence? How should conflicts be resolved?
“The Organic Law 3/2018 does not cover what happens if a consumer is registered on the LSP but not on the Lista Robinson.”
Daniel Vidal, Lawyer and Legal Director at Webpilots Spain
The result, for now, is a grey area complicating daily operations, increasing checks and adding legal uncertainty.
Daniel Vidal, Lawyer and Legal Director at Webpilots Spain, during his presentation at the 4th edition of CX Brunch by Enreach.
3. UPCOMING CUSTOMER‑SERVICE LAW: THE CATALAN‑LANGUAGE PROVISION
In recent months we’ve seen it in the headlines. The Spanish Government proposes to include in the upcoming Law on Customer Service Provision a clause requiring companies headquartered in Spain to provide service in Catalan when the customer requests it. Vidal reminded that, previously, other institutions had already called for service in any of the co‑official languages.
“If the contract is signed in Catalan, I don’t see why telephone or chat service couldn’t also be delivered in that language.”
Daniel Vidal, Lawyer and Legal Director at Webpilots Spain
Less visible in the media but operationally more impactful is the proposal by Pablo Bustinduy (Plural National Parliamentary Group SUMAR): to require a distinct numbering for commercial calls compared to customer‑service calls.
“This poses a considerable challenge: a business‑to‑business call might be considered commercial and require specific numbering.”
Daniel Vidal, Lawyer and Legal Director at Webpilots Spain
If these measures proceed, the sector would need to revise within record time its criteria for classification, routing and number‑management.
4. TELEPHONE‑FRAUD‑PREVENTION ORDER: THE MOST DEBATED TOPIC
One of the focal points of the presentation was the TDF/149/2025 Order. Its first phase was clear: curb telephone fraud conducted via unassigned numbers.
“The fraudster could impersonate your bank and ask you for your credentials easily because that number appeared under the bank’s name.”
Daniel Vidal, Lawyer and Legal Director at Webpilots Spain
Following its implementation, in February 2025 some 50 million calls were blocked and 2.5 million SMS were intercepted.
The greatest impact for the industry came with the second phase: the blocking of unsolicited commercial calls and SMS as well as customer‑service calls via mobile numbering.
“It’s an unjustified block that, to date, hasn’t been solidly justified.”
Daniel Vidal, Lawyer and Legal Director at Webpilots Spain
Since 7 June 2025, the date the regulation came into effect, around half a million calls a day and 18,500 SMS daily in July were blocked. According to Vidal, the volume partly stems from the AEPD’s imposition of potential licence loss for any operator that fails to block such communications.
The consequences for companies are severe: the CNMC classifies non-compliance as a serious offence, punishable by fines of up to €2 million, or twice the profit gained, or 1% of the company’s turnover from the previous financial year. In addition, businesses risk losing the telephone numbers used and face an extra €30,000 fine for individuals in executive or representative roles.
Despite the severity of the sanctions regime, the order leaves questions that raise concern: most notably, the lack of a clear definition of what constitutes an ‘unsolicited call’.
5. EUROPEAN AI REGULATION: NOW IN EFFECT
Vidal reminded the audience that Regulation ( EU ) 2024/1689 — the new European AI law — is already in force and that from 2 August 2025 the obligations on transparency and governance — including those affecting general‑purpose models — are enforceable and subject to sanction.
Providers of general‑purpose AI models are obliged to: document their models technically, publish a summary of the data used to train them, have a policy that respects copyright, and provide that information to anyone integrating those models. If they don’t, they can be sanctioned by the authorities.
AI INNOVATIONS FOR THE CONTACT CENTRE
Vidal presented very specific examples of how AI already enables real‑time accent adaptation to improve comprehension between interlocutors. A direct aid to smoother conversations.
“This technology is here to stay and to help — not to replace the people working in this sector.”
Daniel Vidal, Lawyer and Legal Director at Webpilots Spain
He also underlined their limitations: AI does not inherently include cultural nuance, context or intent. There are processes deeply human that it will not replicate without specific training and good oversight. The key, he insisted, is to add it to the team to enhance — not replace — the workforce.
MAGNETRON’S SESSION
Francisco de la Torre, Director of the Communications Division at Magnetron, shared a few words of encouragement and reminded us that AI has been with us for some time, embedded in everyday solutions such as EPOS headsets, which deliver high‑quality sound experience.
Next, he ran a raffle among the attendees for an exclusive model and encouraged everyone to try out the full range available in the room.
Francisco de la Torre, Director of the Communications Division at Magnetron, during his presentation at the 4th edition of CX Brunch by Enreach.
NETWORKING BRUNCH: THE SYNERGY MOMENT
The brunch‑style networking was the perfect finale to a highly productive morning. Our office buzzed with enquiries, thank‑yous and spontaneous conversations that — we’re certain — will mark the beginning of new synergies and collaborations.
Attendees of the 4th edition of CX Brunch by Enreach during the networking brunch.
FINAL CONCLUSIONS
We’d like to thank, once again, all the attendees and the event’s partners: Webpilots Spain and Magnetron as co‑organisers; our media partners Relación Cliente and Contact Center Hub; and the AEERC Association for their support.
After four editions, we can affirm that we’re driving a gathering for and by the industry, together with professionals who ensure a clear message and deliver high‑value insights.
“It’s been a pleasure to be at Enreach’s home, reviewing with rigour and openly the technical and legal updates for the contact‑centre.”
Daniel Vidal, Lawyer and Legal Director at Webpilots Spain
Once again, we “lit up the path” and explained how to overcome the legal challenges that are putting pressure on our sector’s operations — so we can work up to date and in full compliance.
“Again, we’ve seen how regulation impacts the sector and how technology — especially AI‑based — helps us surmount those barriers and do things the right way.”
Alfred Nesweda, Managing Director at Enreach
In 2025, the industry has experienced a multitude of legal updates — complex and, at times, ambiguous — which demand the expert clarification of professionals capable of resolving doubts and shedding light on so much uncertainty.
“Bringing the industry together in an open debate about the challenges facing contact centres and end‑clients was necessary.”
Carlos Jiménez, Head of Sales at Enreach
We know that we want to keep contributing to the sector and also go beyond our technological core: success only comes when we all row in the same direction.
“When all parties and industry players collaborate, only solutions are found.”
Luis A. González, Head of CCaaS Sales at Enreach
See you at the next edition of CX Brunch!
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