Answers to the questions that arise most often, with the article cited alongside wherever the answer follows from a rule.
Questions and answers
Does our virtual assistant have to identify itself as a machine?
Yes. Article 50 of Regulation (EU) 2024/1689 requires that a person interacting with an AI system be informed of that fact, unless it is obvious to a reasonably well-informed person. The duty has applied since 2 August 2026, with a grace period to 2 December 2026 for systems already in operation.
Article 50 of Regulation (EU) 2024/1689
Can we analyse our agents’ emotions?
No. Article 5 of Regulation (EU) 2024/1689 prohibits the placing on the market, putting into service and use of AI systems that infer emotions of a natural person in the workplace, save for medical or safety reasons. The prohibition has applied since 2 February 2025, with no transition period. Sentiment analysis applied to agent performance evaluation falls within it.
Article 5 of Regulation (EU) 2024/1689
Do the accessibility requirements apply to telephone customer service?
Yes. The European Accessibility Act expressly covers support services, including telephone call centres and relay services. In Portugal it is implemented by Decree-Law 82/2022 of 6 December, applicable since 28 June 2025. Conformity information must be provided both in writing and orally, and the oral requirement is the one most often overlooked.
Directive (EU) 2019/882; Decree-Law 82/2022
We hold a quality certification. Are we covered?
No. Certification against a voluntary standard demonstrates conformity with that standard, not with the law. Certification schemes address service quality; the legal regimes address obligations, deadlines and evidence. An operation can be certified and non-compliant at the same time, and frequently is.
We serve Spanish customers from Portugal. Does Spanish law apply to us?
Very likely. Ley 10/2025 of 26 December applies to undertakings established in Spain or in another State, provided they operate in Spanish territory. It covers providers of services of general interest and all large undertakings — 250 or more employees, turnover above €50 million or a balance sheet above €43 million. It has been fully enforceable since 28 December 2026 and its waiting-time and human-attention requirements are markedly more demanding than the Portuguese ones.
Ley 10/2025 (Spain)
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