The absence of a harmonised customer service regime has drawn attention away from four obligations that apply identically in every Member State, on the same date and in the same terms. Three of them are recent, and none of them is optional.
Layer by layer
Call cost — since 2011
A consumer contacting a trader by telephone about a concluded contract may not be charged more than the basic rate. This is the oldest of the harmonised obligations and the one most often satisfied by accident, because premium-rate consumer lines have been declining commercially for other reasons.
Article 21 of Directive 2011/83/EU
Data protection — since 2018
Recording, logging and the retention of traffic data are processing of personal data and require a lawful basis, prior information and a justified retention period. The right to object to direct marketing under article 21(2) is unconditional and takes effect immediately.
Regulation (EU) 2016/679
Accessibility — since 28 June 2025
Support services, expressly including telephone call centres and relay services, must meet accessibility requirements, and the conformity information must be provided both in writing and orally. The oral requirement is the one most often overlooked.
Directive (EU) 2019/882
AI transparency — since 2 August 2026
A natural person interacting directly with an AI system must be informed of that fact, unless it is obvious to a reasonably well-informed person. A grace period runs to 2 December 2026 for systems already on the market. Emotion recognition in the workplace has been prohibited outright since 2 February 2025.
Articles 5 and 50 of Regulation (EU) 2024/1689
The duty in article 50(1) falls on the provider of the AI system; paragraphs 2 to 4 place obligations on deployers, principally the marking of generated or manipulated content. An operation that buys a voicebot should therefore verify what the provider has done, and not assume that the obligation is exclusively its own — or exclusively the vendor’s.
Apply this to your operation
A general framework is no substitute for a concrete assessment. The diagnostic determines what applies to your operation.