Answers to the questions that arise most often, with the article cited alongside wherever the answer follows from a rule.
Questions and answers
How many regimes apply to a contact centre?
Six, and they do not cross-refer. The national customer service regime, where one exists; the rules on the cost of consumer contact lines; consumer law as it applies to service and to distance contracting; data protection, as regards recording, logging and unsolicited communications; accessibility of support services; and transparency of automated interaction systems. Each layer has its own instrument, its own timetable and its own authority, and none of them refers to the others.
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
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
Will the ePrivacy Regulation replace the current rules?
Not in the foreseeable future. The proposal for a Regulation on privacy and electronic communications was formally withdrawn by the European Commission, with the withdrawal published in the Official Journal in October 2025, on the grounds that no agreement was in prospect and that the proposal had been overtaken by legislation adopted since. Directive 2002/58/EC therefore continues to apply, as transposed by each Member State — which means the divergence between national regimes is durable, not transitional.
Commission communication C/2025/5423
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.
What does it take to demonstrate that we comply?
Evidence organised by obligation. Complying and being able to show that you comply are different things, and before an authority or a contracting party only the second one counts. The practice that solves it is easy to state and laborious to execute: for each applicable obligation, identify the document, record or measurement that demonstrates it, check whether it exists, produce what is missing, and name who keeps it current. That matrix, not good intentions, is what gets produced in an inspection.
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