Introduction
The electricity sector in Spain is undergoing a historic transformation. On February 12, 2026, Royal Decree 88/2026—the new General Regulation on the Supply, Marketing, and Aggregation of Electrical Energy—officially took effect.
Until now, complying with regulations in the electricity market was a matter of internal processes. A contract was sent, an invoice was issued, and the process ran its course. Under the new law, the regulator (CNMC) no longer asks whether a task was completed, but rather whether the company can legally prove it in court. This poses major operational challenges and risks running into the millions for electricity retailers that fail to adapt the customer relationship systems underpinning their business processes in a timely manner.
What is Royal Decree 88/2026, and how does it affect electricity retailers?
This new regulation aims to protect consumer rights and ensure maximum transparency in the supply of electricity to households and businesses. It is no longer enough to simply carry out day-to-day operations; every interaction becomes a potential piece of evidence.
The regulation imposes new, very strict requirements:
- Mandatory Precontractual Document: A clear summary of the terms and conditions must be provided before the contract is signed. There must be an accurate record of when it was sent or read.
- Full telephone recordings: If the sale is made over the phone, the user’s explicit consent must be recorded. In addition, the recording must be saved with the exact date and time and provided to the customer upon request within 20 days.
- Transparent price adjustments: Price increases or changes can no longer be hidden away in a corner of the bill. They must be communicated separately one month in advance, including a table that compares the old and new rates.
- Full traceability: Changes in energy suppliers or aggregators and the handling of complaints must leave a clear and measurable electronic trail.
The Major Regulatory Risks of Inaction
Failure to adapt exposes companies in the electricity sector to serious financial and reputational consequences:
| ❌ Contract Nullity | If a customer claims they were unaware of the terms and conditions or that their identity was stolen, and the energy supplier does not have solid evidence to the contrary, the contract is immediately voided |
| ❌ Mass Refunds | If a price review is conducted and the customer cannot provide conclusive proof that the advance notice was sent, the customer is entitled to a refund of the amounts charged. |
| ❌ CNMC Penalties | Any poorly managed regulatory inspection or complaint that lacks a time-stamped audit trail directly results in administrative fines. |
The Solution: Turning Salesforce into Legal Evidence
To address this challenge without adding bureaucracy or compromising the user experience, we at Unified Comms (a Mailcomms Group company) have developed an innovative concept for the electricity sector in Spain. It involves combining the commercial and operational capabilities of Salesforce with the legal safeguards provided by the native Salesforce CertySign connector.
As a result, the classic customer record in your CRM is no longer just a repository for commercial and operational data. It is natively transformed into a legal record of evidence. This record collects, seals, and safeguards all evidence of interactions with the consumer under the European eIDAS framework.
| 📂 Salesforce Customer Record |
| 🛡️ LEGAL EVIDENCE FILE
Incorporates the Legal Capabilities of a Qualified Trust Service Provider |
| 🕒 Shipping/Tracking Test, Review of the Pre-Contractual Summary, and Data Collection
|
| 🎥 Video Identification and Advanced Electronic Signature
|
| 🎙️ Phone call recording with a timestamp
|
| ✉️ Certified notifications and document custody for price reviews
|
How does native, automated integration work?
Thanks to Salesforce Ready connectors, the entire legal workflow runs automatically from the Salesforce clouds (Sales, Service, or Marketing Cloud), eliminating the need for disconnected external systems.
The process follows a natural, educational, and transparent flow:
- Identity Capture and Verification: Using the capabilities of the native Salesforce video identification connector , the user’s identity is quickly and securely verified remotely, reducing the risk of fraud during sign-ups.
- Sending the Pre-Contractual Summary: Salesforce generates the summary document required by Royal Decree 88/2026. The CertySign connector sends it via certified channels (email, SMS, WhatsApp, or RCS). The system accurately records the exact second it was opened or read.
- Signing and Evidence Retention: The customer signs the electricity contract using an advanced electronic signature. If the process involves phone calls, the Archiving service captures the audio, time-stamps it, and links it to the customer’s file in Salesforce.
- Contractual Notices and Service Disconnections: Whenever a rate adjustment or a notice of service disconnection due to nonpayment is issued, the system generates a digital record presumed to be intact. This shifts the burden of proof in favor of the company in the event of any litigation.
Key Benefits for the Electricity Sector in Spain
Adopting this digital evidence solution in partnership with Unified Comms (Mailcomms Group) offers immediate strategic advantages:
- Guarantee of Regulatory Compliance: The energy retailer always has a complete set of documents on hand to demonstrate to the regulator that it is 100% compliant with Royal Decree 88/2026.
- Transparency and trust: Customers sign agreements and receive clear information through accessible digital channels, improving conversion rates and brand image.
- Operational efficiency: Manual tasks and information silos are eliminated. The entire team works in Salesforce with unified traceability.
- Legal Protection: In the event of claims related to price increases or disputed contracts, the company provides irrefutable digital records rather than mere screenshots.
Conclusion
Royal Decree 88/2026 is now a reality that redefines the rules of the game for electricity supply in Spain. Inaction is not an option in an environment where the lack of digital evidence can cost millions.
Now is the time to integrate legal capabilities into Salesforce to transform how you manage your customers and build a culture based on trust and legal certainty.
Would you like to discuss your situation to see how to implement this Salesforce Legal Evidence File solution?
