Hungary’s Act VII of 2024 on the Market in Crypto-Assets
Hungary’s Act VII of 2024 on the Market in Crypto-Assets, in force since 30 June 2024, brings the EU’s MiCA regime fully into Hungarian law: any entity that issues crypto-assets, offers them publicly, lists them or provides related services in or from Hungary must obtain a MiCA-compliant licence from the Magyar Nemzeti Bank, which now holds supervisory and sanctioning powers over all crypto-asset service providers (CASPs). A separate, Hungary-specific authorisation from the Supervisory Authority of Regulated Activities (SZTFH) is compulsory for businesses that validate crypto-to-fiat or crypto-to-crypto exchange transactions; licensees must have owners and managers of good repute, suitably skilled staff and documented conflict-management procedures.
The Act applies to any person that, in or from Hungary,
- issues crypto‑assets, offers them to the public or seeks admission to trading,
- provides any crypto‑asset service (exchange, custody, portfolio management, advice, trading‐platform operation, etc.), or
- performs crypto‑asset exchange validation.
All definitions (crypto‑asset, crypto‑asset service, electronic‑money token, asset‑referenced token, etc.) mirror Regulation (EU) 2023/1114.
Hungary’s crypto-asset regime assigns prudential and conduct oversight of all crypto-asset service providers to the Magyar Nemzeti Bank (MNB), acting as the Felügyelet, which licenses firms, monitors them on an ongoing basis and wields investigative, sanctioning and licence-withdrawal powers, while the separate Supervisory Authority of Regulated Activities (SZTFH) alone authorises and polices “crypto-asset exchange validation” businesses, maintaining their public register and carrying out on-site inspections and enforcement.
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Determine whether your planned activity is a crypto‑asset service as defined in MiCA and the Act.
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Prepare a crypto‑asset white paper (“alapdokumentum”) if you will issue tokens or seek public offering / trading. The document must be filed with the MNB and published before launch.
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Compile the MiCA licence application package (organisational information, programme of operations, governance, AML/CTF framework, ICT and cyber‑resilience arrangements, initial capital, etc.) and submit it to the MNB. The Act expressly requires full compliance with Regulation (EU) 2023/1114; no lighter regime is available.
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Pay the supervisory application fee and be ready to pay annual fees once authorised.
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Demonstrate fit‑and‑proper governance – board members, senior managers and majority shareholders must have clean criminal records and appropriate expertise; internal policies to avoid conflicts of interest are mandatory.
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Implement additional Hungarian conduct rules that accompany MiCA:
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staff offering personalised advice must meet knowledge and experience criteria (to be detailed in a government decree);
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a Hungarian‑language complaint‑handling system with call recording and five‑year record retention;
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mandatory reporting of major ICT incidents to the national CSIRT;
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compliance with MNB consumer‑information regulations that will be issued by the central‑bank governor.
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The MNB may refuse or withdraw a licence and impose proportionate sanctions if any MiCA or Act requirement is breached.
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This is a distinct, Hungary‑specific authorisation: every crypto‑to‑fiat or crypto‑to‑crypto exchange must be preceded by an independent validation attesting to customer and transaction identification.
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Exclusive right: only a legal entity that has obtained an SZTFH validation licence may issue the requisite “conformity declaration”.
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Core obligations: conduct origin‑of‑funds analysis, wallet ownership checks, counter‑party identification and external database screening within a reasonable time.
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Licence prerequisites:
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professionally competent leadership and staff,
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owners and managers of good repute with no relevant convictions in the preceding five years,
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documented procedures for conflict‑of‑interest management, and
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fulfilment of detailed personal, technical, IT‑security and financial conditions that the SZTFH president will lay down in a separate decree.
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Public register and supervision: the SZTFH keeps and publishes a register containing the licensee’s name, seat, tax number and contact data; it can inspect premises, seize evidence and suspend or revoke licences.
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Application & annual supervisory fee for CASPs
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Fixed element: 75 000 HUF × factor 4 = 300 000 HUF per year.
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Variable element:
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0.6 %o of the larger of the two turnover figures defined in MiCA, plus
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0.35 %o of the market value of crypto‑portfolios managed (where portfolio management is offered). njt.hu
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Validation service licence fee: set by SZTFH decree (not yet published) but annual supervisory oversight is already foreseen.
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Start‑ups entering the market after 30 June 2024 must hold the appropriate licence before commencing operations. Existing Hungarian CASPs have a grace period but must become fully MiCA‑compliant by 1 July 2025 at the latest.
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