Detailed overview
Hungary: MNB MiCA Authorisation and SZTFH Conversion-Validation Overlay (Act VII of 2024)
Hungary is a full MiCA jurisdiction. The Hungarian framework is based on Regulation 2023/1114 and Act VII of 2024 on the crypto-assets market.
The Magyar Nemzeti Bank is the Hungarian competent authority for MiCA. It is the main regulator for standard crypto-asset service provider authorisation in Hungary.
Hungary also has a separate national crypto-asset conversion-validation regime supervised by the Supervisory Authority of Regulated Activities. This is distinct from ordinary MiCA CASP authorisation and is particularly relevant to exchange services.
Regulator
The main regulator for a standard Hungarian CASP application is the MNB.
The MNB receives CASP authorisation applications, supervises Hungarian CASPs and acts as Hungary’s MiCA competent authority.
The SZTFH supervises crypto-asset conversion-validation service providers. It is not the ordinary MiCA CASP authorisation authority, but its regime may affect exchange services in Hungary.
The correct authority must be checked before filing, especially for credit institutions, investment firms, electronic-money institutions, payment institutions, ARTs, EMTs, exchange services and conversion-validation issues.
Licensing route
A business that provides crypto-asset services in or from Hungary generally needs MiCA authorisation as a crypto-asset service provider unless it is an eligible financial entity using Article 60 or a duly authorised EU CASP passporting into Hungary.
The relevant crypto-asset services are custody and administration of crypto-assets for clients, operation of a crypto-asset trading platform, exchange of crypto-assets for funds, exchange of crypto-assets for other crypto-assets, execution of client orders, placing of crypto-assets, reception and transmission of orders, advice on crypto-assets, portfolio management on crypto-assets and transfer services for clients.
Transfer services are a separate MiCA service and should be included in the service-mapping analysis.
The licence perimeter applies only where the asset is within MiCA. Tokens that qualify as financial instruments, deposits, structured deposits, fund interests, payment instruments, non-MiCA e-money arrangements, insurance products or other regulated products require separate legal analysis.
Article 63 authorisation
A standard unregulated Hungarian CASP applicant applies to the MNB for MiCA authorisation.
A MiCA-authorised CASP must have a registered office in an EU Member State where it carries out at least part of its crypto-asset services, its effective management in the EU and at least one EU-resident director.
A credible Hungarian application should include a full service map, legal perimeter analysis, programme of operations, business plan, constitutional documents, proof of prudential safeguards, governance materials, management fit-and-proper evidence, qualifying-holder information, internal controls, AML and counter-terrorist-financing procedures, sanctions controls, TFR procedures, risk assessment, business-continuity plan, ICT and DORA materials, client-asset and client-fund segregation procedures, complaints procedures, conflicts management, outsourcing framework, custody policy where relevant, trading-platform rules and market-abuse systems where relevant, exchange commercial policy and pricing methodology where relevant, execution policy where relevant, advice and portfolio-management competence evidence where relevant and transfer-service procedures where relevant.
The MNB assesses completeness and may request additional information. The practical timing depends heavily on file quality, ownership structure, service scope, outsourcing, AML and TFR controls, ICT readiness, custody model, conversion-validation issues and market-abuse controls.
Article 60 notification
Article 60 is not a general shortcut for unregulated applicants. It is a notification route for specified regulated financial entities and permitted equivalent crypto-asset services.
The Article 60 route may be relevant for credit institutions, central securities depositories, investment firms, market operators, electronic-money institutions, UCITS management companies and alternative investment fund managers.
The financial entity must notify the competent authority at least 40 working days before first providing the relevant crypto-asset services.
A regulated entity must map each proposed crypto-asset service to its existing authorisation and the MiCA Article 60 equivalence rules.
A regulated entity that wants to provide non-equivalent crypto-asset services may still need full CASP authorisation.
Transitional position
Hungary’s MiCA transition has expired.
Providers already operating before 30 December 2024 had to comply with MiCA by 1 July 2025 at the latest.
Legacy activity, previous status or transitional reliance should not be marketed as MiCA authorisation.
New or continuing Hungary-facing crypto-asset service activity should be structured through MiCA authorisation, a valid Article 60 route or a valid MiCA passport.
Passporting and register checks
A MiCA-authorised CASP may provide its authorised services across the EU through the MiCA passport, subject to the required notification process and authorised service scope.
A Hungarian legacy status or expired transitional position does not itself create a MiCA passport.
MNB, SZTFH and ESMA register information should be checked before relying on a provider’s authorisation status, onboarding a counterparty, launching services or publishing any authorisation claim.
Costs
MNB application fees apply.
The current MNB fee schedule lists HUF 1,900,000 for CASP authorisation.
A qualifying-holding procedure can attract a HUF 900,000 fee. Certain change matters can attract a HUF 650,000 fee.
White-paper-related fees may also apply. The current schedule lists HUF 1,100,000 for notification of a white paper for crypto-assets other than ARTs and EMTs, HUF 1,100,000 for EMT white-paper notification and HUF 1,900,000 for approval of an ART white paper by a credit institution.
Authorised CASPs also pay MNB supervisory fees. The base supervisory fee is HUF 300,000. Variable supervisory fees also apply and are linked to the MiCA prudential amount and, where relevant, crypto-asset portfolio-management assets.
The fee schedule should be checked before filing because MNB and SZTFH fee rules may be amended.
These amounts are not the full cost of authorisation. Applicants should also budget for legal, governance, AML, sanctions, TFR, DORA, ICT, custody, outsourcing, complaints, conflicts, audit, accounting, prudential, insurance and operational implementation costs.
Prudential safeguards
A CASP must maintain MiCA prudential safeguards at all times.
The required amount is at least the higher of the applicable permanent minimum capital requirement and one quarter of fixed overheads for the preceding year.
The MiCA class amounts are EUR 50,000 for class 1, EUR 125,000 for class 2 and EUR 150,000 for class 3.
Class 1 covers execution of orders, placing, transfer services, reception and transmission of orders, advice and portfolio management.
Class 2 includes class 1 services plus custody and administration, exchange of crypto-assets for funds and exchange of crypto-assets for other crypto-assets.
Class 3 includes class 2 services plus operation of a crypto-asset trading platform.
Where a provider offers services in more than one class, the highest applicable class applies.
Prudential safeguards may take the form of own funds, an insurance policy, a comparable guarantee or a permitted combination.
Complaints and staff competence
Hungarian CASPs should prepare local complaint-handling and staff-competence arrangements before filing.
CASPs must make telephone and internet complaint channels available. Telephone complaint communications must be recorded and retained for five years. Complaints must be investigated free of charge. A CASP must designate a contact person for consumer-protection matters. Complaints are handled in Hungarian unless otherwise agreed.
Natural persons providing information or advice on behalf of a CASP must have appropriate knowledge and professional experience. Hungary has a specific government decree on the knowledge and experience required for persons providing CASP information or advice.
Advice, information and portfolio-management models should therefore be reviewed for staffing, training and evidence requirements.
Hungarian conversion-validation overlay
Hungary has a separate national conversion-validation regime.
Subject to SZTFH decree exceptions, crypto-assets may be exchanged for money or other crypto-assets only on the basis of a compliance statement issued by an authorised crypto-asset conversion-validation service provider.
A conversion service provider must refuse the conversion service where customer or transaction identification is unsuccessful.
A validation service must cover at least examination of the origin of the crypto-assets, verification of ownership of the storage device or wallet, identification of related persons where possible, profile-based review of the service user and external database checks.
A crypto-asset conversion-validation service provider requires SZTFH authorisation. The current SZTFH authorisation fee is HUF 620,000.
This overlay is particularly relevant for exchange of crypto-assets for funds, exchange of crypto-assets for other crypto-assets, OTC conversion, brokerage flows, wallet conversion flows and settlement models.
The regime is also subject to EU-law uncertainty. The European Commission has opened an infringement procedure concerning Hungary’s MiCA implementation. Providers should monitor this proceeding and any resulting Hungarian amendments before launching conversion activity.
AML, TFR and DORA
Hungarian CASPs must prepare AML, sanctions, TFR and ICT controls before filing.
Core controls include customer due diligence, beneficial ownership analysis, AML risk assessment, sanctions screening, transaction monitoring, suspicious-activity escalation, travel-rule procedures, treatment of self-hosted addresses where relevant, outsourcing oversight, recordkeeping and staff training.
DORA and ICT readiness are also central. A Hungarian application should include ICT governance, security documentation, incident management, business continuity, outsourcing controls and operational-resilience evidence.
The conversion-validation regime does not replace ordinary AML, TFR, sanctions or MiCA compliance.
ARTs, EMTs and token issuance
Token issuance and CASP authorisation are separate workstreams.
A public offer or admission to trading of crypto-assets other than ARTs and EMTs must comply with MiCA. ART issuers, offerors and admission applicants must comply with MiCA. EMT public offers and admission to trading require separate MiCA and Hungarian analysis.
A credit institution or e-money institution offering an EMT must comply with the applicable MiCA rules and notify the relevant white paper to the MNB.
White-paper notification or approval fees may apply.
A CASP licence should not be treated as covering token issuance, admission to trading, ART obligations, EMT obligations or white-paper obligations.
Ongoing obligations
A Hungarian CASP must comply with MiCA, Act VII of 2024, MNB supervisory requirements, AML and counter-terrorist-financing obligations, sanctions controls, TFR, DORA and applicable Hungarian complaint-handling and staff-competence rules.
Core obligations include governance, management suitability, qualifying-holder controls, prudential safeguards, internal controls, risk management, AML and counter-terrorist-financing procedures, sanctions controls, transaction monitoring, TFR implementation, business continuity, ICT and DORA controls, outsourcing oversight, complaints handling, conflicts management, custody safeguards, client-asset and client-fund segregation, recordkeeping, fair and non-misleading client information, cost and fee transparency, market-abuse systems where relevant and service-specific conduct rules.
Exchange services and conversion flows must also be reviewed under the Hungarian conversion-validation regime.
Enforcement risk
Hungary is not a light-touch jurisdiction.
The MNB may impose supervisory measures for MiCA and Hungarian-law breaches. These can include public statements, orders to cease or desist, management restrictions, suspension or prohibition of crypto-asset services and measures affecting online interfaces and access.
MiCA requires Member States to maintain administrative penalties and supervisory measures for CASP infringements. These include public statements, cease-and-desist orders, benefit-based fines, natural-person fines and legal-person fines.
Hungarian criminal-law exposure may also arise in relation to unauthorised crypto-asset conversion activity and breach of the conversion-validation obligation.
The main enforcement risks are operating without MiCA authorisation, continuing activity based on expired transition, presenting legacy status as a MiCA licence, using Article 60 without eligibility, providing services outside authorised scope, ignoring the conversion-validation overlay, weak AML or TFR controls, weak DORA readiness and misleading marketing or authorisation claims.
Practical assessment
Hungary is suitable only for firms that are prepared to handle both MiCA authorisation and Hungary’s local conversion-validation overlay.
It is not suitable for firms looking for a simple paper registration, continued transition, or an informal exchange-services route.
The main execution risks are incorrect service classification, missing transfer services, treating Article 60 as a general shortcut, relying on expired transition, underestimating MNB documentation expectations, overlooking SZTFH conversion-validation requirements, launching exchange services without a validation analysis, failing to evidence prudential safeguards and filing before AML, TFR, DORA, ICT, custody, outsourcing, complaints, conflicts and service-specific controls are ready.