Hungary's National Assembly enacted Act XXXVIII of 2026, repealing the mandatory crypto-asset conversion validation regime that had applied since 1 July 2025. The bill passed 143 votes to 46, with one abstention. The government cited direct conflict between the national validation requirement and Regulation (EU) 2023/1114 (MiCA), which applies uniformly across EU member states as a directly applicable EU regulation and supersedes conflicting national rules.
The repealed regime was introduced by amendment to Act LXXXV of 2020 on the Prevention and Combating of Money Laundering and Terrorist Financing. It required every crypto-asset conversion to be preceded by a declaration of conformity from a registered validation service provider. Validators were required to verify wallet ownership, customer identity, and the origin of funds before each transaction could proceed. Act XXXVIII of 2026 also repeals the criminal offences of crypto-asset misuse and providing unauthorised crypto-asset conversion services that the 2025 regime created.
Crypto-asset service providers (CASPs) and their clients operating in Hungary benefit directly from the repeal: the transaction-level validation step and its associated compliance costs no longer apply to conversions. CASPs retain all obligations under MiCA and Hungary's transposition of the Sixth Anti-Money Laundering Directive (AMLD6), including AML/CFT customer due diligence, record-keeping, and suspicious transaction reporting. The Magyar Nemzeti Bank (MNB) continues as the competent authority for CASP supervision under MiCA in Hungary.
Firms that were registered as validation service providers under the prior regime should confirm whether transitional provisions in Act XXXVIII of 2026 impose residual obligations or wind-down requirements. CASPs that structured transaction workflows to accommodate the validation step should review and update their operational procedures. Act XXXVIII takes effect on the eighth day following publication in the Magyar Kozlony.
We advise CASPs and crypto-asset businesses on MiCA authorisation, national regulatory change impact, and AML/CFT compliance across EU jurisdictions. Our partner network includes local counsel in Hungary and across the EU. Work we undertake includes MiCA CASP licensing, AML programme design, national regulatory change impact assessments, and competent authority engagement.