Hungary: New implementing rules for the Hungarian crypto-asset regime

30 Oct 2025    2 minute read
FSR

In brief

Following the significant changes to the regulation of crypto-asset services adopted this summer, the Supervisory Authority for Regulatory Affairs (SARA) has published the implementing decree ("Implementing Decree") to the amended Crypto Markets Act that sets out the detailed rules of the new regulatory framework.

Contents

As expected, the Implementing Decree outlines the exceptions under which the conversion of crypto-assets does not require validation. Crypto-assets may be converted to funds or other crypto-assets without validation if:

  • A natural person converts crypto-assets exclusively for their own purposes, and the transaction is aimed solely at converting their own crypto-assets into other crypto-assets.
  • The crypto-asset conversion service is provided without consideration.
  • The crypto-asset conversion service is not provided on a regular bases.
  • The crypto-asset service is provided in a decentralized manner, and where applicable, by using smart contracts, including, but not limited to:
    • One or more smart contracts locking and creating crypto-assets (bridging) for the same person or persons in order to ensure interoperability between DLT networks
    • One or more smart contracts granting the client a new crypto-asset – providing control over the asset made available by the client – in exchange for the crypto-asset provided by the client for the purpose of liquidity pooling
    • The creation and granting of a crypto-asset providing control over a crypto-asset is carried out in any other decentralized manner.
  • In certain cases concerning criminal investigation

It should be noted, that the first exception only applies to the conversion of a crypto-asset into other crypto-assets. Therefore, if no other exception can be invoked, the conversion of crypto-assets to funds by natural persons – and any conversion by legal persons – must be validated.

The Implementing Decree also sets out the detailed rules of the authorization procedure for the service provider authorized to validate crypto-asset exchange transactions ("Validator"). Future Validators must comply with several requirements, including having a board of directors, a supervisory board and a statutory auditor. They must have at least a registered capital of HUF 80 million, at least two employees with specific qualifications, special softwires and specific policies.

Validators will also be required to publish the names and company registration numbers of the crypto-asset service providers, for whom they provide validation services.

The Implementing Decree shall enter into force on 30 October 2025. However, it should also borne in mind that the amendments of the Crypto Markets Act adopted this summer shall only apply from the 60th day following the entry into force of the Implementation Decree. Therefore, market participants still have a transitional period to prepare for the new regime.

Contact Information
Jozsef Vagi
Partner at BakerMcKenzie
Budapest
Read my Bio
jozsef.vagi@bakermckenzie.com
Andras Szondy
Associate at BakerMcKenzie
Budapest
andras.szondy@bakermckenzie.com

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