Hungary: Significant changes to the Hungarian crypto market

10 Jul 2025    2 minute read
Crypto

In brief

Recent legislative reforms in Hungary have introduced notable changes to the regulation of crypto-asset services. In Hungary, crypto-asset services are regulated by the Markets in Crypto-Assets Regulation (MiCA) and Act VII of 2024 on the Market of Crypto-Assets ("Crypto Act"), which has been amended with effect from 1 July 2025. The amendment affects all crypto-asset service providers offering services in Hungary involving the exchange of crypto-assets for funds or for other crypto-assets.

Contents

According to the amended Crypto Act, crypto-assets may only be exchanged for funds or other crypto-assets based on a compliance certificate issued by a service provider authorized to validate crypto-asset exchange transactions ("Validator"). In the absence of a compliance certificate, the transaction shall be invalid and produce no legal effect. Additionally, according to the recent changes to the Hungarian Criminal Code, it constitutes a criminal offense (i) to carry out crypto-asset exchange activities in violation of the validating requirements set out in the Crypto Act and (ii) to exchange crypto-assets for funds or other crypto-assets by using unauthorized crypto-asset exchange services. The aforementioned actions may constitute a criminal offense only if the exchanged amount reaches or exceeds HUF 5 million.

The Validator is a legal entity authorized and supervised by the Supervisory Authority for Regulatory Affairs (SARA). The purpose of validating crypto-asset exchange transactions is to identify the clients and the transactions. The validation procedure includes at least (i) the examination of the origin of the crypto-asset, (ii) verification of ownership of the device or wallet suitable for storing the crypto asset, (iii) the identification of associated natural or legal persons, where possible, (iv) a profile-based assessment of the service user and (v) verification against external databases. If the validation results in successful identification of both the client and the transaction, the Validator shall issue a compliance certificate.

As a general rule, a compliance certificate is required for the conversion of crypto-assets to funds or other crypto-assets in all cases. However, the Crypto Act preserves the option for the president of SARA to establish exemptions. Therefore, although no exemptions have been adopted yet, it is possible that certain transactions will be excluded from the validation obligation (e.g., transactions under a certain threshold).

At this stage, several questions remain unanswered. No Validator has been authorized to date, and the technical rules governing the validation procedure are still unknown. The amended Crypto Act has authorized the president of SARA to adopt the detailed rules implementing the changes. The new rules outlined above will apply from the 60th day following the entry into force of the implementation decree of the president of SARA. However, this decree has not yet been published.

Contact Information
József Vági
Partner
Budapest
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jozsef.vagi@bakermckenzie.com
András Szondy
Associate
Budapest
andras.szondy@bakermckenzie.com

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