| Act LXIX of 2024 on Hungary's cybersecurity (NIS2)Supervisor: SZTFH (Supervisory Authority for Regulatory Affairs) · incident handling: NKI (National Cyber Security Centre)28 | In forceEnacted 20 Dec 2024, in force 1 Jan 2025, repealing Act L of 2013 and the 2023 act25. Amendments in force 31 May 202526. | Entities report their data to the authority within 30 days of falling in scope, sign an audit contract within 120 days of registration and complete an audit within two years, then every two years29. First round: audit contracts by 31 Aug 2025, audits by 30 Jun 202626. Audits must come from auditors on the SZTFH register; SZTFH Decree 6/2026 eased auditor conditions on 8 Jun 202627. Fines for essential entities reach €10M or 2% of global turnover28. Supervision fee up to 0.015% of turnover, capped at HUF 10M29. | Implication: about 3,500 entities run a two-year audit cycle27, and audit findings need remediation. Response: audit-readiness and remediation alongside a licensed auditor partner, then managed SOC, GRC and supplier assurance. |
| Act LXXXIV of 2024 on the resilience of critical entitiesTransposes the CER Directive; repeals Act CLXVI of 2012 | In forceFirst phase from 30 Dec 2024. Material provisions from 1 Jan 202525. | The government designates a general competent authority and a separate one for the energy sector. Designation procedures had to start by 30 Apr 202525. We did not re-verify which entities have been designated. | Implication: energy, transport, health and other critical operators combine physical and cyber resilience duties. Response: OT assessments, resilience operations and tested DR runbooks. |
| Cyber Resilience Act (CRA)Regulation (EU) 2024/2847 | Reporting liveReporting duties apply from 11 Sep 2026. Most obligations apply from 11 Dec 202734. | Manufacturers of products with digital elements report actively exploited vulnerabilities and severe incidents: early warning in 24 h, notification in 72 h, final report in 14 days (vulnerabilities) or one month (incidents), through ENISA's Single Reporting Platform34. | Implication: Hungarian electronics, automotive-electronics and device makers need vulnerability handling now. Response: cloud code signing, IoT PKI and a 24 h reporting runbook. |
| GDPR + Act CXII of 2011 (Infotv.)Supervisor: NAIH (National Authority for Data Protection and Freedom of Information) | In forceIn 2025 NAIH ran 4,855 investigations (+37%) and 893 inspections (+52%), with fines of about HUF 98M in total30. | The largest Hungarian fine to date, HUF 250M, went to Budapest Bank for AI analysis of customer calls, including emotional state, without an adequate DPIA. 2025 focus areas: AI in banking, workplace CCTV, webshop privacy notices and health data30. | Implication: AI on personal data needs a DPIA first, and as a processor XcellHost is audited by customers. Response: EU hosting by default and privacy operations adapted to GDPR and Infotv. |
| GDPR transfers to IndiaChapter V · SCCs: Decision (EU) 2021/914 | In forceIndia is not on the Commission's adequacy list31. | Transfers need a tool such as the standard contractual clauses. Clause 14 requires the parties to assess the destination's laws and practices, a transfer impact assessment (TIA)32. | Response: EU hosting by default, processor SCCs with a documented TIA for Mumbai support, and encryption with EU-held keys via Cloud HSM. |
| EU Data ActRegulation (EU) 2023/2854 | In forceApplies from 12 Sep 2025. Access-by-design from 12 Sep 2026. Switching and egress charges must go by 12 Jan 202733. | Data holders give users access to connected-product data. Cloud and edge providers remove switching barriers and add safeguards against unlawful third-country government access33. | Implication: vehicles, batteries and industrial kit made in Hungary are connected products. Response: no exit fees, documented export formats and a migration offer timed to Jan 2027. |
| eIDAS 2.0 + Digital Citizenship Programme (DÁP)Regulation (EU) 2024/1183 | In forceEach member state offers an EU Digital Identity Wallet by 24 Dec 202635. The DÁP app had nearly 2.5 million downloads by Nov 202522. | From 24 Dec 2027, regulated relying parties such as banking, energy, transport, health and telecoms, and very large platforms, must accept the wallet35. The 2025 Digital Decade report said Hungary's eID was not yet notified under eIDAS3. | Implication: regulated firms need wallet acceptance and stronger PKI. Response: managed PKI, Cloud HSM and MFA integration. We partner with a qualified trust service provider for qualified signatures. |
| EU AI Act + Digital Omnibus on AIReg. (EU) 2024/1689 · amended by Reg. (EU) 2026/1744 | In force · phasedBans and AI literacy from 2 Feb 2025. GPAI duties from 2 Aug 2025. The Omnibus took effect 27 Jul 20263637. | Transparency duties apply from 2 Aug 2026. Annex III high-risk systems move to 2 Dec 2027 and Annex I (products) to 2 Aug 2028. New prohibited practices apply from 2 Dec 202636. | Implication: customers need an AI inventory, risk classification and staff AI literacy. Response: vCAIO advisory, ISO/IEC 42001 and AI literacy training. |
| Act LXXV of 2025 on implementing the AI ActWith Government Decree 344/2025 (X.31.) | In forceAdopted 21 Oct 2025, in force 1 Dec 2025. AI authority governance provisions from 2 Aug 202638. | As enacted in 2025: the National Accreditation Authority is the notifying authority, the minister for enterprise development the market surveillance authority, and the MNB the authority for high-risk AI in financial services. A Hungarian AI Council advises39. Designations may change after the 2026 change of government; not re-verified. | Implication: banks face MNB scrutiny of high-risk AI, such as credit scoring. Response: AI security assessments and governance workshops before high-risk dates. |
| DORARegulation (EU) 2022/2554 · supervisor: MNB | In forceApplies from 17 Jan 202540. | ICT risk management, incident reporting, resilience testing and ICT third-party risk for financial entities, including a register of ICT providers40. | Implication: banks and insurers audit every ICT provider, XcellHost included. Response: a DORA contract annex, audit and exit rights, and the BFSI Cloud evidence pack. |
| MNB Recommendation 2/2025 on community and public cloudRead with Recommendation 1/2025 on IT system protection | AppliesIssued 13 Jan 2025, applies from 17 Jan 2025, and repeals Recommendation 4/2019. Not binding; applies to DORA entities where it does not conflict with DORA41. | Assess risks of data location and document extra care for providers outside the EEA. Record processing locations at data-centre level. Give the institution and the MNB audit rights, including on-site. Keep an exit strategy and plan, and notify the MNB of an exit41. | Implication: a Mumbai-hosted service for a Hungarian bank needs extra justification. Response: EU partner DCs for bank data, DC-level location records and an MNB-ready exit plan. |
| Public-sector cloud use and state ITAct LXIX of 2024, section 9 · state agencies DMÜ, DKÜ, NISZ | Check per projectCovered bodies may use non-private cloud or process data abroad only on the basis of their data classification29. In June 2026 the new government replaced the heads of DMÜ, DKÜ and NISZ and began an audit of state IT systems23. | Classification sets where state data may sit. We could not confirm whether a separate decree requires in-country hosting for all state data; Act L of 2013, which earlier commentary linked to EU/EEA hosting, was repealed25. | Implication: public work goes through Hungarian primes and in-country DCs. Response: sell only through partners, with a classification-to-hosting mapping per tender. |
| Entity & taxKft. · CIT · local business tax · innovation contribution · VAT · WHT | CurrentAs summarised by PwC (reviewed 1 Jul 2026)424344. | Kft.: HUF 3M minimum capital, attorney-countersigned or notarised deed46. CIT 9%, local business tax up to 2%, innovation contribution 0.3% (micro and small firms excluded)42. VAT 27%, the EU's highest standard rate4345. No domestic WHT on dividends, interest or royalties paid to companies44. | Response: see pricing & tax. Get Hungarian tax advice for each contract structure. |