Framework in place HU Verified 21 Oct 2026

Hungary

EU AI Act implementation, 2026

Hungary has a complete national framework (Act LXXV of 2025 and Government Decree 344/2025, in force 1 December 2025) with a ministerial AI market surveillance authority, now housed in the Ministry of Science and Technology after a 2026 portfolio reshuffle, and the National Accreditation Authority as notifying authority.

Implementing law
EnactedDec 2025
Penalty regime (Art. 99)
Adopted
Regulatory sandbox
Planned
Readiness rank
8 of 27score 76 / 100

Key findings

  • Hungary enacted a full framework by 1 December 2025: Act LXXV of 2025 plus Government Decree 344/2025 (X.31.), with a ministry-based AI market surveillance authority rather than an independent regulator.
  • The National Accreditation Authority is notifying authority; the MNB supervises AI in financial services; other sector regulators must consult the AI authority before compliance decisions.
  • National penalty rules exist: Decree 344/2025 converts the Article 99 euro ceilings into forint maxima and sets 30-day payment terms; the authority may also settle by written administrative agreement.
  • The authority's ministerial home shifted in 2026: the 'minister responsible for enterprise development' portfolio moved from the Minister for National Economy to the Minister of Economy and Energy after the new government formed, and Decree 139/2026 of 31 August 2026 assigned it to the Minister of Science and Technology, followed by a September departmental reorganisation.
  • The Commission's public list still shows no Hungarian single point of contact as of September 2026, and no operational sandbox has been confirmed.

National authorities

Market surveillance

Minister responsible for science and technology (AI Market Surveillance Authority operating as an organisational unit of the Ministry of Science and Technology)

National AI market surveillance authority and single point of contact under Article 70; Decree 344/2025 designates the 'minister responsible for enterprise development'; that portfolio passed from the Minister for National Economy to the Minister of Economy and Energy after the 2026 government formation and, by Government Decree 139/2026 (VIII.31.) amending Decree 90/2026, to the Minister of Science and Technology (reported by secondary sources); operates the regulatory sandbox and oversees real-world testing.

njt.jog.gov.hu (opens in new tab)
Market surveillance

Magyar Nemzeti Bank (MNB)

Sectoral market surveillance authority for high-risk AI systems used directly to provide financial services.

cms.law (opens in new tab)
Market surveillance

Sectoral authorities (where a sector regulator supervises the field)

Must obtain the AI market surveillance authority's opinion before deciding on AI Act compliance in their sector.

cms.law (opens in new tab)
Notifying authority

Nemzeti Akkreditáló Hatóság (National Accreditation Authority)

njt.jog.gov.hu (opens in new tab)
Single point of contact (Art. 70(2))

AI Market Surveillance Authority within the Ministry of Science and Technology (Article 70(2)); not yet shown on the European Commission's list as of 7 September 2026

Implementing law, penalties and sandbox

Implementing law Enacted

Act LXXV of 2025 on the domestic implementation of the EU AI Regulation, with Government Decree 344/2025 (X.31.) on the AI notifying and market surveillance authorities

Dec 2025

njt.jog.gov.hu (opens in new tab)
Penalty regime Adopted

National rules on penalties under Article 99 have been laid down.

Regulatory sandbox Planned

Sections 3(2) and 10 of Act LXXV of 2025 on regulatory sandboxes and real-world testing took effect on 2 August 2026; the AI market surveillance authority operates the sandbox with the Hungarian AI Council participating. Industry testbed proposals were invited by 20 February 2026, but no operational sandbox cohort was confirmed as of October 2026.

regulations.ai (opens in new tab)
National AI strategy

Hungary's National Artificial Intelligence Strategy 2020–2030 (Government Resolution 1573/2020)

2020

regulations.ai (opens in new tab)

Notable developments

  1. Parliament adopts Act LXXV of 2025; Decree 344/2025 issued

    The act and Government Decree 344/2025 (X.31.) entered into force on 1 December 2025, designating the National Accreditation Authority as notifying authority, the minister for enterprise development as AI market surveillance authority and single point of contact, converting EU fine ceilings into HUF maxima and creating the advisory Hungarian AI Council.

    njt.jog.gov.hu (opens in new tab)
  2. Hungarian AI Council holds founding meeting

    The Magyar Mesterséges Intelligencia Tanács, an advisory body chaired by the Government AI Commissioner with no decision-making powers, held its founding meeting on 15 December 2025.

    economx.hu (opens in new tab)
  3. Sandbox provisions take effect; portfolio moved to Ministry of Science and Technology

    Sections 3(2) and 10 of Act LXXV of 2025 on sandboxes applied from 2 August 2026. On 31 August 2026 Government Decree 139/2026 amended Decree 90/2026 on ministers' duties, assigning the AI market surveillance authority and Article 70(2) contact-point tasks to the Minister of Science and Technology.

    gdpr.blog.hu (opens in new tab)
  4. Ministry splits AI Act duties across departments

    An organisational instruction published in the Official Gazette on 21 September 2026 (effective 22 September) assigned market surveillance procedures, authority decisions and the single contact point to separate units within the Ministry of Science and Technology.

    mlex.com (opens in new tab)
  5. Commission list still blank for Hungary

    The Commission's market surveillance authorities page updated 7 September 2026 shows no entry for Hungary, implying the formal notification of the SPOC had not been reflected despite the domestic designation.

    digital-strategy.ec.europa.eu (opens in new tab)

Analysis

Hungary was an early mover on paper. Act LXXV of 2025 and its implementing Government Decree 344/2025 were in force by 1 December 2025, four months after the EU designation deadline and well before most peers. The model is unusual in placing market surveillance and the single point of contact inside a government ministry, under a minister, rather than with an independent authority such as the data protection regulator (NAIH) or the media authority (NMHH). The decree also did the housekeeping many member states have skipped: fine ceilings converted into forints, conformity-assessment designation rules, reporting duties, and a jurisdictional reach covering any AI output used in Hungary.

The weakness is institutional stability. Within nine months the 'enterprise development' portfolio that carries the authority moved from the Minister for National Economy to the Minister of Economy and Energy and then, by Government Decree 139/2026 of 31 August 2026, to the Minister of Science and Technology, with a further organisational instruction in September 2026 splitting procedures, decisions and the contact point across departments. The Commission's authority list, updated 7 September 2026, still shows a blank for Hungary. For an operator, the legal designation is clear but the practical interlocutor has been a moving target.

The sandbox and real-world testing provisions only took effect on 2 August 2026, and the authority had invited industry testbed proposals in early 2026; with the Digital Omnibus pushing the EU sandbox deadline to August 2027 there is time. The advisory AI Council and the NAIH's active enforcement on biometric and speech-analysis cases suggest Hungary's practical AI oversight will run through several bodies regardless of the formal design. On balance Hungary has the law and the penalties but not yet a settled, visibly functioning authority.

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Sources

  1. Minister responsible for science and technology (AI Market Surveillance Authority operating as an organisational unit of the Ministry of Science and Technology) (opens in new tab) njt.jog.gov.hu
  2. Magyar Nemzeti Bank (MNB) (opens in new tab) cms.law
  3. Notifying authority: Nemzeti Akkreditáló Hatóság (National Accreditation Authority) (opens in new tab) njt.jog.gov.hu
  4. Regulatory sandbox (opens in new tab) regulations.ai
  5. Hungarian AI Council holds founding meeting (opens in new tab) economx.hu
  6. Sandbox provisions take effect; portfolio moved to Ministry of Science and Technology (opens in new tab) gdpr.blog.hu
  7. Ministry splits AI Act duties across departments (opens in new tab) mlex.com
  8. Commission list still blank for Hungary (opens in new tab) digital-strategy.ec.europa.eu