New MNB regulation on complaint handling by financial organisations
The National Bank of Hungary (MNB) has published a new decree on complaint handling by financial organisations (Decree No. 16/2026 (VI. 3.)), replacing the rules that have been in force since 2021. The new decree, which goes into force in late July 2026, largely preserves the earlier framework but extends compliance obligations to market participants that were not previously covered and tightens certain customer-protection standards.
These changes are expected to impact payment institutions, electronic money institutions, credit servicers and crypto-asset service providers.
The new decree applies to 14 categories of service provides as opposed to the nine categories previously affected. Payment institutions, electronic money institutions, voucher issuers, the Postal Clearing Centre operator, credit servicers and crypto-asset service providers are now included.
Crypto-asset service providers are subject to certain provisions on how complaints must be answered, rather than to the full set of obligations.
The definition of “complaint” has also been widened in accordance with the extended scope of financial organisations. Previously, the decree covered grievances raised by fund members, customers, members and investors. The new decree adds borrowers as a distinct category and brings credit servicing activities within the types of conduct that can be targeted for complaints. In practice, borrowers who interact with credit servicers now have an explicit complaint channel under the MNB’s rules.
The change most likely to require immediate operational adjustment is the five-minute live-operator rule. Until now, only four types of service provider were required to ensure a live customer service agent answered the phone within five minutes of a successfully connected call. The new decree extends this to nearly all financial service providers, from investment firms through to credit servicers.
For institutions that have not previously staffed their telephone complaint lines to this standard, the requirement may mean recruiting additional agents, adjusting shift schedules or upgrading call-routing technology.
The regulation uses a reasonableness standard whereby the service provider must act “as can be generally expected in the given circumstances” but the five-minute benchmark is explicit and measurable. Independent and tied insurance intermediaries are subject to a lighter rule: they may record the incoming call and call the customer back for substantive complaint handling no later than the following business day.
The decree also requires that the MNB complaint form be available online. Previously, this requirement applied only where a service provider operated a website to comply with a statutory obligation. Under the old rules, a service provider that maintained a website purely for commercial or marketing purposes was not required, on that basis alone, to make the MNB complaint form available on the website. The new regulation drops that distinction: any service provider that operates a website, irrespective of why the website is maintained, must make the form available. Written complaints submitted in other forms must still be accepted.
Several provisions remain largely unchanged. Response deadlines remain 30 days for written complaints, and 15 business days for payment-service complaints. If a payment-service complaint cannot be fully answered within 15 business days for reasons beyond the provider’s control, the provider must send an interim response explaining the delay and setting a deadline for the final answer, which may not exceed the 35th business day after receipt of the complaint.
Where the response is sent electronically, the dispatch must be logged through a closed, tamper-proof system that records the time of sending, the recipient and an electronic fingerprint of the content. Service providers must also continue to group complaints by topic at regular intervals, identify root causes, assess whether those causes may affect other products or services, initiate corrective action and document recurring problems and legal risks.
The new decree will enter into force 45 days after its publication, giving newly in-scope entities a transitional period to take the measures necessary to ensure compliance.
For more information on the new decree and how the changes may affect your complaint-handling procedures in Hungary, contact your CMS client partner or the CMS experts who contributed to this article.
The article was co-authored by Luca Pintér.
