Amendments to certain BM decrees concerning medical examination related to occupational, professional and personal hygiene suitability

The Hungarian Minister of Internal Affairs has issued BM Decree No. 20/2025 (VI.26.) amending certain BM decrees concerning medical examinations of occupational, professional and personal hygiene suitability for employment (the “Decree”), which amends NM Decree No. 33/1998 (VI. 24.) on medical examinations and assessment of occupational, professional, and personal hygiene suitability (the “NM decree”), and BM Decree No. 70/2011 (XII. 30.) on the rules for the performance of occupational health and safety duties and occupational health activities of law enforcement agencies under the control of the Minister of the Interior as of 27 June 2025.

The NM decree amended by the recently passed Decree is summarised below.

1. Scope of the NM decree

The newly passed Decree has amended the scope of the NM Decree No. 33/1998 (VI. 24.) on the medical examination and assessment of occupational, professional and personal hygiene suitability regarding preliminary, periodic occupational suitability examinations and opinions. According to the amendment, the scope of the NM decree extends to, among others, employers who:

• employ employees in the context of organised work, in cases specified by law or in jobs subject to exposure as specified in the ministerial decree;
• who have decided that the employee’s fitness for work must be determined on the basis of an occupational suitability examination;
• employees performing work in Hungary or abroad who are employed by an employer referred to in the first two points listed above in the job specified therein within the framework of organised work; and
• persons entitled to benefits for persons of working age.

2. Preliminary occupational suitability examination

The Decree amends the mandatory case of conducting a preliminary occupational suitability examination, by providing that such an examination must also be carried out if, following the commencement of employment, a legal regulation or the employer’s decision requires an occupational suitability assessment to determine the employee’s suitability for work.

3. Periodic occupational suitability examination

According to the Decree, employees must participate in periodic occupational suitability examinations for, among others, the purpose of re-evaluating their occupational suitability in the following cases:

• at the employer’s discretion;
• for persons performing work domestically or abroad, employed by an employer, in a position defined by law, in the framework of an organised employment scheme; and
• persons entitled to benefits for active age.

An employee exposed to biological agents is also included in the scope of the compulsory periodic occupational suitability examination.

4. Employment of minors

After the Decree enters into force, no annual monitoring X-ray examination can be carried out for those under the age of 18 years, neither as part of the preliminary nor periodic occupational suitability examination.

5. Key positions and tests to be performed

The Decree further amends the scope of examinations to be carried out in the cases of positions and activities of epidemiological interest. Additionally, the range of physical and chemical causal factors whose exposure necessitates periodic occupational suitability examinations has been amended.

For more information on how this Decree may affect your Hungary-based business, contact your CMS client partner or these CMS experts.

The article was co-authored by Viktor Kovács.