Hungary extends regulatory framework to cover exempt investment funds and managers

On 27 June 2025, Hungary’s recently passed amendments to Act XVI of 2014 on Collective Investment Trusts and Their Managers and on the Amendment of Financial Regulations will come into force. These changes expand the supervisory powers of the National Bank of Hungary (NBH) by bringing certain investment funds, previously exempt from oversight, under its regulatory supervision.

The amendments ensure that individuals holding qualifying interests in the managers of private investment funds are subject to licensing requirements, which will allow the NBH to monitor and oversee these owners effectively.

For fund managers of private investment funds, venture capital funds, and private equity funds, changes in ownership will now be managed through fund management policies. These policies must explicitly identify individuals with qualifying interests in the fund manager and any changes related to these qualifying owners require prior approval from the NBH.

Importantly, during the NBH’s approval process, which must be completed within five business days, the updated fund management policies cannot be implemented. For all other elements of fund management policies concerning private investment funds, simple notification to the NBH will remain sufficient.

The amendments also impact mergers of private investment funds since those may also result in changes concerning the fund manager. Previously, such mergers were not subject to NBH approval if the fund manager was authorised under management policy to make the decision on the merger, or if the decision was subject to the approval of the investment unit holders holding a specified majority. Under the new rules, this exemption is removed, and NBH approval will be required for mergers that affect individuals holding qualifying interests in fund managers.

Private funds already operating before the amendment’s effective date are not exempt. They must submit their updated fund management policies to the NBH within ten business days after the new rules take effect. This submission ensures that the NBH can confirm whether qualifying owners of the fund manager have the required approval.

To comply with the updated legal framework, fund managers will need to amend the investment funds’ management policies and submit the revised policies for NBH approval in time.

For more advice on these regulatory changes, contact your regular CMS advisor or these local CMS experts.

The article was co-authored by Márton Lázár.