Hungary registers first crypto-asset conversion validation service provider
Hungary’s Supervisory Authority for Regulatory Affairs (SZTFH) has registered Caduceus Zrt. as its first crypto-asset conversion validation service provider.
A crypto-asset service provider (CASP), which targets Hungarian users, must engage a crypto-asset conversion validation service provider in addition to holding a valid licence under the EU Markets in Crypto-Assets Act (Regulation (EU) 2023/1114 – MiCA).
The following article summarises what this means for CASPs intent on providing services to Hungarian users.
Hungarian crypto-asset conversion validation regime
Since 27 December 2025, crypto traders are required to exchange crypto-assets for funds or other crypto-assets only on the basis of a compliance statement issued by a crypto-asset conversion validation service provider. Exceptions include exchanges provided without consideration or on an irregular basis.
From 1 January 2026, all exchanges undertaken without the compliance statement constitute a criminal offence.
This additional regulatory burden applies in parallel to MiCA licencing provisions. Previously, due to the lack of registered service providers in Hungary, many prominent CASPs cautiously restricted or suspended Hungarian activities. For these CASPs and their users, this news is a welcome development, and potentially the first step in resuming Hungarian operations.
Crypto-asset conversion validation offered by the first service provider
Validation is a risk-analysis service based on on-chain data, which serves to identify and assess compliance and AML risks related to crypto asset transactions. Validation complements but does not replace the following CASP protections – Know Your Customer (KYC), Anti-Money Laundering (AML), Source of Funds (SOF) and Source of Wealth (SOW) obligations and processes.
A CASP remains fully liable for its decision to execute a transaction.
The validator analyses blockchain transaction history and network patterns associated with specified crypto asset addresses and provides a risk assessment (i.e. acceptable risk, requires increased attention or high risk). Validation may include backward tracing, forward tracing, cluster analysis (e.g. co-spending, change-address, service-pattern, time-pattern, fee/gas-patterns) and comparison with external risk databases (e.g. hack, scam, mixer, darknet, sanction, high-risk exchange etc.).
The base fee for validation is HUF 5,000 (approximately EUR 13) plus VAT per transaction. Typical fulfilment times range from three minutes (in the case of simple backward tracing) to 48 hours (for complex and full risk assessments). Discounted pricing, custom package offers, querying via Application Programming Interface (API) and expedited validation are also available under individual contracts.
It remains unclear whether newly registered service providers with no prior experience or references in crypto-asset conversion validation possess the necessary organisational and technical means to fulfil their duties in practice and at scale.
Next steps
CASPs wishing to offer crypto services to Hungarian users are advised to contact one of the registered crypto-asset conversion validation service providers.
To carry out the validation, the systems of the new validation service provider will likely need to be interconnected with the systems of CASPs. At present, no public information is available on the technical characteristics of this integration or connection, or on the time, workload or cost requirements required.
The full list of crypto-asset conversion validation service provider registered with the SZTFH is available here.
Currently, the list contains only one service provider – Caduceus Zrt. Other service providers are expected to register with the SZTFH and thus CASPs will have a wider range of options to choose from.
For details on the Hungarian crypto-asset conversion validation regime, please see our prior Law-Now articles: Hungary criminalises unauthorised crypto-asset exchanges and Hungary clarifies regime for validating crypto-asset conversions.
For information and assistance on your contractual negotiations with crypto-asset conversion validation service providers, contact your CMS client partner or the CMS experts who contributed to this article.
The article was co-authored by János Bálint.
