The Hungarian Parliament has passed Act XXXVIII of 2026 on the Repeal of Certain Statutory Provisions Concerning Crypto-Asset Conversion Services, abolishing the crypto-asset conversion validation obligation and its associated criminal sanctions, which went into force on 7 August 2026.
The Act reversed the regime introduced in 2025, removing the requirement for crypto-asset conversions to be certified by an authorised validation service provider.
The following article explores the impact of these changes.
No more mandatory validation of crypto-asset conversion transactions
The Act makes extensive amendments to the Hungarian Crypto Markets Act, repealing the relevant definitions, core validation obligation, dedicated procedural subtitles and enforcement provisions. As a result of these amendments, no validation will be obligatory for any crypto-to-crypto or crypto-to-fiat conversion.
Decriminalisation
The Act amends the Hungarian Criminal Code by repealing the offences of “Abuse of crypto-assets” and “Unauthorised crypto-asset exchange service provision”. Engaging in crypto-asset conversions without a declaration of conformity no longer carries criminal liability for the service provider or users.
SARA’s crypto-related supervisory powers ends
The Act also amends the Supervisory Authority for Regulatory Affairs (SARA) Act by repealing SARA’s authority to license and supervise crypto-asset conversion validation service providers. By 12 August 2026, SARA was obliged to terminate all ongoing licensing and supervisory proceedings relating to the validation of crypto-asset conversion services ex officio and validation service providers. SARA was also ordered to irrecoverably delete all data collected in connection with crypto-asset conversions and unauthorised crypto transactions.
Practical impact
The Act’s preamble identifies two bases for the repeal.
First, the validation requirement constitutes a restriction on competition and is incompatible with the EU’s internal market. Second, the uniform regulatory framework established by the EU in Crypto-Assets Regulation already ensured that customers could access crypto-asset services in a safe, transparent and traceable manner, making the additional national validation layer redundant.
For market participants, the Act signals a clear policy reversal. Because the Act entered into force on 7 August 2026, entities that have undertaken the gap analysis and required compliance investment are no longer required to maintain this infrastructure for validation purposes.
Payment institutions, crypto-asset service providers and intermediaries that have in-scope conversions routed to authorised validators should now unwind those processes.
For more information on the Act and crypto-currency regulations in Hungary, contact your CMS client partner or the CMS experts who wrote this article.
The article was co-authored by János Bálint and Péter Virányi.
