1. Status of implementation
  2. National deviations
  3. Loan origination regime
  4. Regulatory guidance

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Hungary
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Status of implementation

Hungary initiated the transposition process on 14 October 2025, when draft Bill No. T/12797 was submitted to the Hungarian Parliament. The bill was accepted on 16 December 2025 in the form of Act C of 2025 on the Amendment of Laws Regarding the Financial Intermediary System (the “Implementing Act”), amending several laws including Act XVI of 2014 on Collective Investment Funds and Investment Fund Managers (Kbftv.). The AIFMD II transposition unfolds in stages: from 16 April 2026 the core framework takes effect, from 16 April 2027 enhanced regulatory reporting and certain ESAP-related requirements apply, from 10 January 2028 further ESAP-related obligations and cross-border cooperation measures come into force, and transitional provisions for legacy loan-originating AIFs expire on 16 April 2029.

National deviations

The deviations of Hungarian law from the AIFMD II text are outlined below:

  • Ancillary services and credit purchasing: Hungarian law transposes the AIFMD II additions concerning ancillary services and also permits AIFMs to perform credit-purchasing, in addition to credit-servicing, as an ancillary service, thereby expanding the domestic regulatory perimeter.
  • Substance requirements: at least two executive persons must qualify as Hungarian residents under applicable currency rules, and at least one such person must have held domestic residence for a minimum of one year.
  • Depositary requirements for AIFs: Hungarian law aligns with AIFMD II clarifications on CSD custody arrangements and third-country AML and tax-cooperation tests, but does not activate the optional cross-border depositary appointment pathway, so a Hungarian AIF’s depositary must be established in its home Member State.
  • Crypto-asset services: although not directly related to AIFMD II, the Implementing Act also permits AIFMs and UCITS management companies to provide certain authorised crypto-asset services under MiCA.

Loan origination regime

AIFMD II leaves it to the discretion of Member States to determine whether, for reasons of public interest, AIFs should be prohibited from granting loans to consumers. Hungary has exercised this option, prohibiting both Hungarian and foreign AIFs from granting consumer loans and providing consumer-credit servicing to consumers located in Hungary. However, this prohibition does not affect the marketing in Hungary of units of AIFs that are authorised to grant consumer loans in other Member States. Other requirements reflect the Directive itself, and Hungarian law does not gold-plate in this area.

Regulatory guidance

No guidance or supervisory position has been issued by the Magyar Nemzeti Bank (MNB) at this stage.