European Accessibility Act Compliance in Hungary (Act XVII of 2022)

The Act applies to economic operators that place covered products on the Hungarian market or provide covered services to consumers in Hungary. Section 1(2) lists electronic communications services, audiovisual media access services, air, bus, rail and water passenger transport services, lakossági banki szolgáltatások (retail banking services), electronic books and their dedicated software, and e-commerce services.

A mikrovállalkozás that provides services is exempt. The Act sets the threshold in the same terms as the rest of the EU: fewer than 10 employees AND annual net turnover or balance sheet total of no more than the forint equivalent of EUR 2 million. Both have to be met. The exemption covers services only, so a micro-enterprise that manufactures, imports or distributes a covered product still has to comply.

Section 12(1) also leaves out time-based media and office file formats published before 28 June 2025 and archived content not edited after it. Public sector websites and mobile applications sit under a separate law, 2018. évi LXXV. törvény, which transposes Directive (EU) 2016/2102 and does not apply to private businesses under the EAA.

2022. évi XVII. törvény a termékekre és a szolgáltatásokra vonatkozó akadálymentességi követelményeknek való megfelelés általános szabályairól (Act XVII of 2022 on the general rules of compliance with accessibility requirements for products and services). The Országgyűlés adopted it at its sitting of 19 July 2022, it was promulgated on 22 July 2022, and it entered into force on 28 June 2025. Its harmonisation clause states that the Act serves compliance with Directive (EU) 2019/882. It is implemented by 605/2022. (XII. 28.) Korm. rendelet, the government decree on the implementation of Act XVII of 2022, published on 28 December 2022 and in force from the same date of 28 June 2025.

Transposition was late. The EU deadline was 28 June 2022, the Act was promulgated three and a half weeks later, and the decree naming the authorities and the fines followed six months after that. On 19 July 2022 the Commission sent letters of formal notice to 24 Member States over EAA transposition. Hungary was one of them, in case INFR(2022)0307, and the Commission closed that case on 11 December 2025.

Act XVII of 2022 does not name a technical standard. It works through the harmonised standards mechanism of Regulation (EU) No 1025/2012, under which conformity with a harmonised standard cited in the Official Journal carries a presumption of conformity. For the EAA that citation has not happened yet. The Commission's harmonised standards index carries an entry for websites and mobile applications of public sector bodies and none for Directive (EU) 2019/882, so that presumption is not available in practice today.

EN 301 549 is the technical reference used anyway, adopted in Hungary as MSZ EN 301 549, and 2018. évi LXXV. törvény names MSZ EN 301 549:2015 for the separate public sector regime. EN 301 549 V3.2.1 of March 2021 carries the WCAG 2.1 level A and AA success criteria. EN 301 549 V4.1.1, which adopts WCAG 2.2 AA, was published on 2 September 2026 and is not yet cited in the Official Journal. Conforma tests against WCAG 2.2 AA, which covers the web criteria of both versions.

Enforcement is split by sector. Section 1 of 605/2022. (XII. 28.) Korm. rendelet designates an ellenőrző hatóság (inspection authority) for each group of products and services. E-commerce services and electronic books go to the fogyasztóvédelmi hatóság (consumer protection authority). Since 1 January 2025, under 326/2024. (XI. 14.) Korm. rendelet, that role is held by the Nemzeti Kereskedelmi és Fogyasztóvédelmi Hatóság (NKFH, National Trade and Consumer Protection Authority) together with the county and Budapest government offices.

Electronic communications and audiovisual media access services go to the Nemzeti Média- és Hírközlési Hatóság Hivatala, the Office of the NMHH. The Magyar Nemzeti Bank is the inspection authority for lakossági banki szolgáltatások (retail banking services) and for payment acceptance terminals and cash machines, while other payment terminals stay with the consumer protection authority. Passenger transport goes to the aviation, bus, rail and shipping authorities by mode.

Under section 8(6) of the Act a consumer may bring proceedings before the inspection authority or before a court to have the accessibility requirements enforced, and an ordinary consumer dispute can also go to a békéltető testület (conciliation board).

On penalties, section 8(3) has the authority issue a warning and agree a deadline for dealing with what the inspection found. Only if the operator does not cooperate or misses that deadline does section 8(4) require a közigazgatási bírság (administrative fine). Section 9 of the decree sets that fine from HUF 15,000 up to HUF 500,000 for most operators. For an operator with annual net turnover above HUF 100 million that falls outside the Hungarian act on small and medium-sized enterprises, the ceiling is 5 percent of annual net turnover and at most HUF 500 million.