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

The European Accessibility Act was transposed in Hungary by 2022. évi XVII. törvény (Act XVII of 2022), promulgated on 22 July 2022 and in force since 28 June 2025, together with its implementing decree, 605/2022. (XII. 28.) Korm. rendelet. It covers electronic communications, audiovisual media access services, air, bus, rail and water passenger transport, retail banking, electronic books and e-commerce sold to consumers in Hungary. Transposition was late. Hungary missed the EU deadline of 28 June 2022, and the decree that names the enforcing authorities followed only in December 2022.

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National law 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 20 July 2022 the Commission sent letters of formal notice to 24 Member States over EAA transposition. Only Estonia, Italy and Denmark had notified by then, which places Hungary in that group, though we could not source a Commission document naming Hungary.
Web standard 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. The current European version is EN 301 549 V3.2.1 of March 2021, carrying the WCAG 2.1 level A and AA success criteria. Conforma tests against WCAG 2.2 AA and EN 301 549, which covers the WCAG 2.1 AA floor.
Enforcement 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.

Who has to comply in Hungary

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.

The deadlines that matter

28 June 2022

EU deadline for Member States to transpose the EAA. Hungary had not adopted its transposing act by this date

19 July 2022

The Országgyűlés adopts Act XVII of 2022, transposing Directive (EU) 2019/882

20 July 2022

The Commission sends letters of formal notice to 24 Member States for not communicating full transposition of the EAA

22 July 2022

Act XVII of 2022 is promulgated

28 December 2022

605/2022. (XII. 28.) Korm. rendelet is published, designating the inspection authorities and setting the fine amounts

28 June 2025

The Act and the decree enter into force. Products placed on the market and services newly provided from this date have to comply

28 June 2027

Requirements on answering emergency communications to 112 start to apply under section 12(5) of the Act

28 June 2030

Outer limit for services continued under contracts concluded before 28 June 2025

WCAG 2.2 AA, EN 301 549

Prove your Hungary compliance

Conforma tests your site against WCAG 2.2 AA and EN 301 549, the reference behind MSZ EN 301 549, and keeps a dated record of every issue found and every fix applied. It drafts an accessibility statement for the Hungarian market citing 2022. évi XVII. törvény. What you get is testing and evidence. Conforma does not issue a certificate of compliance, and automated testing cannot cover every requirement on its own.

Hungary EAA questions, answered

When did the EAA start to apply in Hungary, and is there a transition period?

Act XVII of 2022 and 605/2022. (XII. 28.) Korm. rendelet both came into force on 28 June 2025, so products placed on the Hungarian market and services newly provided from that date have to comply. Section 12(2) leaves service contracts concluded before that date untouched until they expire, and in any case no later than 28 June 2030. Section 12(3) lets self-service terminals that were already in lawful use stay in use to the end of their economically useful life, and for no more than 20 years from when they were put into use. Requirements on answering emergency communications to 112 apply from 28 June 2027.

Is my small business exempt?

A mikrovállalkozás that provides services is exempt from the accessibility requirements. The threshold is the same across the EU and both parts have to be met: fewer than 10 employees AND annual net turnover or balance sheet total of no more than the forint equivalent of EUR 2 million. Cross either one and the obligations apply. The exemption is for services. If you manufacture, import or distribute a covered product, size does not exempt you.

Which accessibility standard does my website have to meet in Hungary?

The Hungarian Act names no standard. It relies on the harmonised standards mechanism of Regulation (EU) No 1025/2012, and no harmonised standard has been cited in the Official Journal for the EAA so far, so there is no formal presumption of conformity to rely on. For digital accessibility the working reference is EN 301 549, adopted in Hungary as MSZ EN 301 549. Version V3.2.1 carries the WCAG 2.1 level A and AA success criteria. Building to WCAG 2.2 AA meets that floor and leaves room for the next revision.

Who enforces the rules and what are the penalties?

It depends on the sector. E-commerce and electronic books go to the fogyasztóvédelmi hatóság, meaning the Nemzeti Kereskedelmi és Fogyasztóvédelmi Hatóság and the county and Budapest government offices. Electronic communications and audiovisual media access go to the Nemzeti Média- és Hírközlési Hatóság Hivatala, and retail banking to the Magyar Nemzeti Bank. The authority issues a warning and agrees a deadline first. If the operator does not cooperate or misses the deadline, section 9 of 605/2022. (XII. 28.) Korm. rendelet sets a közigazgatási bírság of HUF 15,000 up to HUF 500,000, or up to 5 percent of annual net turnover and at most HUF 500 million for an operator with turnover above HUF 100 million that is outside the SME act.

This page is a plain-English summary, not legal advice. Check the cited national law for specifics.

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