EMI license in Hungary: e-money institution (EMI) requirements (2026)

Yes. To provide electronic-money or payment services in Hungary you need authorisation as an Electronic Money Institution (EMI), supervised by the Magyar Nemzeti Bank (MNB), under the EU E-Money Directive (2009/110/EC) and the Second Payment Services Directive (PSD2).

The Magyar Nemzeti Bank (MNB).

Application and supervisory fees that vary by country (often €5,000–€25,000), plus safeguarding and audit costs.

Typically roughly 3–12 months; the regulator has up to 3 months to decide once the application is complete.

The application file centres on programme of operations listing each payment service you will provide; business plan with a three-year budget forecast; evidence of the €350,000 initial capital; governance arrangements and internal-control mechanisms; plus fit-and-proper evidence for directors and qualifying shareholders.

Incorporate in the member state and establish real local substance (registered office and part of the business conducted there). Build the application file: programme of operations, three-year business plan, governance, AML/CFT, safeguarding and security policies. The authority then assesses the file and, once authorised, you can begin operating.

Yes — an EMI authorisation passports across the whole EEA (all 27 EU states plus Norway, Iceland and Liechtenstein).

Payment Institution (PI) and Electronic Money Institution (EMI) licences are issued by the MNB under the Payment Services and Electronic Money Act (PSPA), transposing EU PSD2 and EMD2. Minimum initial capital for an EMI is HUF 100 million. A Limited Network Exemption (LNE) exists requiring only notification, not a licence, where annual transaction volumes exceed HUF 300 million.

MNB-licensed PIs and EMIs are listed in the EBA's PSD2 payment-institutions register and may passport services into other EEA states. Conversely, EEA-authorised PIs and EMIs may establish branches in Hungary via MNB notification from their home regulator.

Hungary's Azonnali Fizetési Rendszer (AFR) launched 2 March 2020 as a globally rare mandatory rollout, all domestic banks were required to offer 24/7 instant credit transfers up to HUF 20 million within 5 seconds from day one. Proxy identifiers (mobile number, email, tax ID) are supported; banks are prohibited from charging a premium for instant vs. standard transfers.

PSD2 was transposed in Hungary in 2019, mandating banks to open APIs to licensed AISPs and PISPs; however adoption has been slow, with only a handful of AISPs licenced and a single active open banking service as of 2025. PSD3 and the Payment Services Regulation (PSR) reached political agreement at EU level in November 2025, with enforcement expected mid-2026 and a 21-month transition period for member states.

BNPL currently operates in a regulatory gap in Hungary: consumer credit obligations (creditworthiness assessment, advertising rules, pre-contractual disclosures) do not apply to short-term deferred-payment products. Hungary is transposing EU CCD2, introducing BNPL-specific provisions under the Consumer Credit Act; from 20 November 2026, BNPL arrangements will be treated as regulated credit agreements and BNPL providers will require registration and must comply with consumer-credit rules.

The MNB operates an Innovation Hub and a regulatory sandbox (launched 2019) enabling fintech companies to test products in a live environment and streamline licensing. By 2024 the sandbox had supported approximately 200 projects; the MNB also publishes an annual FinTech and Digitalisation Report and maintains a publicly accessible Fintech Legal Repository.