Hungary’s bespoke validation regime for crypto-asset exchanges entered into force on 27 December, making it illegal to execute crypto-to-fiat or crypto-to-crypto exchanges without a prior declaration of conformity issued by a licensed validator. The obligation stems from amendments to Hungary’s Crypto Act (Act VII of 2024) and the implementing Decree 10/2025 (X.27.) of the Supervisory Authority for Regulated Activities (SARA), which together create a new, transaction-level “validation” gatekeeper for exchanges. In parallel, Hungary has adopted criminal law provisions penalising both the provision and the use of unauthorised exchange services when validation is required, sharpening legal risk for service providers and users once the regime applies.
What “validation” means in practice
Under the framework, a crypto-asset exchange may only proceed on the basis of a compliance certificate issued by a SARA-licensed validator. The absence of a certificate renders the transaction invalid and without legal effect. The validator’s due diligence is purpose-built and goes beyond ordinary KYC/AML checks, covering at least the origin of the crypto-asset, verification of ownership of the device or wallet, identification of associated persons, a profile-based assessment of the user and checks against external databases. The Central Bank of Hungary (MNB) has flagged that validators are supervised and registered by SARA and that exchanges may only lawfully occur based on a declaration of conformity from such a registered validator. SARA’s public register of authorised validators and its guidance on Decree 10/2025 are now available to market participants for implementation and counterparty checks.
Timing, scope and exemptions
Decree 10/2025 was issued on 27 October 2025 and became applicable following the statutory lapse period – culminating in application from 27 December – prompting exchanges to announce Hungary-specific service pauses. While validation is the default rule for crypto-asset exchanges, SARA’s regime preserves targeted exemptions, for example for transfers between own wallets for personal use or activities not regularly provided for consideration, easing burdens where the risk profile is demonstrably lower.
Criminal exposure and compliance responses
Hungary’s Criminal Code now includes two crypto‑specific offences tied to the validation regime: carrying out exchange services in violation of the validation requirement and using unauthorised exchange services, with penalties scaling by transaction value. These provisions, coupled with the invalidity of non‑validated exchanges, require firms to align product flows, vendor due diligence and geofencing with the validator model, as well as monitor SARA’s register for authorised entities. In anticipation of applicability on 27 December, some platforms announced temporary suspensions for Hungarian users due to validator availability and implementation risk, underscoring that trading would resume once a compliant, scalable path is established.
Relationship to MiCA and supervisory split
The national validation layer complements the EU’s Markets in Crypto‑Assets Regulation (MiCA), which harmonises authorisation, conduct and disclosure obligations for crypto‑asset service providers EU‑wide while leaving Member States room for additional measures. In Hungary, MiCA‑related CASP licensing is overseen by the Central Bank (MNB), while the bespoke validator licensing and supervision sits with SARA, creating a dual‑track supervisory structure that firms must reflect in their compliance architecture. With the validation obligation now applicable from 27 December, market participants should verify validator status before executing exchanges, calibrate controls to the new certification step and document reliance on SARA‑listed validators in their operational workflows.
By Gergely Szaloki, Counsel, and Noemi Csiki, Associate, Wolf Theiss
