Hungary - AI Regulation Implementation (344/2025)

Overview

Government Decree 344/2025 (X.31.) implements the domestic procedural and institutional arrangements necessary to apply the EU Artificial Intelligence Regulation ((EU) 2024/1689) in Hungary under Act LXXV of 2025. The Decree designates the Nemzeti Akkreditáló Hatóság as the national notifying authority and the minister responsible for enterprise development as the national market surveillance authority and single point of contact; it establishes reporting duties, designation procedures for conformity-assessment organisations, market surveillance powers and sanctioning rules. Full official text and related Act are published in the National Legislation Database; see 344/2025. (X. 31.) Korm. rendelet - Nemzeti Jogszabálytár and the underlying Act at 2025. évi LXXV. törvény. The Decree aligns Hungarian practice with the EU legal framework available at Regulation (EU) 2024/1689 (EUR-Lex).

Definitions

The Decree adopts and incorporates definitions used in the EU Regulation and in Act LXXV/2025 (mi‑system, provider, deployer, high‑risk AI system, general‑purpose models, conformity assessment, notified body). For the purposes of national procedures the Decree clarifies: 'MI bejelentő hatóság' = the national notifying authority (Nemzeti Akkreditáló Hatóság), 'MI piacfelügyeleti hatóság' = market surveillance authority (minister responsible for enterprise development), 'Tanács' = Magyar Mesterséges Intelligencia Tanács (the Hungarian AI Council), as well as procedural terms (designation, accreditation, reporting deadlines, administrative fine).

Governance and Institutional Framework

The Decree assigns specific institutional roles and reporting lines to implement the EU Regulation domestically. It designates the Nemzeti Akkreditáló Hatóság as the notifying authority responsible for designating conformity assessment bodies for high‑risk AI systems and for monitoring their suitability in line with accreditation decisions. It designates the minister responsible for enterprise development as the AI market surveillance authority and single contact point for EU cooperation and reporting. The Decree establishes the Hungarian AI Council as an advisory forum of ministers, agencies and public institutions to support uniform law‑application and national policy design; the Council's membership and functions are set out in the underlying Act and repeated in the Decree. For source text see Decree 344/2025 (NJT) and the Act at 2025. évi LXXV. törvény. These assignments are intended to integrate existing national accreditation, product safety and sectoral oversight systems with the AI-specific enforcement environment.

Key Focus Areas

The Decree concentrates on five practical implementation priorities: (1) designation and oversight of conformity‑assessment organisations (only accredited bodies meeting statutory criteria may be designated), (2) market surveillance mechanisms and powers to investigate, suspend and require remedial action for non‑compliant AI systems, (3) reporting and transparency obligations for designated bodies and national authorities (annual reports, incident reporting), (4) sanctions and administrative fines (the Decree maps EU euro‑denominated maxima into explicit HUF ceilings and prescribes payment deadlines), and (5) coordination across sectoral regulators and the Hungarian AI Council to ensure harmonised national practice. The Decree references existing laws governing accreditation and conformity assessment to ensure consistent sanctioning and appeals processes, and requires designated conformity assessment bodies to submit annual activity reports (with enumerated content) to the notifying authority by January 31 each year.

Implementation Framework

Operationally, the Decree establishes: application and documentation requirements for designation (proof of accredited status and supporting accreditation decision); the framework for periodic review of designations (linked to accreditation validity); mandatory reporting formats and timelines for notified bodies; the legal basis and process for withdrawing a designation where accreditation is revoked; and procedural interaction between the notifying authority and market surveillance authority in individual cases. It also instructs that the notifying authority will apply sanctioning tools in accordance with the conformity‑assessment and accreditation statutes where appropriate (including use of sanctions available under the 2009 CXXXIII. Act on conformity‑assessment organisations and the implementing government decree). The Decree further clarifies that market surveillance proceedings will follow domestic administrative procedure rules and product market surveillance legislation where relevant.

Monitoring and Evaluation

The Decree requires the notifying authority and the market surveillance authority to report at least annually to the Government and to the Hungarian AI Council on enforcement activity, designation decisions, market surveillance outcomes and national experience with AI systems. Designated conformity‑assessment bodies must provide an annual report by January 31 containing the scope of activities, the number and type of conformity assessments conducted, cooperating organisations, and any complaints received. The Decree foresees data collection, aggregation and periodic publication of non‑confidential enforcement and oversight statistics to support transparency and policy review.

Penalties, Liability, and Appeals

The Decree transposes the EU Regulation's sanction framework into national practice by fixing HUF ceilings corresponding to the EU's euro maxima for administrative fines and by prescribing payment procedures (the fine shall be established in forints and paid to the market surveillance authority within 30 days). It specifies the legal basis for remedial measures, suspension or prohibition orders and for withdrawal of designations. Sanctions and fines are to be applied by the market surveillance authority and follow existing administrative procedural guarantees, with rights of appeal under Hungarian administrative law. The relevant fine maxima in forints are set out in the Decree and reflect the EU categories for breaches of the AI Regulation (provided in the Decree as explicit HUF amounts); see the full text at NJT 344/2025.

Relationship to Other Instruments

The Decree cross‑references and relies upon multiple existing Hungarian laws and EU instruments: Act LXXV/2025 (the implementing Act), the national accreditation statute (2009 CXXXIII. law), the product market surveillance act (2012 LXXXVIII. law), and the EU Regulation (EU) 2024/1689. Where sectoral laws designate a sectoral market surveillance authority (for example in finance or health), the Decree preserves sectoral competence and foresees cooperation and information exchange between the AI market surveillance authority and competent sectoral regulators. In this way it acts as an integrating instrument, aligning EU obligations and domestic institutional arrangements.

International Alignment

The Decree explicitly aligns Hungarian implementing arrangements with the EU Artificial Intelligence Regulation ((EU) 2024/1689) and the broader New Legislative Framework (including references to Regulation (EC) No 765/2008 and Decision No 768/2008/EC). It establishes the Hungarian single point of contact for the EU AI Office and requires annual reporting and cooperation with EU counterparts. The Decree also instructs national authorities to follow EU guidance and to coordinate with other Member States’ notifying and market surveillance authorities to ensure consistent cross‑border enforcement and market supervision; the EU text is available at EUR-Lex.

Implementation Timeline

Sources and References