The pioneering era of artificial intelligence regulation in Hungary: Implementation of the EU AI act

This is Regulation 2024/1689 of the European Parliament and of the Council (commonly known as the AI Act). Hungary lays down the institutional and procedural foundations for national implementation with Act LXXV of 2025 and its enforcing Government Decree 344/2025. (X. 31.). These legal acts are intended not only to fulfil the obligation imposed on Member States by the regulation to establish an Artificial Intelligence Authority but also to develop the domestic AI ecosystem, standardize legal application, and ensure respect for fundamental rights and human autonomy.

The pillars of the domestic institutional framework

The AI Act requires the designation of Member State notifying and market surveillance authorities for the ex-ante conformity assessment and ex-post market surveillance of AI systems. The Government has designated the following organizations to perform these tasks:

Artificial Intelligence Notifying Authority (AI Notifying Authority):

The National Accreditation Authority (in Hungarian: Nemzeti Akkreditáló Hatóság) performs these tasks. Its primary duty is to assess, designate, notify, and monitor, based on accredited status, the bodies that check the conformity of high-risk AI systems.

Artificial Intelligence Market Surveillance Authority (AI Market Surveillance Authority):

The Minister responsible for enterprise development has been designated as the general market surveillance authority and the operator of the sole point of contact. The market surveillance authority has exclusive competence to investigate AI systems if the client is not considered a consumer. However, the surveillance does not extend to high-risk AI systems that are placed on the market, put into service, or used by organizations falling under the scope of the Act on the Hungarian National Bank in connection with the provision of financial services; the supervision of these systems is performed by the Hungarian National Bank (MNB).

Tools for legal application

The domestic regulatory framework establishes special provisions for AI-related procedures:

Market surveillance procedure:

The AI Market Surveillance Authority acts ex officio in market surveillance cases under the AI Act. During the procedure, the authority may impose an administrative fine, establish the unlawful application of the AI system, and call upon the person concerned to cease the unlawful conduct. The maximum amount of the fine may be a fixed HUF amount corresponding to the amounts expressed in EUR as defined in the AI Act, which is significant (e.g., HUF 13.3 billion for violating the provisions concerning prohibited AI practices)

Cooperation between authorities:

If the AI system is placed on the market or put into service in a sector for which another sectoral market surveillance authority is also responsible, the sectoral authority shall cooperate with the with the AI Market Surveillance Authority in the AI market surveillance procedure. In other cases, where the conformity of an AI system needs to be examined in a procedure of a sectoral authority (such as the National Media and Infocommunications Authority (NMHH) in its consumer protection/market surveillance procedure, or the National Authority for Data Protection and Freedom of Information (NAIH) in its data protection procedure), the expert opinion of the AI Market Surveillance Authority must be obtained.

Sectoral information: If the AI Market Surveillance Authority does not request an expert opinion from the sectoral authority, it shall also take into account the sectoral authority's information when assessing the conformity of the AI system.

AI regulatory sandbox:

The AI Market Surveillance Authority establishes and operates the AI Regulatory sandbox. Its purpose is to safely test development under real-world conditions, and for this purpose, the authority may mandate data provision and conduct inspections without prior notice.

Procedural exception:

The summary procedure (accelerated proceeding) is excluded in the procedures of both the AI Notifying and the AI Market Surveillance Authority, meaning the accelerated conduct of the procedure is not possible even if all information and evidence necessary for making the decision are available and no evidence procedure is required.

The Hungarian Artificial Intelligence Council

To ensure the uniformity of legal application, to develop the national AI strategy and policy, and to deepen the dialogue between the actors of the domestic AI ecosystem, the Hungarian Artificial Intelligence Council has been established.

The Council operates as a body without decision-making authority. It supports the Government in developing and implementing the national AI strategy and policy. Its further tasks include coordinating research, development, and innovation activities, monitoring AI applications in the public sector, cooperating in the establishment of the AI regulatory sandbox, and creating and increasing national AI literacy.

The members of the Council are persons designated by key state bodies (e.g., MNB, NMHH, GVH, NAV, NAIH), ministers, and representatives of the scientific and economic spheres (e.g., MTA, MKIK). The Council's President is appointed by the Prime Minister for a term of 5 years, upon the proposal of the Minister responsible for enterprise development and the Minister responsible for informatics. The position of the Council's President shall be filled by the Government Commissioner responsible for Artificial Intelligence for the duration of his appointment existing at the time of the law's entry into force.

By creating this legal framework, Hungary is ready for the pioneering task of implementing the EU AI Act, which presents a continuous challenge to the actors due to the rapid development of technology and the lack of experience in legal application.