Hungary introduces BNPL rules under the Consumer Credit Act

Deferred payment offered by a supplier of goods or a provider of services (“BNPL”)

1. Current position

Currently, arrangements where credit is granted free of interest and without any other charges are exempt from the Act CLXII of 2009 on Consumer Loans (“Consumer Credit Act“).

However, the Hungarian Parliament has adopted an amendment to the Hungarian Consumer Credit Act transposing the Directive (EU) 2023/2225 (“Consumer Credit Directive 2“). This amendment introduces stricter rules for suppliers of goods or providers of services offering deferred payment to consumers in Hungary.

The new rules will apply from 20 November 2026.

2. What changes?

The amended Consumer Credit Act introduces BNPL-specific provisions. The contracts on deferred payment will be treated as a credit agreement (“BNPL Arrangement“) and the suppliers of goods and the providers of services offering deferred payment to consumers in Hungary will be treated as creditors (“BNPL Providers“). In most cases, BNPL Providers will be required to comply with the Consumer Credit Act, and BNPL Arrangements will fall within its scope.

3. Exemptions

The Consumer Credit Act does not apply to BNPL Arrangements in the following cases:

3.1 General BNPL exemption (excluding non-SME enterprises offering information society services)

• Applies to small, medium and large enterprises with physical stores and small and medium enterprises offering information society services.
• No third party offers credit.
• Price is paid free of interest and without any other charges.
• Late payment interest does not exceed the base rate of the National Bank of Hungary.
• Full payment within 50 days of delivery.

3.2 Online BNPL exemption (non-SME enterprises offering information society services)

• Applies to large enterprises offering information society services (e.g. e-commerce platforms, streaming platforms).
• No third party offers credit.
• Price is paid free of interest and without any other charges.
• Late payment interest does not exceed the base rate of the National Bank of Hungary.
• Full payment within 14 days of delivery.

Note: Under Consumer Credit Directive 2, the online BNPL exemption does not apply if a third party offers or purchases credit. The amended Consumer Credit Directive, however, refers only to the “offer” of credit, similarly to the general BNPL exemption. Therefore, it remains unclear whether BNPL models where a financial institution acquires the payment claim against the consumer fall under the Consumer Credit Act.

4. Who falls within the scope of the Consumer Credit Act?

Any BNPL Provider that does not meet the above exemption criteria (e.g., third-party BNPL Provider, longer repayment terms, additional fees) must comply with the Consumer Credit Act.

5. Key obligations for in-scope BNPL

• Registration: BNPL Provider must register with the National Bank of Hungary or, for telecom providers, with the National Media and Infocommunications Authority.

Exemption from registration

• Applies to small, and medium enterprises not falling under general BNPL exemption and online BNPL exemption.
• BNPL offered only as an ancillary activity for their own goods/services.
• Price is paid free of interest and without any other charges.
• Late payment interest does not exceed the base rate of the National Bank of Hungary.

Consumer protection duties:

• Provide clear and comprehensible pre-contractual information (standard form).
• Fair, clear and not misleading marketing communication.
• Include marketing warnings such as: “Caution! Borrowing money costs money.”
• Prohibit any granting of BNPL to consumers without their prior request and explicit agreement.
• Conduct creditworthiness checks based on information provided by the consumer and credit reference services.
• Ban on BNPL Arrangements as default options;
• Offer access to independent debt advisory services for consumers in financial difficulty.

• Supervision: The National Bank of Hungary or the National Media and Infocommunications Authority will maintain a public register and monitor compliance.

6. Action points

• Assess your BNPL model: If exempt, document compliance with exemption conditions.
• If in scope: Prepare for registration and implement consumer-credit processes by mid-2026.
• Third-party BNPL providers: Full compliance with the Consumer Credit Act applies.