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Expected legislation on the horizon

Reading time: 4 minutes

The Government has submitted its legislative programme for the period extending until the end of 2026 to the Parliament, from which it is already becoming apparent which regulatory areas are expected to undergo significant changes in the near future.

The document contains a total of 83 proposals, the most important of which are summarised below.

Labour law proposals

Pay transparency

In the field of labour law, a particularly significant initiative is the draft legislation on pay transparency between men and women, which aims to transpose Directive (EU) 2023/970 of the European Parliament and of the Council of 10 May 2023 to strengthen the application of the principle of equal pay for equal work or work of equal value between men and women through pay transparency and enforcement mechanisms (“Pay Transparency Directive”) into national law. The proposed regulation is expected to impose substantial new obligations on employers, particularly in relation to the transparency of remuneration systems, the provision of information to employees, and regular data reporting requirements. The amendments aim to reduce the gender pay gap and to ensure more effective enforcement of the principle of equal pay for equal work. The adoption of the draft legislation is expected to take place in October 2026.

Platform-work

The transposition of the regulation of platform-based employment also serves to fulfil an EU legal harmonisation obligation is, which aims to improve and make more predictable the working conditions of labour performed through digital platforms. The Directive (EU) 2024/2831 on improving working conditions in platform work (“Platform Work Directive”) sets 2 December 2026 as the final deadline for transposition by Member States. In line with this, the Hungarian legislative process is expected to conclude earlier, as the adoption of the relevant national legislation is anticipated for October 2026.

Occupational safety and health

In the field of occupational safety and health, several forthcoming changes are also taking shape. The planned amendments related to the implementation of Regulation (EU) 2023/1230 of the European Parliament and of the Council on machinery and repealing Directive 2006/42/EC of the European Parliament and of the Council and Council Directive 73/361/EEC (“Machinery Regulation”), primarily aim to modernise the safety and health requirements applicable to machinery, with particular regard to the use of new technologies, including artificial intelligence.

Corporate law proposals

In the area of company law, amendments to Act V of 2006 on Public Company Information, Company Registration and Winding-up Proceedings (“Ctv.”) are expected. Among other things, the proposal would introduce shorter deadlines for registering changes and conducting proceedings at the court of registry and would extend the application of certain EU regulations to general partnerships and limited partnerships. The proposal would also simplify administrative procedures related to cross-border operations, for example by abolishing the apostille requirement within the European Union and introducing an EU company certificate.

In this context, a further bill is also expected to be submitted to postpone the entry into force of Act LIX of 2025 on the Register of Legal Entities, as well as Act LX of 2025 on certain court proceedings relating to legal entities and winding-up proceedings. The postponement is primarily justified by delays in the development and readiness of the IT systems required for the implementation of the new regulatory framework.

Commercial law proposal

In the area of commercial law, changes to regulations governing foreign direct investment are expected. The planned changes aim to enhance the competitiveness of the investment environment and make the regulatory framework more investor-friendly, with regard to the energy sector. In this context, restrictions on transactions affecting the ownership structure of strategically important companies operating solar power plants are also expected to be abolished.

Digital state-related proposal

In connection with the development of the digital state, a review and amendment of Act CIII of 2023 on the digital state and certain rules on the provision of digital services (“Dáptv.”) and the related implementing decrees is expected. The proposed amendments would introduce clarifications and improvements based on practical experience, with particular regard to the functioning of electronic administration and e-government services.

Review of acts relating to the administration of justice

Finally, several amendments to legislation affecting the operation of the judicial system are also expected, in particular Act XLI of 1991 on Notaries Public, Act XLIX of 1991 Bankruptcy Proceedings and Liquidation Proceedings (“Cstv.”), and Act LIII of 1994 on Judicial Enforcement (“Vht.”). The purpose of these amendments is to implement the corrections necessitated by a review of the existing regulatory frameworks.

Summary

Our firm continuously monitors developments and submitted proposals, and where appropriate provides Clients with detailed updates on their content. Should you have any questions regarding the above, please do not hesitate to contact us.

Photo source: pexels.com, Efrem Efre 

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The cessation of AVDH and the related tasks of companies

Reading time: 4 minutes

Electronic administration has undergone significant changes in recent years with the introduction of the Digitális Állampolgári Program (DÁP). The previously widely used document authentication (AVDH) has been phased out and is now completely obsolete. Given that this has a significant impact on the way individuals and companies conduct their electronic administration (e.g. ePapír administration, either as individuals or through the Company Gate), we outline below the essence of the changes, the parties affected and the practical steps to be taken.

AVDH in brief

AVDH was previously a free document authentication solution available to all users with a client gate. It was a widely applicable, easily accessible and simple to use service, and was also considered suitable for corporate signatures. Documents authenticated with AVDH were considered private documents with full probative force, so they could be used in a wide range of procedures and administrative processes.

The general availability of AVDH ended at the end of last year, so it could only be used in a limited scope, integrated into the ePapír service. This meant that when individuals and companies submitted documents to government agencies (e.g. to the labour authority) via ePapír, they could authenticate their submissions and attachments with AVDH, thus eliminating the need for electronic signatures.

Changes in November

On 31stOctober 2025, the AVDH service was completely discontinued (i.e. in official procedures as well). It was replaced by a service for user document assignment (FEDOR) with significantly reduced functions, starting from 1 November 2025.

However, FEDOR does not provide nearly all the features of its predecessor. The FEDOR service does not replace the signature, but only assigns it to the individual, so it does not result in a fully probative private document. However, for an electronic document to be considered authentic, it must at least have the probative value of a private document (and an electronic time stamp).

Necessary steps

Given that authentic electronic documents must be submitted during electronic administration, authorities currently ask clients to resubmit the appropriate documents in cases where the documents do not qualify as private documents with full probative value.

Under current legislation, documents bearing a qualified electronic signature or an advanced electronic signature based on a qualified certificate are considered private documents with full probative value, so the documents to be submitted must be signed with one of these.

In order to ensure that the company’s communication with authorities does not become impossible, we know that many companies have quickly opted for a qualified electronic signature provided by a Hungarian trusted service provider. However, it is important to note that choosing the right partner in the long term opens up many more opportunities for digitisation.

Practical options

Private individuals have access to the eAláírás function provided by DÁP, which is considered a qualified electronic signature. However, it is important to note that this can only be used by private individuals, i.e. the DÁP eAláírás function is not suitable for corporate signatures under the provisions of the law, so business organisations will have to look for other solutions.

Qualified electronic signatures and advanced signatures based on qualified certificates can only be provided by so-called trust service providers. It is important to note that this is regulated at European Union level, which means that such services can be used not only from the three providers registered in Hungary, but also from providers registered in any EU Member State, as Member States are obliged to accept them. In Hungary, the National Media and Infocommunications Authority (NMHH) is the competent supervisory authority, which maintains this register, and the list of registered service providers can be found here. Service providers registered in the various EU Member States can be accessed via the following link.

It is also important to note that it is, of course, possible to act through an authorised representative (e.g. a private individual, accountant, legal representative) in electronic procedures, in which case the authorised representative must have the appropriate signature.

Summary

With the complete discontinuation of the previously widely used AVDH service, an appropriate electronic signature is required to use the ePapír service.

Although this may initially be perceived as a burden by those affected, electronic signatures can be used in a much wider range of applications and can practically replace the role of previous paper-based signatures entirely. Electronic signatures may, of course, entail additional costs, but it should also be noted that their use reduces several other costs (e.g. paper, printing, postage, courier and travel costs). Given that there are several types of electronic signatures, which result in different types of documents with varying degrees of evidential value, and that they can be used in a wide range of situations (e.g. company procedures, employment relationships, official notifications), it is definitely advisable to consider the purpose and scope of use when selecting a specific service (signature type). In our practice, we have assisted numerous group of companies with their digital transition, and we can clearly state that companies choose different service providers based on their varying priorities (e.g., mass document uploading, document management, a wide range of signatories, signatures that can be provided to employees by their employer, cost).

Photo source: pexels.com, Karola G.

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