Hungary NIS2 Transposition

National implementation of Directive (EU) 2022/2555. Covers essential and important entities in critical infrastructure. Supervised by the National Directorate General for Disaster Management.

JurisdictionHungary
CategoryCybersecurity
StatusActive
Latest development

Analysis

Hungary has fully transposed the NIS2 Directive (Directive (EU) 2022/2555) through Act LXIX of 2024 on the Cybersecurity of Hungary, in force since 1 January 2025, complemented by Government Decree 418/2024 (XII.23.) and earlier Act XXIII of 2023 on cybersecurity certification and supervision for staged implementation and registration.Act LXIX overview | CMS summary of Cybersecurity Act & Decree 418/2024 | Chambers Cybersecurity 2025 – Hungary | Lex Mundi NIS2 Hungary

Below is a structured compliance-oriented analysis tailored to NIS2 in Hungary.


Key Requirements

Hungary’s NIS2 regime is primarily set out in Act LXIX of 2024 on the Cybersecurity of Hungary (often called the 2024 Cybersecurity Act) and detailed in Government Decree 418/2024 (XII.23.) on implementation.Act LXIX overview | CMS summary of Cybersecurity Act | Chambers Cybersecurity 2025 – Hungary

Scope and Entity Classification

  • Sectoral coverage and exclusions
  • The 2024 Cybersecurity Act implements NIS2 and CER (critical entities resilience) together, creating a unified framework for critical infrastructure sectors.Eversheds NIS2 Hungary | Lex Mundi NIS2 Hungary
  • Certain sectors are excluded or handled by other EU acts, e.g. banking and financial market infrastructures (Annex I Sections 3–4 of NIS2) are handled under DORA, and classified/nuclear‑related systems fall under separate regimes.Chambers Cybersecurity 2025 – Hungary | Lex Mundi NIS2 Hungary

Registration and Designation Obligations

Cybersecurity Risk Management and Technical / Organisational Measures

Incident Reporting Duties

Supervision, Audits, and Enforcement


Compliance Challenges

Complexity of Scope and Entity Classification

Registration and Deadline Management

Integrating Risk Management and Governance

Incident Response and Reporting

Resource and Audit Burden


Implementation Best Practices

1. Structured Gap Assessment Against NIS2 and Act LXIX of 2024

2. Governance and Role Definition

  • Create a clear NIS2 governance model
  • Best practice is to assign a senior executive or committee responsible for NIS2 compliance, with formal board reporting and oversight, reflecting NIS2’s management‑body accountability.[Directive (EU) 2022/2555 – NIS2](https

Recent developments

  • — Eversheds Sutherland reports that Hungary has introduced further refinements to its NIS2 transposition regime as of January 2026, clarifying size thresholds and narrowing the scope for certain private‑sector entities, which may reduce the number of in-scope organizations and allow some to de‑register from supervision.[5] (source)
  • — Legiscope’s 2026 NIS2 Enforcement Tracker notes that Hungary is among the 23 EU Member States that have fully transposed NIS2 and has already imposed a first confirmed fine of €78,000 under its new cybersecurity regime, signaling that enforcement and audits are now operational and penalties real for non-compliance.[8] (source)
  • — CMS Hungary highlights that as of 6 January 2026, an amendment to the Hungarian Cybersecurity Act (implementing NIS2) revises the scope of entities in critical sectors, meaning some businesses may now fall outside the regime and can de‑register from the Supervisory Authority for Regulatory Affairs (SZTFH).[7] (source)
  • — CMS reports that Government Decree 418/2024, adopted on 23 December 2024, sets detailed rules for implementing Hungary’s Cybersecurity Act, including registration, supervisory procedures, and audit timelines, shaping how NIS2 obligations are applied in practice to essential and important entities.[3] (source)
  • — Hungarian Chamber of Commerce and Industry (MKIK) and the Supervisory Authority of Regulated Activities (SZTFH) proposed extending the deadline for mandatory NIS2 cybersecurity audits from 31 December 2025 to 30 June 2026, while keeping the obligation to contract with an officially registered auditor by 31 August 2025, reflecting industry concerns over capacity and readiness.[9] (source)
  • — Eversheds Sutherland notes that Hungary’s comprehensive NIS2 transposition via Act LXIX of 2024 became operational on 1 January 2025, with implementing decrees adopted in January 2025 on cybersecurity audits and annual supervisory fees, triggering immediate compliance obligations and cost impacts for in-scope entities.[5] (source)
  • — CMS details that under the Cybersecurity Act and NIS2 transposition, entities already registered with SARA as of 31 December 2024 must submit information on EU member states where they provide services by 15 February 2025 and comply with new registration, auditor contracting, and audit deadlines, significantly tightening regulatory oversight.[3] (source)
  • — NIS2-Directive.com summarizes that Act LXIX of 2024 on the Cybersecurity of Hungary, which entered into force on 1 January 2025, is the primary legislative instrument implementing NIS2, replacing earlier cybersecurity laws and creating an integrated national framework that expands scope and strengthens requirements for network and information systems security.[2] (source)
  • — CMS explains that on 20 December 2024, Hungary adopted Act LXIX of 2024 on Cybersecurity in Hungary, repealing the partial NIS2 transposition Act XXIII of 2023 and consolidating public and private sector cybersecurity obligations into a single statute, representing a major structural change in the country’s cybersecurity regulation.[3] (source)
  • — The European Commission issued a reasoned opinion to Hungary and 18 other Member States in late 2024 for failing to notify full NIS2 transposition by the 17 October 2024 deadline, increasing pressure on the Hungarian government and indirectly driving accelerated adoption of the comprehensive Cybersecurity Act later that year.[6] (source)

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