Information security has become a strategic priority for organizations across Europe, and Hungary is no exception. With the transposition of the EU’s Network and Information Security Directive 2 (NIS 2) into local law and the ongoing emphasis on data protection under GDPR, Hungarian entities must navigate both the international ISO 27001:2022 framework and a suite of national overlays.
In this article, I will outline Hungary‐specific requirements, explain how organizations build and maintain an Information Security Management System (ISMS) that satisfies local regulators, explore the impact on businesses, and distill key takeaways for security leaders preparing for the next audit cycle.
Country-specific requirements for ISO 27001 in Hungary
Hungary retains the global ISO 27001:2022 standard as its core, but adds a series of country-specific modules and legal mandates. These overlays ensure that certification aligns with national accreditation, cybersecurity legislation, and sectoral decrees.
PRO TIP
Before you engage a certification body, download the NAH public register and filter for MSZ ISO/IEC 27001:2023 auditors with “NIS 2” experience. Pre-selecting three candidates saves weeks of vetting and reduces scope-creep over Hungarian crypto/logging add-ons.
Accreditation and national standard adoption
Organizations seeking an ISO 27001 certificate in Hungary must use a certification body accredited by the Nemzeti Akkreditáló Hatóság (NAH). Certificates from non-NAH bodies—even if they carry international IAF-MLA links—are frequently rejected in public tenders and by regulatory authorities. Since September 1, 2024, all new and transition audits must reference MSZ ISO/IEC 27001:2023, the official Hungarian translation of the 2022 edition. Contracts and audit reports cite Hungarian clause numbering and terminology.
NIS 2 transposition and security classes
Act LXIX of 2024 on Cybersecurity, supported by Government Decree 418/2024 (XII. 23.), implements NIS 2 obligations for “essential” and “important” entities as of January 1, 2025. An ISO 27001 certificate confers a presumption of conformity provided the Statement of Applicability (SoA) lists every control required by the Act. The law introduces a three-tier security-class system—Basic, Significant, and High—each mapped to 121 concrete controls detailed in Ministerial Decree 7/2024 (VI. 24.). Hungarian crypto requirements and logging standards augment the baseline ISO 27002:2022 guidance.
Legacy and sector-specific mandates
Public-sector bodies and municipalities continue to follow Act L of 2013 on Electronic Information Security plus Government Decree 271/2018, maintaining four historic security classes and biennial risk analyses. Critical‐infrastructure operators (energy, finance, transport, water) comply with a chain of sectoral decrees referring to ISO 27001 Annex A plus bespoke controls.
Telecommunications providers under Act C of 2003 and NMHH rule-book must align policies with ISO 27001 clauses 4–10, undergo triennial external audits, and file annual security reports. Financial institutions follow Magyar Nemzeti Bank Recommendations 8/2020 and 12/2020, citing ISO 27001 as “state-of-the-art,” and feed clause 9 KPIs into yearly ICT-risk and upcoming DORA dashboards.
| Area | Hungarian requirement | Difference from ISO 27001 |
| Accreditation of Certificates | NAH-accredited bodies only | International certifiers without IAF-MLA link often rejected |
| National Standard Adoption | MSZ ISO/IEC 27001:2023 mandatory since 1 Sep 2024 | Contracts use Hungarian clause citations |
| NIS 2 Transposition | Act LXIX/2024 + Gov. Decree 418/2024 (1 Jan 2025) | Adds 3 security classes; presumption if SoA covers all controls |
| Security-Class Details | MK Decree 7/2024 (VI.24.) | Maps 121 controls; includes Hungarian crypto/logging rules |
| Public-Sector ISMS | Act L/2013 + Gov. Decree 271/2018 | Four legacy classes; biennial risk analysis |
| Critical-Infrastructure Operators | Sector-chain: 65/2013 → 330/2015 → 374/2020 | Annex A baseline + sector controls |
| Telecommunications | Act C/2003 + NMHH rule-book (2020 EECC package) | Policies aligned to clauses 4–10; triennial audits |
| Financial Services | MNB Recommendations 8/2020 & 12/2020; DORA from Jan 2025 | Clause 9 KPIs feed ICT-risk report and DORA |
| Cyber-Maturity Tool | NKI “Kibervédelmi követelmény-katalógus” guide (2024) | 40 controls one-to-one with ISO 27001 |
| Data-Protection Interplay | GDPR + NAIH guidance treating ISO 27001 as “state-of-the-art” safeguards | Valid cert reduces fine calculations |
How organizations implement ISO 27001 in Hungary
Building an ISMS that satisfies both ISO 27001 and Hungary-specific mandates requires strategic layering, early cross-mapping, and synchronized audit cycles.
Strategic overlay selection
You begin with the plain ISO 27001:2022 core—ideal for export markets—and then bolt on additional modules as needed. If your organization falls under NIS 2, you incorporate Act LXIX and its decree. Municipalities and public bodies maintain their existing Act L/2013 cycle. Sectoral operators add CIP, telecommunications, or financial controls on top.
Early cross-mapping and documentation
Preparing a cross-reference matrix—linking ISO 27001 clauses with Act LXIX, MK 7/2024, Act L/2013, NMHH, and MNB/DORA requirements—ensures clarity in the SoA. Auditors from NAH, supervisors at the National Cyber Security Authority (SARA), and NMHH will request this matrix during audits and inspections.
Use of Hungarian artefacts and bilingual policies
Risk assessments, incident response run-books, and filings under Law 5160 (Act LXIX) must be in Hungarian. Maintaining bilingual policy and procedure documents accelerates both domestic compliance and foreign audits, reducing translation lags.
Synchronizing audit and reporting cycles
Aligning multiple audit cadences into a single schedule minimizes redundant work.
| Framework | Mandatory cadence | Alignment tip |
| ISO 27001 | 3-year recertification + annual surveillance | Bundle year-2 surveillance with the first Law LXIX external cyber audit |
| Law LXIX (NIS 2) | External audit ≥ every 2 years + quarterly KPI | Reuse ISO 27001 internal-audit minutes and clause 9 dashboards |
| Act L/2013 + Decree 271/2018 | ISMS audit every 2 years | Merge with Law LXIX audit where possible |
| NMHH Telecom | Full audit every 3 years + annual report | Generate report directly from ISO 27001 metrics |
| MNB / DORA | ICT-risk report yearly | Feed raw KPIs from the same dashboard |
PRO TIP
Tag your SIEM alerts and vulnerability-scan outputs with regulator labels (“NIS2,” “NMHH,” “MNB”). Configure automated quarterly CSV exports for each label—so your GRC tool regenerates all four reports in one click.
Automation for “comply once, report many”
By tagging vulnerability scanners, SIEM dashboards, and KPI tools against multiple compliance requirements, you create a single evidence store. This approach allows you to populate ISO 27001 metrics, NIS 2 KPIs, NMHH reports, and MNB/DORA templates with minimal manual intervention.
Impact on businesses adopting ISO 27001 in Hungary
The decision to pursue ISO 27001 certification in Hungary yields tangible advantages across procurement, regulation, supply-chain confidence, funding, and operational resilience.
| Impact Area | Practical Effect |
| Tender Eligibility | Government cloud services and most public RFPs mandate ISO 27001 (often with ISO 27017/18) and NAH accreditation |
| Regulatory Shield | ISO 27001 serves as “state-of-the-art” proof under GDPR Art 32, NIS 2, NMHH telecom rules, and MNB guidelines |
| Supply-Chain Trust | Large corporates verify certificates in the NAH register; vendor-risk questionnaires are reduced by ~50 % |
| Insurance & EU Funding | Cyber-insurers offer lower deductibles; Hungarian RRF and Horizon grants award extra points to ISO-certified projects |
| Operational Resilience | The continual-improvement loop aligns with NIS 2 incident SLAs, NMHH outage reporting, and MNB stress tests |
PRO TIP
Track two metrics monthly—“public tenders won” and “audit findings closed”—and plot them alongside your ISMS roadmap. Present this simple dashboard to executives to demonstrate how certification activities directly drive new business and reduce risk.
Key takeaways for Hungarian security leaders
Building a resilient ISMS in Hungary means thinking modularly: start with one ISO 27001:2022 core, then append Law LXIX, Act L/2013, NMHH, MNB, or sector CIP controls as required. Staying within the NAH accreditation umbrella is essential to avoid tender rejections and regulatory pushback.
By tagging and automating evidence collection, you can “collect once and report everywhere,” feeding multiple regulators with the same data set. Finally, with the first full Law LXIX audit window closing on December 31, 2027, a mapped ISMS today positions you at least 80 % of the way toward readiness before auditors arrive.
Simplify Hungarian ISMS with CyberUpgrade
CyberUpgrade cuts through Hungary’s patchwork of ISO 27001:2022, NIS 2, NMHH, MNB, and legacy public-sector mandates by centralizing your control mappings into one unified SoA. Automated, bilingual evidence tagging feeds SIEM logs and KPI dashboards directly into every regulator’s portal—so you comply with Act LXIX, MSZ ISO/IEC 27001:2023, and sector-specific decrees without juggling spreadsheets or missing deadlines.
Real-time compliance prompts in Slack or Teams guide your team through 24 h/72 h incident-reporting workflows and quarterly KPI filings, while a shared risk-register lake auto-populates ISO surveillance, NIS 2 audits, telecom security reports, and ICT-risk dashboards. This “collect once, report everywhere” approach slashes up to 80 % of manual compliance effort, prevents audit fatigue, and keeps you audit-ready year-round.
With fractional CISO support, you tailor your ISMS annexes—from critical-infrastructure OT measures to financial-sector KPIs—without the cost of a full-time hire. As an EU-informed, Hungary-ready solution, CyberUpgrade accelerates public-sector tender success, lowers insurance premiums, and transforms compliance from a burden into a competitive advantage.
Ahead to 2027: Securing Hungary’s digital future
As Hungary’s cybersecurity landscape evolves under NIS 2 and sectoral mandates, your ISMS must not only comply but also anticipate emerging requirements. By architecting a unified framework that adapts to new controls and streamlines reporting, you will ensure that your organization remains secure, competitive, and audit-ready well into the next audit cycle.
