I’m excited to guide you through the EU’s new Markets in Crypto-Assets Regulation (MiCA) and its impact on Hungary. You’ve likely heard that MiCA aims to unify crypto rules across Europe, but what does that mean for your operations in Hungary?
In this article, I’ll walk you through the local legal framework, licensing process, and the milestones you need to hit to keep your crypto venture on the right side of regulators.
Overview of MiCA and its direct applicability in hungary
Let’s break down MiCA’s timeline and how Hungary plugged it into local law. The EU’s MiCA (EU) 2023/1114 became directly applicable on December 30, 2024, filling gaps in existing financial-instruments legislation for crypto-assets.
Hungary had already passed its Crypto-Assets Act (Act VII of 2023) in mid-2023, designating the Magyar Nemzeti Bank (MNB) as the sole authority overseeing licences, supervision, and enforcement under MiCA.
PRO TIP
Compare the EU text on EUR-Lex with Act VII to spot any procedural tweaks—early awareness of local deviations saves time during your application.
Competent authority and national framework
In Hungary, the MNB wears two hats: central bank and MiCA supervisor. It grants or revokes authorisations for Crypto-Asset Service Providers (CASPs), monitors compliance with prudential and conduct rules, and keeps a public registry of authorised firms.
You’ll also see consumer-protection warnings issued against unauthorised providers, so maintaining an active listing is non-negotiable.
PRO TIP
Before you queue up your dossier, lock in a pre-application meeting with the MNB. Aligning on dossier layout and fee expectations up front slashes review cycles later.
Licensing requirements for CASPs
You need a MiCA authorisation under Article 62 if you “professionally provide” any crypto service in Hungary. That covers everything from centralised exchanges and alternative trading systems, to custodial wallets, crypto-fiat conversion, portfolio advice, and issuance or redemption of asset-referenced tokens (ARTs) and e-money tokens (EMTs).
Application dossier and prudential criteria
Your licence application has to hit every checklist item. Think of it as assembling a “regulatory LEGO” set—miss a piece, and the tower wobbles.
| Requirement | What You Need |
| Program of Activities | A clear business model outline: services you’ll offer, your target markets, and any EU passporting plans. |
| Governance & Fit & Proper | An org chart naming your governing body, compliance officer, and risk manager, plus “fit & proper” attestations for senior staff. |
| Risk Management & AML/KYC | Transaction-monitoring systems, customer due diligence, and suspicious-activity reporting, including MiCA’s Travel Rule and Hungarian AML rules. |
| Technical & Operational Resilience | ICT architecture diagrams, cybersecurity controls, recent penetration-test reports, and business-continuity/disaster-recovery plans. |
| Capital & Financial Resources | Tiered minimum own funds (€50 000–€150 000), client-asset segregation protocols, and cold-wallet insurance for custodial services. |
| White Paper & Disclosure (ART/EMT) | Standardised token prospectus with details on rights, fees, governance, redemption, and risk factors. |
| Supporting Documentation | Legal incorporation proof, audited financial statements, and professional-indemnity insurance certificates. |
PRO TIP
Kick off your penetration tests and continuity drills at least six months before submission. Regulators want to see recent, hands-on resilience exercises, not maps of future intentions.
Transitional regime and key deadlines
Hungary’s 12-month transition window is a sprint compared to MiCA’s usual 18 months. If you were operating under the old framework, you’ve got until July 1, 2025, to apply—or you’ll need to pause services.
Any new service launched after December 30, 2024, requires full MiCA clearance from day one.
| Date | Milestone |
| June 30, 2024 | ART/EMT provisions under MiCA become effective. |
| December 30, 2024 | Full MiCA CASP regime enters force; all new crypto-asset services need authorisation. |
| July 1, 2025 | Deadline for existing Virtual Asset Service Providers (VASPs) to file applications or cease operations. |
PRO TIP
Reverse-engineer your project plan from July 1, 2025—factor in internal reviews, external audits, and regulator feedback to avoid a last-minute sprint.
What crypto firms in Hungary need to know
MiCA compliance isn’t just an exercise in paperwork—it demands real operational muscle. You’ll need a bona fide Hungarian presence (office, local management, active operations) ready for on-site MNB inspections.
Your AML/CFT program must fold in MiCA’s enhanced Travel Rule, with crystal-clear policies for transaction monitoring and reporting. Governance needs a dedicated compliance officer and documented conflict-of-interest policies.
Think of infrastructure resilience like a digital vault with multiple locks—regular penetration tests, redundant ICT setups, and rehearsed incident-response plans are mandatory. For capital planning, budget for minimum own funds, supervisory fees, and custodial insurance.
And remember: a Hungarian MiCA licence gives you EU passporting rights—just notify MNB of your cross-border plans. Slip up, and you’re facing fines up to 5 % of turnover or €5 million, plus local sanctions.
PRO TIP
Run mock inspections with an external auditor to stress-test your transaction-monitoring and incident-response playbooks—real-world drills reveal hidden gaps faster than tabletop exercises.
Practical next steps
Now, let’s turn strategy into action. Start with a gap analysis: map your existing AML/KYC, governance, and ICT resilience against MiCA and Act VII. Next, build your authorisation dossier—draft your program of activities, governance framework, AML/CFT manuals, ICT schematics, financial forecasts, and token white papers. Book those pre-application meetings with the MNB to fine-tune submission details.
Train your teams on breach-notification duties and passporting procedures. Finally, commit to a monthly regulatory watch by tracking ESMA’s delegated acts and MNB circulars, so you never get blindsided by technical updates.
PRO TIP
Set up a shared “RegWatch” Slack channel for the team—summaries of ESMA and MNB updates keep everyone in the loop without clogging inboxes.
Streamline MiCA compliance with CyberUpgrade
Meeting MiCA’s rigorous requirements—from whitepaper filings to ongoing governance and transparency—often means endless manual tracking and audit prep. CyberUpgrade automates your MiCA workflows with prebuilt templates and real-time Slack or Teams prompts, keeping policies, risk assessments, and evidence audit-ready in one central hub.
Beyond MiCA, CyberUpgrade also supports DORA, ISO 27001, and NIS 2 frameworks, letting you “map once, prove many” across multiple regulations. Automated data extraction, vulnerability scans, and KPI dashboards feed each regulator’s portal seamlessly, reducing manual work by up to 80 %.
With fractional CISO services guiding your continuous monitoring and customizable compliance workflows, you’ll secure faster approvals, avoid fines, and adapt as MiCA and related frameworks evolve—turning compliance from a hurdle into a strategic advantage.
Ready to turn MiCA into your competitive edge?
MiCA compliance is more than a box-ticking exercise; it’s your chance to stand out with top-tier governance, rock-solid resilience, and customer trust. CyberUpgrade is here to help you navigate this journey—reach out if you’ve got questions, or let’s chat about how you can leverage your Hungarian licence for seamless EU market access.
