New Hungarian law requires ATMs in all towns and villages

The Hungarian Parliament has passed Act XVIII of 2025 (ATM Act), which obliges payment service providers to ensure access to cash withdrawal services by installing and operating ATMs in every municipality. This law follows Hungary’s 14 April 2025 constitutional amendment that makes cash payments for transactions a constitutional right (see Law-Now Hungary’s new constitutional right to cash payment explained).

Regarding the ATM Act, the Governor of the Hungarian National Bank (MNB) will specify in a decree the specific payment service providers that will be required to operate ATMs in each municipality, and the criteria for installing and operating ATMs. The timeline for fulfilling this obligation will be set out in a decree from the Minister for National Economy.

The ATM Act may ease the burden on payment service providers by allowing joint installation and operation of ATMs, but any agreements between payment service providers must be in line with the Hungarian Competition Act. The MNB Governor will also specify the rules on cost-sharing among payment service providers in a decree.

To facilitate implementation of the ATM Act, municipal governments must provide suitable locations for ATMs free of charge and cooperate with payment service providers on establishing the necessary conditions for their installation and operation. The ATM Act also stipulates, however, that payment service providers remain obliged to fulfill ATM installation and operation requirements even if municipal governments fail to provide suitable conditions.

The specific criteria constituting suitable conditions — including requirements related to the plot on which the ATM is to be installed and technical, infrastructural, and accessibility standards — will be set out in a decree from the Minister for National Economy.

Non-compliance with the new ATM installation and operation obligations may result in fines from the MNB of between HUF 2 million and HUF 200 million. Interestingly, these fines will not become part of the MNB’s revenues, but instead will contribute directly to the central state budget. After imposing a fine, the MNB will carry out a follow-up review three months later to assess whether the payment service provider has complied. If the violation persists, the MNB will impose another fine, which will increase with each subsequent breach.

Importantly, the ATM Act elevates the provisions of existing Government Decree No. 49/2025 (III. 24.) to the level of statutory law. As a result, banks operating ATMs or offering cash withdrawal services from their branches as of 15 May 2025 will not be permitted to discontinue these services. Should a service provider violate this prohibition, the MNB can impose a fine as stated above.

In addition, the ATM Act amends Act LXXXV of 2009 on the Provision of Payment Services and changes the rules for cash withdrawal limits. Under the amended rules, the upper transaction limit for ATM cash withdrawals cannot be less than HUF 150,000 per transaction — up from the previous HUF 75,000. Despite this change, however, banks are allowed to set a lower daily withdrawal limit in the payment services agreement with customers, provided that consumers are able to raise the limit to at least HUF 150,000 on any given withdrawal day.

Installing and operating ATMs in every municipality will be a major project with significant costs to payment service providers. To ensure compliance, regulatory developments should be monitored closely, including legislation and regulations issued by the Governor of the MNB and the Minister for National Economy.

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The article was co-authored by Viktória Dorusák.