On 11 June 2025, the Hungarian parliament passed legislation widening the scope of corporate criminal liability as part of the transposition into Hungarian law of Directive 2024/1226 on the definition of criminal offences and penalties for the violation of EU restrictive measures. Most of these changes go beyond the scope of the Directive, however, and will apply to all criminal offences, not just violating sanctions. The following article is an overview of the most important provisions in this new legislation.
Changes to the Criminal Code and the Code of Criminal Procedure
Under the Hungarian Criminal Code, it is already an offence to violate sanctions, such as violating the freezing of funds or economic resources and economic, trade or financial prohibitions. The new legislation introduces additional and more detailed prohibitions on the conclusion of transactions, conduct of activities and providing services with or to natural and legal persons subject to EU sanctions, the violation of export licences, assisting with entry into, exit from or transit through Hungary, and violating reporting or data provision obligations.
Following a change to the Code of Criminal Procedure, covert intelligence gathering subject to permission of a judge may be employed against intentional perpetrators of violations of international economic restrictions. The covert intelligence gathering subject to permission of a judge are secret surveillance of an information system, secret search, secret surveillance of a locality, secret interception of a consignment and interception of communications.
Changes to the Corporate Criminal Code
With this amendment to the Corporate Criminal Code, the commission of an intentional criminal offence will no longer be a condition for the application of criminal measures against companies. Theoretically, the new legislation will allow for corporations to be sanctioned if the criminal offence results in financial benefits for the company or was committed by way of using company resources even if the crime is deemed negligent. According to the amendment, it will be sufficient if the company executive “was unaware, through negligence, that a criminal offence was being prepared or committed by a member or employee of the company and therefore failed to take the necessary measures to prevent the commission of the offence”.
Interestingly, corruption offences have been highlighted among the crimes that may serve as grounds for imposing penalties on corporations. Since authorities will be required to consider extending the scope of investigations to include corporate entities in cases, it is anticipated that the amended Corporate Criminal Code will trigger a significant increase in proceedings against companies.
The maximum fine that can be imposed on a company will be 5% of its turnover in the year preceding the commission of the offence. Currently, the maximum fine is three times the value of the financial gain achieved or intended to be achieved by the criminal offence, but not less than HUF 780,000 (approximately EUR 1,930).
Although some of these changes to the Corporate Criminal Code are influenced by the provisions of the Directive, the amendments of the Corporate Criminal Code will remain applicable to all criminal offences, not just to the violations of international economic restrictions.
Summary and next steps
These changes will significantly impact how sanctions and trade compliance matters are addressed. Companies must act now to review and, where necessary, overhaul their compliance frameworks to ensure they are robust, adequate, and in line with the new legal environment. Failure to do so could expose companies and individuals to substantial legal, financial, and reputational consequences. Companies should carefully assess their current approach to sanctions, anti-corruption and trade compliance in order to align with the updated requirements.
Following the Hungarian President’s signature, the new legislation is expected to be published in the Official Journal. Changes to the Criminal Code and the Code of Criminal Procedure will enter into force on 1 September 2025. Changes to the Corporate Criminal Code will go into effect on 1 January 2026.
The full text of the new legislation is available here (only in Hungarian).
Background of the Directive
The Directive defines certain conduct as criminal offences when committed intentionally and in violation of EU restrictive measures or the national implementing provisions. The Directive also prescribes minimum penalties applicable to natural and legal persons in breach of EU sanctions.
The full text of the Directive can be viewed here. See our previous summary of the Directive here. And stay tuned for Law-Now’s upcoming article, which will explore changes to Hungary’s Corporate Criminal Code in detail.
For more information on how these changes could impact your Hungarian business, contact your CMS client partner or these CMS experts.
The article was co-authored by János Bálint.
Social Media cookies collect information about you sharing information from our website via social media tools, or analytics to understand your browsing between social media tools or our Social Media campaigns and our own websites. We do this to optimise the mix of channels to provide you with our content. Details concerning the tools in use are in our Privacy Notice.