Hungary
Licensing and registration
Regulatory background
The Hungarian legal framework governing electromobility services is quite detailed and well defined, even to the point of rigidity and inflexibility in certain aspects. The below pieces of legislation define the distinct roles of charging point operators (CPOs) and electromobility service providers (EMSPs), set conditions for licensing and registration, and introduce a system of accountability and potential sanctions:
- Act I of 1988 on Transportation (“Transportation Act”),
- Gov. Decree No. 243/2019 on certain aspects of electromobility services (“E-mobility Decree”),
- Act LXXXVI of 2007 on electric energy (“Hungarian Electricity Act”) and
- Gov. Decree No. 273/2007 on the implementation of certain provisions of the Hungarian Electricity Act (“Implementation Decree of the Hungarian Electricity Act”).
What is the scope of application?
Major stakeholders and their roles in the EV value chain in Hungary are:
- CPOs: operate public EV charging equipment, carry out its technical operation and maintenance, provide electromobility services to electromobility users, and ensure the technical conditions for the provision of such services to EMSPs.
- EMSPs are persons, who may provide electromobility services to electromobility users on the basis of a contract with a CPO.
- electromobility users (customers) are persons who use electromobility services in a long-term legal relationship with at least one CPO or EMSP or as ad-hoc charging.
A CPO may operate EV charging points and provide e-mobility service at the same time or may pull in one or more EMSPs to provide the e-mobility service through the CPO’s EV charging points. Even is a CPO teams up with an EMSP, the CPO must remain able to provide ad-hoc charging. The only restriction is that transmission system operators (“TSO”) and distribution system operators (“DSO”) cannot operate public EV charging stations.
Additionally, the regulatory framework extends to all service providers offering electromobility services in Hungary, regardless of whether the service is provided under a long-term contract or on an ad hoc basis. It also applies to any legal or natural person entering into business relationships involving the provision or resale of such services.
As part of this legal structure, all entities participating in the electromobility ecosystem are required to comply with registration or licensing obligations, maintain direct contractual chains.
What are the requirements?
CPOs may operate public electric charging equipment only if they hold a valid operating licence issued by the Hungarian Energy and Public Utility Regulatory Authority (“HEPURA”). The licence must be requested at least 75 days before the planned start of operations. Once issued, the operator has 18 months to install the charging equipment; otherwise, the licence expires for that equipment. If there are changes involving 20 or more chargers (e.g., number, type, or performance), this must also be reported to the HEPURA at least 75 days in advance. Minor deflections from the permit shall only be reported to the HEPURA, but in case of major alterations (i.e., change of the type of more than 20 charging points) the operating licence itself will have to be amended as well. The licence is granted for an indefinite period, provided the applicant meets the applicable legal and technical conditions set out in the foregoing regulations, especially the Hungarian Electricity Act and the Implementation Decree of the Hungarian Electricity Act.
In case CPOs choose to engage an EMSP, the HEPURA registers the EMSP indicated by the CPO in the application for the operating licence. The EMSP and CPO must establish a formal contractual relationship, because they share responsibility for ensuring continuous access to charging services for end users.
Providing e-mobility service is not subject to an operation licence, only to a prior registration. Therefore, EMSPs may commence operations only after completing a formal notification procedure and being registered by the HEPURA. This notification must be submitted at least 75 days before service begins and must include proof of a contractual relationship with a licenced CPO. The involvement of sub-EMSPs or intermediaries in the contractual chain is not permitted. Within the Hungarian regulatory framework, EMSPs must conclude a contract with the CPO and a separate agreement with the end user.
Further, it is the EMSPs’ (or if the CPO itself provides the e-mobility service, the CPO’s) duty to prepare and disclose its GTC, the geolocation of the charging station, the real-time occupancy data and the expiry date of the validity of the measuring instrument on its website with the following information indicated in a clearly visible manner: (i) performance and type of the charging station and type of available plugs; and (iii) the fee payable.
Also, telephone or personal consumer support service shall be ensured for the consumers for the whole so-called uptime period, which means a 24/7, non-stop duty for EMSPs.
EMSPs and CPOs are free to define the terms and conditions of pricing and accounting among them in their mandatory agreement. Nevertheless, invoices between CPO and EMSP as well as invoices sent to end users must comply with the detailed statutory requirements.
Charging fees may be determined (i) on the basis of the charging station’s type (AC/DC); or (ii) taking into consideration the usage time or the energy filled in; or (iii) on the basis of both of the above; or (iv) any other pricing methodology, provided that, in each case, the pricing is rational, easily and clearly comparable, transparent and non-discriminative. Idling fees may be applied on a per minute basis.
Who enforces the regulations?
In addition to its licensing and registration duties, the HEPURA is responsible for supervising compliance with the legal framework applicable to electromobility services. This includes the review of operational practices, the accuracy of data management for billing purposes, and the lawful structuring of contractual relationships between market participants.
Where the HEPURA identifies a breach, it must assess whether the infringement has been remedied prior to determining the appropriate regulatory response. Sanctions may escalate depending on the severity and persistence of the non-compliance. The HEPURA is required to first issue a warning and/or impose a fine. The maximum fine for non-compliance is either 1% of the operator’s previous year’s net revenue from the licenced activity or HUF 100 million, whichever is higher. Only if the infringement remains unresolved may the HEPURA restrict the business’s activities for up to 12 months. Finally, the HEPURA may revoke the CPO license or the EMSP registration.
Although the legal tools for enforcement are available, the current administrative practice suggests that sanctions have thus far been applied primarily in cases involving general licencing issues outside the electromobility context.
To support transparency and enable due diligence, the HEPURA maintains a publicly accessible registry of licenced CPOs and registered EMSPs. This database serves as a key reference point for verifying the compliance status of prospective business partners.
EMSPs and CPOs must pay a supervision fee to HEPURA of 0.085% of the annual net turnover resulting from their CPO and EMSP activities.
Key commercial considerations
Regulatory background
The contractual, pricing, and liability environment of electromobility services in Hungary is governed primarily by the Transportation Act and the E-mobility Decree.
In addition, Act V of 2013 on the Hungarian civil code (“Hungarian Civil Code”) reinforces these obligations by requiring parties to act in good faith and with due diligence when entering into contracts. Act CLV of 1997 on the protection of consumer rights (“Consumer Protection Act”) and Act XLVII of 2008 on the prohibition of unfair business-to-consumer commercial practices (“Unfair B2C Practices Act”) aim to ensure that consumers are granted transparent, accessible, and fair conditions when purchasing goods or services, including the right to clear information, effective complaint handling, and legal remedies in case of disputes.
What is the scope of application?
The foregoing regulations apply to any person or entity involved in providing or operating public electric charging services or related commercial arrangements. This includes both CPOs and EMSPs. While licensing and registration conditions are addressed elsewhere, it is important to note that both CPOs and EMSPs must maintain direct contractual relationships with the electromobility user and/or each other, depending on their role in the service chain.
These legal requirements also govern the substance of commercial agreements, as well as the permissible scope of terms and conditions offered to electromobility users, which must comply with rules on consumer rights, language, and pricing transparency.
What are the requirements?
In Hungary, all contracts and general terms and conditions (“GTCs”) applicable to electromobility services provided for consumers must comply with the Consumer Protection Act, the Unfair B2C Practices Act, the Hungarian Civil Code and other administrative laws. These documents must be made available in Hungarian, contain country-specific provisions, including especially references to the Hungarian Civil Code, Hungarian arbitration bodies and consumer withdrawal rights.
Pricing and surcharges are also subject to regulatory oversight. In the event of a pricing discrepancy, the Consumer Protection Act mandates that the lower price must be charged. Accordingly, contracts should clearly define which party bears financial responsibility for such discrepancies.
Regarding data protection, all relevant documents must reflect the guidance and decisions issued by the Hungarian Data Protection Authority (“NAIH”). This includes clearly defined purposes for data processing, applicable legal bases, categories of personal data collected, and retention periods. Each processing purpose must be explicitly matched with its legal basis and retention time. Privacy notices must also disclose whether geolocation data is used, describe the conditions of international data transfers, and inform users of their rights under the GDPR and relevant Hungarian implementing decrees. Marketing activities require prior and specific user consent. Data transfer provisions must explain how safeguards are applied and how users can access them.
Who enforces the regulations?
Regulatory enforcement in this context falls within the competence of the following authorities:
- HEPURA monitors compliance with operational and commercial obligations, including contract structure and pricing transparency (see further above at Licensing and registration).
- The Government Office and, in cases where a larger audience and thus competition is affected, the Hungarian Competition Authority (GVH) control consumer protection aspects.
- NAIH oversees compliance with data protection and privacy regulations.
No Roaming - shortcomings of the rigid regulatory environment
Regulatory background
The Hungarian legal regime strictly regulates the provision of public electromobility services and does not permit sub-contracting or the use of intermediaries (sub-CPOs or sub-EMSPs). The underlying regulatory structure is defined in the Transportation Act and in the E-mobility Decree and is further reinforced by the Hungarian Electricity Act.
What is the scope of application?
These regulatory requirements apply to both domestic and cross-border electromobility services. The legal framework is structured to ensure that all market participants, whether based in Hungary or abroad, operate under the same core principles: only registered entities may provide services, and each party must maintain compliance with national licencing and contracting rules.
While technical intermediaries (such as roaming platforms) may support access and system integration, they are excluded from the legal relationships involved in service provision.
What are the main requirements?
The application of inbound and outbound roaming is quite limited in Hungary. The Hungarian laws require that the EMSP must be formally registered in Hungary with the HEPURA, which includes notification and data provision obligations. Once registered, the EMSP must have a direct contractual relationship with end customers and the relevant CPO. Hungarian legislation does not permit any deviation from this regulatory structure. Consequently, the contractual chain is limited to three stakeholders: CPO, EMSP and end-customer, so no sub-CPOs or sub-EMSPs are allowed. This significantly reduces the flexibility of the system to handle roaming and platform aggregation.
The key challenge under this regime is that roaming arrangements common in other EU markets must be adapted to comply with Hungarian regulatory requirements. As a result, foreign market participants must undertake registration, localisation of contracts and documentation, and implement bilateral commercial relationships to lawfully access the Hungarian electromobility market. Any model relying on indirect service provision is incompatible with the legal definitions of EMSP and CPO roles and would likely be rejected by the HEPURA in an audit or compliance review.
Who enforces the regulations?
HEPURA is the competent authority to monitor compliance with regulations relating to roaming restrictions. See HEPURA powers above at Licenses and registration.
To date, there were no published cases in which the HEPURA conducted an official inspection or imposed sanctions on a legal entity specifically for illegal roaming or non-compliance with electromobility service regulations. However, in other cases, in which a business did not have any authorisation to conduct services subject to authorisation or the business provided services that were outside the scope of its authorisation, the HEPURA imposed fines ranging from HUF 500,000 to 8,000,000 (approximately EUR 1,300 to 20,000) on the sanctioned business.
Charging point installation requirements
Regulatory background
The regulatory framework governing the installation of electric charging points in Hungary is primarily established by Gov. Decree No. 176/2008 on the energy performance certification of buildings (“ÉKM Decree”).
As of 1 January 2025, a new Gov. Decree No. 280/2024 on the fundamental regulation of settlement planning and building requirements (“TÉKA”) is in force which details the mandatory installation requirements for public charging stations.
What is the scope of application?
The relevant provisions apply to a wide range of non-residential buildings and associated parking facilities, with obligations triggered based on factors such as building function, parking capacity, and construction or renovation timelines.
The obligations are technology-neutral and ownership-agnostic: compliance is required regardless of whether the parking is owned, leased, or jointly managed. This allows for flexible implementation models, particularly in multi-tenant or mixed-use sites, provided that basic technical and legal conditions are met.
What are the main requirements?
The installation of EV charging points must comply with the spatial, legal and infrastructure requirements set out in the foregoing applicable regulatory framework. This obligation does not always rest solely with the owner of the property operating the building. In certain cases, it may be fulfilled by another entity on an adjacent property, provided the installation serves the original building’s needs.
Current regulations are unclear whether charging points must be located on the legally defined property of the obliged entity or if compliance may lawfully occur through cooperation with neighbouring land users, facilitated by use agreements or amended leases. Such a delegated model awaits explicit endorsement by the competent authorities, but a legislative amendment would be most welcome in this respect.
In addition to the structural principles above, the TÉKA introduces specific quantitative obligations for different property types:
- for new parking lots at retail stores selling daily consumer goods, at least four charging points must be installed per every 100 parking spaces.
- for existing parking lots at such stores, at least two charging points are required if the store’s net floor area exceeds 300 m².
- no installation is required for retail properties under 300 m² or for stores not classified as selling daily consumer goods.
- in settlements with fewer than 20,000 inhabitants, stores under 1,500 m² are granted a grace period until 1 January 2026; and
- paid parking facilities, such as parking garages and underground car parks, are also subject to the 4-per-100 requirement, with a similar transition deadline of 1 January 2026 for existing structures.
Crucially, under the TÉKA, at least 5% of all charging spaces - but no fewer than one - must be designed for barrier-free use, ensuring accessibility for users with reduced mobility.
It is important to note that the TÉKA sets minimum national standards, but local building regulations may impose stricter obligations. Developers and operators should therefore verify whether municipal regulations introduce additional requirements beyond those established at the national level.
All public charging stations must offer at least one connector compatible with Combo 2 (CCS Type 2), even if other formats (e.g. CHAdeMO or Tesla Supercharger) are also provided. Charging points must visibly display connector type labels, as mandated by EU harmonisation rules.
Additionally, national energy regulations permit the installation of charging infrastructure on private electrical networks, subject to legal and technical compliance. A private network may be extended without a licence if confined to a single building. However, supplying multiple users or buildings requires notification and contractual arrangements with the competent DSO. In large-scale developments such as logistics hubs or commercial parks, compliance may require coordination between developers, private network owners, DSOs, and tenants. In such cases, separate metering systems or secondary transformers may be necessary to ensure lawful operation and proper cost allocation.
Who enforces the regulation?
Enforcement of the charging point installation obligations rests with the competent building authority and the Ministry of Energy. These authorities are empowered to verify whether the installation conditions have been met by the relevant compliance deadline. Failure to comply may result in administrative sanctions, including potential limitations on occupancy or usage permits. However, due to the relatively recent nature of the applicable provisions, there is limited case law or administrative practice on the enforcement of these specific obligations. To mitigate risk, businesses are advised to document agreements between property users clearly and proactively engage with the competent authority in cases where property boundaries or operational control complicate direct compliance.
Support schemes
Regulatory background
Support schemes such as the rural charging infrastructure programme published under No. RRF-REP-10.14.1-24 in 2024, while administered through separate funding legislation and EU recovery funds, presume conformity with the regulatory system.
What is the scope of application?
Support schemes in Hungary targeting electromobility are designed to accelerate the deployment of public charging infrastructure outside the capital and major urban centres. The current EU Recovery and Resilience Facility-funded (“RFF”) rural charging development scheme explicitly limits eligibility to entities already holding a CPO licence from the HEPURA.
The scheme applies to CPOs which are entitled to receive either financial support or concessional loans. Network licence holders, however, are excluded from participating, mirroring the licensing limitations applicable to service provision.
The programme expressly prioritises localities with currently insufficient charging coverage, thereby aligning with state objectives to balance infrastructure distribution and reduce range anxiety in rural mobility. It is not sufficient to merely hold a licence or registration; eligible applicants must also commit to installing chargers in areas designated as development-priority zones, as defined in the call for applications.
As such, while EMSPs are critical operational partners in the electromobility ecosystem, they are not direct beneficiaries of these support schemes unless they also qualify as licenced CPOs or participate through consortium structures in compliance with the applicable regulations. EMSPs may, however, indirectly benefit from the expansion of the charging network through increased service reach and transaction volume.
What are the main requirements?
From a financial standpoint, support is offered primarily in the form of preferential loans ranging from HUF 100 million to HUF 4 billion, with a maximum term of 15 years. An own contribution of at least 10% is mandatory. Additionally, non-repayable components are also available under specific circumstances - most notably, where the project involves integration of renewable energy sources or energy storage units into the charging infrastructure. The intensity of support varies by enterprise size: large companies may receive up to 35%, medium-sized up to 55%, and small or microenterprises up to 65% of eligible costs.
The application process requires detailed project documentation, including the technical specifications of the charging stations, location data confirming the site’s rural character or its designation as a development-priority area, and evidence of compliance with all relevant licensing and safety standards. Furthermore, CPOs are obliged to ensure data interoperability and accurate billing transmission, and such obligations extend to supported installations. The same decree mandates that operational accounting and reporting tasks be fulfilled, and this requirement applies identically to subsidised projects.
A distinguishing feature of the current (third) funding round, open for applications between 12 and 20 May 2025, is the explicit administrative aim of reducing application complexity and increasing uptake. The deadline for submitting loan applications has been extended to 30 June 2025, and the final date for signing loan agreements is now end of January 2026, instead of the originally planned May and December deadlines.
Lastly, all beneficiaries must commit to maintaining the funded infrastructure for a specified minimum operational period and must agree to monitoring by the grantor authorities. Projects involving subcontracted CPO or EMSP functions are explicitly ineligible for support and may result in grant revocation or contract annulment under Hungarian Civil Code.
Who enforces the regulation?
The enforcement of the legal requirements applicable to beneficiaries falls within the jurisdiction of the body granting the funds and – where energy-related obligations are concerned - the HEPURA may also have a regulatory or oversight role.
Recipients of public support are subject to additional obligations under the terms of the funding agreement. These may include financial clawback clauses in case of non-compliance, and oversight mechanisms such as reporting obligations or site inspections. Where support was granted based on misrepresentation or in violation of the statutory service chain structure (e.g., through subcontracting with unlicenced partners), the contract may be void or voidable under civil law, and restitution may be required.
Finally, it is important to note that, administrative and civil enforcement mechanisms are cumulative. Breach of funding rules may result in simultaneous regulatory penalties from the HEPURA and financial penalties, repayment of funds or exclusion from future funding by the granting body.
