Tuesday, 7 July 2026
Hungary has adopted Act XVIII of 2026, introducing changes to anti-money laundering (AML) requirements and the regulation of alternative investment fund managers (AIFMs) as part of legislation linked to the country’s access to European Union funding.
The new law amends both Hungary’s AML legislation and the country’s Alternative Investment Fund Managers Act, expanding transparency requirements for ultimate beneficial ownership (UBO) while simplifying certain regulatory procedures for closed-ended alternative investment funds (AIFs).
Under the revised AML framework, the definition of a UBO has been broadened to include additional individuals who exercise effective control over an entity, including those holding preferential voting rights, rights to appoint board members or supervisory board members, or entitlement to at least 25% of an entity’s profits or assets.
For closed-ended AIFs, the legislation introduces additional UBO criteria covering individuals with decisive influence over investment policy, asset allocation, risk management or key governance decisions, including the ability to amend fund rules, replace the fund manager or initiate the fund’s termination. Where no individual can be identified under the new criteria, the manager of the AIFM will be treated as the UBO.
The legislation also introduces enhanced due diligence requirements for financial institutions and other regulated entities providing services to closed-ended AIFs. These institutions will be required to review fund documentation, ownership structures, capital commitments and investor bases, while assessing complex structures such as parallel funds, holding companies and cross-border investment arrangements that could obscure beneficial ownership.
The law strengthens cooperation between Hungary’s Financial Intelligence Unit and the Integrity Authority by allowing the financial intelligence authority to initiate proceedings relating to the supervision of EU-funded projects.
In addition, reporting requirements for Hungary’s UBO register have been updated for closed-ended AIFs, with the first reports under the revised framework due for September 2026. Access to the register will also be extended to additional parties, including media organisations and entities engaged in contractual negotiations with relevant legal persons or arrangements.
The amendments to Hungary’s AIFM legislation simplify several supervisory procedures. Registration of closed-ended AIFs will require additional documentation to be submitted to the National Bank of Hungary, including depositary agreements and fund rules.
However, prior approval from the National Bank of Hungary will no longer be required for amendments to the fund rules of closed-ended AIFs or for mergers by absorption where the fund rules already authorise such actions. In addition, AIFMs will no longer need prior regulatory approval to acquire qualifying holdings, a requirement that will remain applicable only to UCITS management companies.
Alternative investment fund managers must comply with the new requirements by 30 September 2026. The legislation entered into force three days after its publication in the Hungarian Official Gazette.
Source: CMS
