Thursday, 16 July 2026
Hungary has adopted amendments to the Investment Firms Act implementing the EU Listing Act, introducing new rules governing the preparation, labelling and payment of investment research. The changes, which enter into force on 18 July 2026, affect investment firms, research providers and issuers commissioning or distributing research.
One of the key changes is the replacement of the term “investment analysis” with “investment research”, aligning Hungarian legislation with the terminology used under the EU market abuse framework. Investment firms are expected to review internal policies, research templates, client disclosures, disclaimers and marketing materials to ensure the updated terminology is used consistently.
The amendments also establish a general standard requiring investment research prepared by investment firms or third parties to be fair, clear and not misleading. Where the conditions of Commission Delegated Regulation (EU) 2017/565 are met, research must be identified as investment research or by a similar designation, requiring firms to distinguish more clearly between research, market commentary and promotional material.
The legislation introduces a regulated framework for issuer-sponsored research. Research funded wholly or partly by an issuer may only be described as issuer-sponsored research if it complies with the EU Code of Conduct for issuer-sponsored research. Investment firms producing or distributing such research will need procedures to verify and document compliance with the Code.
Issuer-funded material that does not meet the Code’s requirements must instead be treated as marketing communication, making the distinction important for both labelling and the regulatory obligations governing its distribution.
The amendments also assign issuers responsibility for submitting issuer-sponsored research to the Hungarian supervisory authority, which will act as the national collection body for the European Single Access Point (ESAP). Issuers must also provide metadata confirming compliance with the EU Code of Conduct. Although issuer-sponsored research will not be classified as regulated information under capital markets legislation or as investment research under the Investment Firms Act, it remains subject to labelling requirements, Code compliance obligations and supervisory oversight.
The new rules also provide greater flexibility in the way firms pay for third-party research. Investment firms may purchase research together with execution services or pay for it separately. Where research and execution are bundled, agreements with research providers must identify the proportion of costs attributable to investment research. Firms must also disclose their payment model to clients and carry out at least annual assessments of the quality, usefulness and value of research, including its contribution to investment decision-making. Where research is purchased separately, it must be financed either from the firm’s own resources or through a dedicated research payment account.
Certain services are excluded from the definition of investment research, including trading commentary directly linked to the execution of financial instrument transactions and other personalised trade advisory services. However, these communications may still be subject to other regulatory requirements relating to investment advice, marketing or client protection.
Investment firms will also be required to maintain records of all identifiable costs relating to third-party research and provide this information to clients on request each year. Firms may therefore need to review whether existing systems adequately capture research-related costs, particularly where research is purchased alongside execution services.
The amendments strengthen supervisory powers as well. Where issuer-sponsored research prepared or distributed by an investment firm does not comply with the EU Code of Conduct, the Hungarian supervisory authority may suspend its distribution and issue a public warning.
Following public consultation, which concluded on 2 June 2026, the new research-related provisions will take effect on 18 July 2026. Market participants are expected to review their research policies, issuer-sponsored research procedures, payment arrangements, client disclosures and record-keeping processes ahead of implementation.
Source: CMS
