During the holiday season, the Hungarian legislation was extremely active, with several hundred pages of Hungarian Gazette publications resulting in numerous legislative amendments. In this context, in our extraordinary newsletter at the beginning of the year, we briefly summarize the changes in the fields of labour law and corporate law that have entered into force at the beginning of the year or are expected to enter into force in the near future, and which, we believe, may significantly affect the operations of our Clients.
Changes affecting the minimum wage
First and foremost, it is important to note that on 23 December the Government promulgated Government Decree No. 426/2025 (XII. 23.) on the determination of the minimum wage and the guaranteed minimum wage. Pursuant to this decree, in 2026 the monthly minimum wage for full-time employees will increase from HUF 290,800 to HUF 322,800, while the guaranteed minimum wage will increase from HUF 348,800 to HUF 373,200.
Changes related to simplified employment
The provisions of Act LXXV of 2010 on simplified employment (“Simplified Employment Act”) relating to seasonal agricultural work have become more favorable in light of the change that came into force on 1 January 2026.
According to the amendment, the annual employment period (120 days) of workers employed in seasonal agricultural work may be extended by an additional 90 days for the year in question. As a result, an employee may work a maximum of 210 days in agricultural seasonal work in a calendar year. However, the longer employment period places an additional tax burden on employers. Accordingly, in the case of seasonal agricultural work, the daily tax payable for the first 120 days is 0,75 % of the minimum wage applicable on the first day of the month in question (currently HUF 2,400), while for the additional maximum of a further 90 days, it is 1.125% of the minimum wage applicable on the first day of the month in question (currently HUF 3,600).
It is important to note that the increase in the minimum wage automatically entails an increase in the amount of the daily tax burden and the basis for calculating pension benefits for employees working under simplified employment relationships.
New provisions concerning Act IV of 1991 on the promotion of employment and the provision on benefits to the unemployed (“Flt.”)
As of 1 January, when calculating the qualifying period establishing entitlement to jobseeker’s benefit, neither periods of incapacity for work due to illness nor periods spent on sick leave taken for the care of a sick child shall be regarded as circumstances giving rise to an extension of the qualifying period.
When terminating or ceasing an employment relationship, employers must also certify in the certificate of employment that the employee has taken more than 30 days of unpaid leave in the three years prior to the termination. If yes, the first and last day must be indicated; if not, then this fact must be indicated.
Another noteworthy change is that the supervisory authority is now entitled to impose a warning on employers instead of a fine if employers fail to comply with their notification obligations related to collective redundancies, or, acting as temporary work agencies, with their statutory registration or data-reporting obligations, or if they do not comply with such obligation in the prescribed manner, or provide inaccurate or false information.
Changes Affecting Occupational Safety and Health
Pursuant to the amendment of Act XCIII of 1993 on Labour Safety (“Labour Safety Act”), as of 1 January 2026, employers employing at least 50 employees will be required to have their prevention strategy and risk assessment prepared exclusively by a person holding a higher-education qualification in occupational safety and health, provided that their activities fall within Hazard Class I or II under Decree No. 5/1993 (XII. 26.) of the Ministry of Labour. Such activities include, among others, the manufacture of paper products, machinery, tobacco, pharmaceuticals and electrical equipment, as well as the construction of residential and non-residential buildings.
Another new development is that, as of January 1, periodic safety inspections are classified as occupational safety specialist activity and may therefore only be performed by people who meet the conditions specified in the statutory provisions.
From January 1, as part of the provision of information on work processes, information on coordination must be provided in writing at workplaces where the employees of several different employers are employed simultaneously. The written information must cover the method of coordination, the risks to health and safety, and the preventive measures, and must be provided to all employers, employees, and workers’ representatives and other personnel in the area concerned.
Changes related to social security booklet
As of 1st of January, employers are no longer required to maintain paper-based social security booklets (“TB Kiskönyv”). The purpose of the amendment was to establish a uniform electronic registry of health insurance and employment data and to simplify processing. As a result, paper-based social security booklets were abolished and replaced by a modern electronic registry, namely the Patient Path (“Betegéletút Szolgáltatás”) and the e-social security booklet.
Accordingly, the paper-based social security booklet will in the future be maintained in electronic form within a central register. The current paper-based social security booklet kept by the employer must be handed over to the insured person no later than upon the termination of the employment relationship, with proper documentary evidence. The insured person is required to keep the paper-based social security booklet handed over to him/her for five years after he/she reaches the retirement age. In summary, employers are encouraged to hand over the paper-based social security booklet as soon as possible, as responsibility for keeping it will then pass to the employees.
However, it is important to note that the reporting of events related to insurance relationships to the tax authority remains mandatory. Employers operating a social security disbursement unit (“kifizetőhely”) have been entitled, as of 1 January 2026, to access the relevant data via the e-social security booklet interface. The aim of the amendment is to ensure that data previously held in separate registers and required for the determination of benefits are made electronically available to disbursement units, thereby reducing their administrative burden.
Insured persons may access their data relating to healthcare services and insurance relationships managed by the National Health Insurance Fund of Hungary (NEAK) in this website, following identification via DÁP or Ügyfélkapu+.
We would like to draw our Clients’ attention to the fact that, in connection with the transition to the e-social security booklet, it may be necessary to update their records of processing activities, internal data protection policies and, in certain cases, their data protection notices.
Establishment of energy cooperatives
In fulfilment of its obligations under EU law, the legislator introduced, as of 1 January 2026, the legal institution of the so-called energy cooperative into Act X of 2006 on Cooperatives („Cooperative Act”). The energy cooperative is a form of energy community defined in the current Hungarian electricity regulations. The aim of energy communities – including energy cooperatives – is to promote more conscious energy consumption in line with the principles of sustainability, energy efficiency, and environmental protection.
Changes relating to de facto groups of corporations
According to the currently effective provisions of Act V of 2013 on the Civil Code („Civil Code”), if a group of corporations de facto operates for at least three consecutive years, the court – at the request of either of the parties with legal interest – shall have authority to apply the regulations governing the relations between the managements of the dominant member and the controlled member even in the absence of a control contract. In this context, a further new development is that, as of March 2026, the legislator clarifies the scope of parties with legal interest by providing that the definition of a party with legal interest shall include any person whom the controlling member is liable in accordance with the provisions of the Civil Code.