Hungary's Accessibility Fine Isn't Missing — It's in Two Other Laws, and It's One of the Largest in the EU
Comparison tables say Hungary has no quotable figure because its accessibility act defers the penalty elsewhere. That's half right: the act does defer. But the trail ends — twice — in turnover-linked scales capped at HUF 650 million for products and HUF 500 million for services. That's roughly €1.6 million and €1.25 million.
Quick answer
Hungary's EAA law (Act XVII of 2022, in force 28 June 2025) contains no fine itself. Section 9 authorises the Government to set, by decree, "the criteria for determining administrative sanctions, and the method and amount of payment of the administrative fine." That decree exists — 605/2022. (XII. 28.) Korm. rendelet — and the enforcement it points to lands in two separate statutes. For products, Act LXXXVIII of 2012 on Market Surveillance sets fines of HUF 1 million up to 5% of annual net turnover, capped at HUF 650 million. For services, the consumer protection authority applies the consumer protection scale — reported by Hungarian practitioners as up to 5% of net revenue, capped at HUF 500 million. Consumer and disability organisations can also sue in the public interest.
Following the trail to the end
The reason Hungary is filed under "no figure" is that its accessibility act really is silent. Section 8(13) says:
"Detailed rules governing supervision, enforcement, and the criteria for determining administrative sanctions, and the method and amount of payment of the administrative fine, shall be set out in a government decree."
— Act XVII of 2022, § 8(13) (Nemzeti Jogszabálytár), English translation
and Section 9 repeats the authorisation. Most sources stop here and conclude the amount is unknowable. It isn't — there are two more steps.
- The decree exists. Government Decree 605/2022. (XII. 28.), implementing Act XVII of 2022, was made in December 2022 and applies from 28 June 2025. It designates the supervising authorities and routes enforcement into Hungary's existing frameworks rather than inventing a new penalty schedule.
- Those frameworks have numbers in them. And they are large.
Products: HUF 650 million, in the 2012 Act
Act LXXXVIII of 2012 on the Market Surveillance of Products is the pair to the accessibility act — Chapters III/A and IV/B were inserted in 2022 specifically to carry the accessibility obligations for manufacturers, importers and distributors. Its Section 16 sets the money:
"(2) The amount of the fine may range: a) for an economic operator subject to [the Accounting Act] with an annual net turnover exceeding HUF 100 million and not falling within the scope of the Act on Small and Medium-sized Enterprises: aa) from HUF 1 million up to 5% of the economic operator's annual net turnover, but not exceeding HUF 650 million; ab) for an infringement injuring or endangering the life, physical integrity, or health of consumers or users, from HUF 2 million up to HUF 3 billion; b) for an economic operator not falling within point (a): ba) from HUF 100,000 to HUF 2 million…"
— Act LXXXVIII of 2012, § 16(2) (Nemzeti Jogszabálytár), English translation
For accessibility purposes the operative limbs are (aa) and (ba) — the life-and-health tiers in (ab) and (bb) are product-safety provisions unlikely to be reached by an inaccessible interface.
| Operator | Fine range | ≈ EUR | Starting point (§ 16(3)) |
|---|---|---|---|
| Large operator (turnover > HUF 100m, not an SME) | HUF 1m to 5% of net turnover, max HUF 650m | ~€2,500 to ~€1.6m | HUF 3m (~€7,500) |
| Smaller operator | HUF 100,000–2m | ~€250–€5,000 | HUF 550,000 (~€1,400) |
(Euro conversions approximate, at about 400 forint to the euro.)
Section 16(3) does something few statutes bother with: it sets starting points. The reference amounts above are adjusted up or down within the range according to the circumstances. That is unusually transparent — Hungary tells you where the calculation begins.
Two further mechanics. Under § 16(1), whether the operator infringed the same provisions within the preceding three years must be taken into account. Under § 16(4), if a sampled product fails testing, the manufacturer, importer or distributor pays for the testing.
Services: HUF 500 million, via consumer protection law
The services side routes to the fogyasztóvédelmi hatóság — the consumer protection authority — which applies the consumer protection act's own sanction scale rather than a bespoke accessibility one. Hungarian practitioners describe that scale as running from a minimum of HUF 15,000, with large undertakings (annual revenue above HUF 100 million) exposed to
