Executive Circular on Expectations Regarding the Reporting of Fraud Observed Through Payment Services

VICE PRESIDENT RESPONSIBLE FOR THE SUPERVISION OF FINANCIAL ORGANIZATIONS AND CONSUMER PROTECTION Reference Number: 1588-1/2026 Executive Circular on Certain Expectations Related to Ensuring the Reporting of Fraud Observed Through Payment Services

The recipients of this executive circular – with the exception of the Hungarian National Bank (hereinafter: MNB), the Hungarian State Treasury, the institution operating the Post Settlement Center, and the building owners managing funds as payment service providers defined in Government Decree No. 191/2009. (IX. 15.) on Construction Execution Activities – are payment service providers operating in Hungary that maintain payment accounts as defined in point 8 of Section 2 and point 22 of the Act on Payment Services of 2009 (hereinafter: Pft.) (hereinafter jointly: payment service provider).

The MNB’s key task is to maintain the stability of the financial intermediary system, as well as to protect the interests of those using services provided by financial organizations and to strengthen public confidence in the financial intermediary system. In connection with this task, during its supervisory activities, the MNB pays particular attention to the consistent enforcement of customer protection provisions contained in European Union and domestic legislation, as well as to the realization of the customer protection principles and considerations formulated therein.

In accordance with Section 41, Paragraph (3) of the Pft., taking into account Section 40, Paragraph (2) of the Pft., the payment service provider ensures that the customer can, at any time, free of charge, cost, or other payment obligation, make a report if they observe the fraudulent use of cash-replacing payment instruments (hereinafter: Report).

According to Section 41, Paragraph (3) of the Pft., the payment service provider maintaining a payment account must also ensure the possibility of making this Report continuously via telephone, through a live-agent service, every day of the week from 0:00 to 24:00.

The purpose of this executive circular is to facilitate that the recipients of this executive circular uniformly ensure the possibility of making the Report and blocking the cash-replacing payment instrument in the shortest possible time for customers and in an easily understandable manner.

The MNB expects that the payment service provider ensures the possibility of making the Report and blocking the cash-replacing payment instrument via a direct telephone number and/or central telephone customer service, where the payment service provider is prepared and employs a dedicated agent for this purpose.

The MNB further expects that the customer can also restrict account access via mobile and internet banking – if the mobile or internet banking service is available to the customer – in such a way that the payment service provider provides the opportunity to lift the restriction only during personal or telephone agent service.

In order to reduce the time spent in the menu system and thus connect the agent as soon as possible, the MNB expects that, when selecting the telephone customer service, the menu item regarding the Report is placed at the first point of the menu structure (menu point 0) with a clear designation, and that the dedicated agent for this menu item can also immediately execute the blocking of the cash-replacing payment instrument affected by the fraud.

The MNB expects that, in order to provide prior information regarding the menu item for the Report and thus facilitate easier navigation within the menu system, the payment service provider publishes the telephone menu system structure and – if available – the telephone number for direct, yet more effective reporting of fraud, in an easily accessible, clearly visible, and highlighted location on its website. The MNB further expects that the payment service provider provides information regarding the contact details on the subpage recording information related to the prevention, detection, and prevention of fraud observed through payment services, as specified in the Executive Circular on Expectations Regarding Information Related to Fraud Observed Through Payment Services 1, including the attachment, if the Report is not handled directly by a dedicated agent connected via the provided telephone number.

The MNB expects that the payment service provider takes the necessary measures to ensure that the Report is received as soon as possible via telephone and that tasks related to the Reports are performed without undue delay, so that the waiting time until the live-agent connection does not exceed two minutes from the time the call is successfully established. In this context, the MNB expects priority handling of the menu point for the Report, the provision of appropriate agent resources corresponding to the load observed in various periods, and that the payment service provider regularly reviews existing resources based on waiting times.

In order to reach the agent as soon as possible, the MNB expects that, in the case of a Report, during the information provided before live-agent connection following the successful establishment of the call, only those short, mandatory information required by law (e.g., related to data processing) are announced, which are absolutely necessary for the proper conduct of the telephone conversation. To this end, the MNB expects that customers have the opportunity to select the menu item regarding the Report before listening to current advertisements or informational announcements. The MNB expects that additional information assisting the customer and other announcements (e.g., a reminder to file a police report, information indicating the telephone number and website stating that they should contact the Victim Support Center if necessary) are announced at the end of the telephone call.

The MNB further expects that the payment service provider has internal regulations regarding measures to ensure the above, as well as regarding mandatory information prior to live-agent connection (content, timing, date).

Good practice is for the payment service provider to also accept signals related to accounts maintained at the payment service provider that were used as fraud destination accounts, as well as those made by persons not authorized to dispose of the account.

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This executive circular is a supervisory regulatory tool that does not have binding force on supervised institutions. The content of the executive circular issued by the MNB expresses the requirements imposed by laws, principles and methods recommended for application based on the MNB’s legal application practice, as well as market standards and customs. The MNB sends this executive circular directly to the heads of payment service providers and the Hungarian Bankers’ Association, and publishes it on its website.

The MNB expects the affected payment service providers to comply with the expectations formulated in this executive circular as soon as possible.

Thank you for your kind cooperation.

Budapest, January 06, 2026

1 https://www.mnb.hu/letoltes/vezetoi-korlevel-kozzetetelhez.pdf

Dr. Levente Sipos-Tompa s. k.
Vice President Responsible for the Supervision of Financial Organizations and Consumer Protection of the Hungarian National Bank

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