Executive Circular on Information Expectations for State-Subsidized Loans Secured by Condominium Building Rights

VICE PRESIDENT RESPONSIBLE FOR THE SUPERVISION OF FINANCIAL INSTITUTIONS AND CONSUMER PROTECTION Registration Number: 240106-9/2026 Executive Circular on Information Expectations Related to State-Subsidized Loans Secured by Condominium Building Rights

The recipients of this executive circular are credit institutions engaged in the financial service activity of granting loans and cash loans, as defined in point 40 of paragraph (1) of Section 6 of Act CCXXXVII of 2013 on Credit Institutions and Financial Enterprises, which provide state-subsidized mortgage loans to consumers for the purpose of home creation.

The Hungarian National Bank (MNB) has the prominent task of maintaining the stability of the financial intermediary system, as well as protecting the interests of those using services provided by financial organizations and strengthening 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 the case of state-subsidized mortgage loans granted for the purpose of home creation, where disbursement occurs with condominium building rights as security, the interest subsidy ceases if the business entity constructing or commissioning the apartment fails to perform within the deadline defined by law, and thus the supported person cannot prove to the credit institution that the construction work was carried out on time.

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The purpose of this executive circular is to facilitate the recipients of this executive circular providing transparent and verifiable information to consumers regarding the consequences of non-performance of the conditions for home creation interest subsidies occurring without the consumer's fault.

In the case of state-subsidized loans secured by condominium building rights, the MNB expects that the credit institution, prior to concluding the loan agreement, calls the consumer's attention in a verifiable and understandable manner to the fact that if the completion of construction work is not proven to the credit institution within the deadline and in the manner defined by the relevant legislation – regardless of whether the non-performance of the relevant condition is due to the consumer's fault outside their control, resulting from the non-performance of the business entity constructing or commissioning the apartment – the interest subsidy will cease and thus the installment payment may increase, and the interest subsidy already received must be repaid with interest added from the date of its utilization.

The 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 law enforcement practice, as well as market standards and customs. The MNB sends this executive circular directly to the management of the affected credit institutions and to the Hungarian Bankers' Association, and publishes it on its website.

The MNB expects the affected credit institutions to comply with the expectations formulated in this executive circular as soon as possible.

Thank you for your kind cooperation.

Budapest, June 03, 2026

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

ELECTRONICALLY SIGNED DOCUMENT

1 Regarding the FIX 3% housing loan provided under the Home Start program, see Section 21 (2a) of Government Decree 227/2025. (VII. 31.) and point d) of paragraph (1) of Section 39 of Government Decree 518/2023. (XI. 30.) on the favorable CSOK Plusz loan program supporting family home creation.