Management Circular on the Supervisory Assessment of Accounts Maintained by the Hungarian National Bank Regarding the Placement of Funds Received for Payment Transactions

DEPUTY PRESIDENT RESPONSIBLE FOR THE SUPERVISION OF FINANCIAL INSTITUTIONS AND CONSUMER PROTECTION Management Circular on the Supervisory Assessment of Accounts Maintained by the Hungarian National Bank Regarding the Placement of Funds Received for Payment Transactions

The recipients of this management circular – the Hungarian National Bank (hereinafter: MNB), the Hungarian State Treasury, the institution operating the Post Settlement Center, and, with the exception of building contractors defined in Government Decree No. 191/2009. (IX. 15.) on Construction Contracting acting as payment institutions – are payment service providers operating in Hungary in a non-credit institution form that provide payment services, specifically payment institutions and electronic money issuers (hereinafter collectively: non-credit institution payment service providers).

The MNB enables non-credit institution payment service providers to connect to the Real-Time Gross Settlement System (hereinafter: VIBER), as a designated payment system, and – in light of Section 46, Paragraph (3) of the Payment Services Act (hereinafter: Fsztv.) – provides account management services exclusively in connection with participation in designated payment systems for these institutions. The MNB specified in Chapter 1, Section 3.1.1. of its Business Conditions effective from July 15, 2026, regarding accounts maintained by the MNB, as well as for forint and foreign currency settlements, that for non-credit institution payment service providers, the account management service is limited exclusively to the maintenance of a payment account for such purposes, i.e., the MNB maintains an account for non-credit institution payment service providers exclusively for the purpose of settling and executing payment transactions of the provider and its clients within the payment system.

In light of the above, the MNB draws the attention of non-credit institution payment service providers to the fact that customer money protection measures under Section 46, Paragraph (3), point a) of the Fsztv. and Section 51, Paragraph (3), point a) of the Fsztv. are not met if the funds affected by these provisions are placed in accounts maintained by the MNB for them.

Non-credit institution payment service providers can comply with the customer money protection measures of the Fsztv. as follows:

• Proceeds received in exchange for electronic money issuance may be credited temporarily to the electronic money issuer's payment account for a short period, provided that the issuer must immediately take measures ensuring compliance with Section 51, Paragraph (3) of the Fsztv. regarding these funds;
• Funds received for the provision of payment services, which have not been transferred to another payment service provider as part of executing the payment transaction, or paid out to the beneficiary, may be held in accounts maintained by the MNB for non-credit institution payment service providers until the end of the next working day following receipt, provided that from the end of the next working day following receipt, the provider is obligated to take measures ensuring compliance with Section 46, Paragraph (3) of the Fsztv.;
• Compliance with Section 46, Paragraph (2) and Section 51, Paragraph (2) of the Fsztv. is expected by the MNB such that non-credit institution payment service providers may hold amounts related to participation in the VIBER and the Interbank Clearing System (including amounts intended for fee payment) exclusively in accounts maintained by the MNB for them, i.e., neither other own funds nor funds affected by measures necessary for compliance with Section 46, Paragraph (3) and Section 51, Paragraph (3) of the Fsztv. may be held in such accounts.

1 Current valid Business Conditions and appendices | MNB.hu

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This management circular is a supervisory regulatory instrument that does not have binding force on supervised institutions. The content of the management 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 management circular directly to the management of non-credit institution payment service providers and publishes it on its website. The MNB expects the affected parties to comply with the expectations formulated in this management circular as soon as possible.

Thank you for your kind cooperation.
Budapest, June 26, 2026
Dr. Levente Sipos-Tompa s.k.
Deputy President of the Hungarian National Bank responsible for the supervision of financial institutions and consumer protection