MNB Reporting Decrees 32/2026 and 33/2026: Hungary’s 1 October Reset

ByRegReportingDesk

On 14 September 2026 the Magyar Nemzeti Bank (MNB) promulgated two reporting amendments with different commencement and application rules. Decree 32/2026 enters into force on 1 October 2026. Most of Decree 33/2026 entered into force on 15 September 2026, while specified quarterly reporting changes under 33/2026 apply first to the third quarter of 2026. These MNB reporting decrees, 32/2026 (IX. 14.) and 33/2026 (IX. 14.), amend the two instruments that order data supply to the central bank. Decree 32/2026 amends the basic reporting decree, 54/2024 (XII. 3.), which sets the data-supply obligations firms meet primarily for the MNB’s core central-bank tasks. Decree 33/2026 amends 44/2025 (XII. 4.), the decree covering the returns that capital-market entities file for the MNB’s supervisory tasks. Both instruments carry the authorisation in section 171(1)(i) of Act CXXXIX of 2013 on the MNB.

The change matters because it lands mid reporting year rather than at the usual January turnover. The MNB data-reporting portal publishes the 54/2024 version incorporating 32/2026 as effective from 1 October 2026. For 44/2025 as amended by 33/2026, the portal instead states that the amended provisions are effective according to section 6 of 33/2026, reflecting its staggered commencement. For a reporting officer, the practical question is narrow: which tables and completion instructions change, for which reporting population, and what has to be ready for the first affected reference period under each amendment. For 33/2026, the first-application rule must be mapped separately rather than treating 1 October as a blanket reference-period cut-off.

Related reading: MiFIR Transaction Reporting.

The dates that anchor the change

Hungarian decree citations encode the date of publication in the official gazette, the Magyar Kozlony, inside the parenthesis. The “(IX. 14.)” in each decree number is that publication date. The operative calendar reads as follows.

  • 14 September 2026: both 32/2026 and 33/2026 published in the Magyar Kozlony.
  • 15 September 2026: 33/2026 enters into force except for section 5 and point 6(b) of its Annex 2, which are deferred to 1 October 2026.
  • Third quarter of 2026: the quarterly reports expressly identified by the new section 14(5) of 44/2025 must first use the amended structures and completion instructions for this reference period, including the new quarterly report identified in the new section 14(5) of 44/2025.
  • 1 October 2026: 32/2026 enters into force; section 5 and point 6(b) of Annex 2 to 33/2026 also enter into force.

An amendment applying from 1 October is itself the signal worth noting. Decree 41/2025 (XII. 4.), which amended 54/2024 for 2026, took effect on 1 January 2026. Decree 32/2026 instead takes effect on 1 October 2026, so the latter must be implemented during the 2026 reporting year rather than held for the next January cycle.

The split inside 33/2026 does not create a general 1 October reporting-content cut-over. Most of the decree entered into force on 15 September 2026, and the new section 14(5) of 44/2025 expressly makes specified quarterly reporting changes applicable first to the third quarter of 2026. Only section 5 of 33/2026 and point 6(b) of its Annex 2 are deferred to 1 October 2026.

MNB reporting decrees: two streams, two amendments

The MNB collects data through a single central-bank information system, but it does so under separate reporting decrees for separate purposes, and the two decrees amended here sit in different streams. Decree 54/2024 governs the data supplied primarily for the MNB’s basic tasks, which is the statistical work behind monetary, balance-of-payments, securities, financial-accounts, payments, payment-system, financial-stability and macroprudential statistics. Decree 44/2025 governs the data supplied primarily for the MNB’s supervisory tasks by capital-market organisations.

That division decides which amendment a given firm has to read. A bank that files statistical returns follows 54/2024 and, from 1 October 2026, its 32/2026 amendment. An investment firm or fund manager that files supervisory returns for capital-market activity follows 44/2025 and its 33/2026 amendment. Firms that straddle both domains sit in both streams and have to track both. The decrees share the authorisation in section 171(1)(i) of the MNB Act, but the submission method is return-specific. L72 is submitted through ERA, while 54/2024 also contains returns submitted by other electronic methods; the reporting content, annex structure and commencement rules therefore have to be mapped return by return.

What 32/2026 changes in the statistical decree

Decree 32/2026 is a targeted amendment to 54/2024. It replaces the tables and completion instructions for one reporting obligation, MNB code L72, the quarterly report on the mortgage funding adequacy ratio, and enters into force on 1 October 2026. Under Annex 1 of 54/2024, L72 is assigned to banks and mortgage credit institutions, subject to the stated exclusion for Hungarian non-group-leading members of a credit-institution group. The wider reporting population of 54/2024 is not the population affected by 32/2026.

The structure of 54/2024 is worth recalling because it shows where an amendment actually lands. Annex 1 lists each data supply by its MNB identifier code, the reporting population, frequency, submission method and deadline. Annex 2 holds the tables and the rules for completing them. Annex 3 covers the technical helper files, meaning the code lists, cross-table checks and methodology guides, which the MNB publishes on its website when the decree takes effect. Under 54/2024, Annex 3 identifies technical aids including code lists and individual validation criteria that the MNB publishes on its website. Decree 32/2026 itself replaces the L72 tables and completion instructions in Annex 2; it does not establish in its text that every Annex 3 helper or validation file is simultaneously revised. Reporters should therefore apply any amended technical aids that the MNB publishes for the affected return rather than assume that the whole helper-file set changes.

Decree 32/2026 changes one reporting obligation: L72, the quarterly mortgage-funding adequacy-ratio report. It should not be described as changing a broader set of statistical returns. The exact content of the revised tables should be confirmed against the consolidated 1 October 2026 text before any build work, since a single amended completion instruction can change what a field means without changing the table’s shape.

Who reports under 44/2025, and what 33/2026 touches

Decree 44/2025 is the capital-market supervisory reporting decree. Its scope reaches the entities the MNB supervises on the capital-market side: investment firms, investment funds and their managers, central-securities-depository activity, central counterparties, trading venues, crowdfunding service providers and crypto-asset service providers, among others, and it carries returns spanning areas such as remuneration, securities-account data, trading-venue data and digital operational resilience. It entered into force on 1 January 2026, so 2026 is its first full application year, and 33/2026 is the first amendment to reach it in that year.

Decree 33/2026 makes targeted changes within 44/2025 rather than imposing a single new version on every reporter from 1 October. Decree 33/2026 amends 44/2025. The MNB reporting-decrees portal states that its effectiveness follows section 6 of 33/2026 rather than a single blanket commencement date. The return-by-return amendments and first-application rules should therefore be taken directly from the amending decree before implementation. Firms therefore need to map each amended provision and return rather than use 1 October as a blanket planning date.

An investment firm that also has MiFIR transaction-reporting duties should keep the two obligations separate. Transaction reporting under Article 26 of Regulation (EU) No 600/2014 is its own EU-level return with its own fields and its own validation, and a change to a national supervisory return under 44/2025 does not by itself change that MiFIR return. Where a fund manager’s activity intersects with lending, the AIFMD II reporting changes discussed in our AIFMD II Annex IV reporting guide are a parallel EU track rather than a substitute for the national return.

The completion instructions carry the change, not just the table

The failure mode these amendments invite is to read them as a table swap. Under 54/2024, the reporting framework comprises the tables, their completion rules and the technical aids identified in Annex 3, including code lists and validation relationships. Under 44/2025, the relevant reporting annexes provide the applicable reporting content and completion instructions, while the decree separately points reporters to MNB technical guidance for ERA use and, where applicable, return-specific technical material. An amendment can leave a table’s visible shape untouched and still change the return by rewriting a completion instruction or a validation rule.

Practically, change control should reconcile each amended table and its completion instructions against the applicable decree, and should also check any MNB technical aids or ERA guidance that apply to the affected return. It also means the internal mapping, the logic that populates each field from source systems, has to be checked against the revised instructions, because a field that is redefined rather than moved will pass a structural check and fail a content check. This is where an on-time table carrying last quarter’s completion logic still produces a failing return.

These decrees are not the EBA framework returns

A reporting officer in Hungary works two overlapping reporting worlds, and the 1 October changes belong to only one of them. The MNB reporting decrees, namely 54/2024, 44/2025 and their amendments, are national instruments that order statistical and supervisory data supply. Submission method is return-specific: L72 is submitted through ERA, while 54/2024 also contains returns using other electronic channels; 44/2025 uses ERA for the supervisory reporting addressed here. The harmonised prudential returns that credit institutions and investment firms file under the EU single rulebook, such as COREP and FINREP, run on the EBA’s reporting framework and its data-point model, and in Hungary those XBRL submissions are received through the MNB’s STEFI system.

The distinction matters operationally. EBA Reporting Framework 4.2 completed the transition of most modules to the DPM 2.0 data dictionary from the March 2026 reference date. The COREP OF module uses the v4.2 technical package from March 2026, but the additional CRR3/CRD6 operational-risk reporting requirements have a first reference date of June 2026. For reference dates from 31 March 2026, the EBA requires xBRL-CSV, and the MNB expects the relevant submissions in that format through STEFI. None of that is what 32/2026 and 33/2026 do. Confusing a national statistical return with an EBA-framework STEFI submission sends a change to the wrong pipeline and the wrong deadline. If your build backlog already carries the EBA transition, keep the MNB decree amendments on a separate line; our COREP reporting guide and FINREP reporting guide cover that framework, and it moves on its own schedule.

Crypto-asset and resilience returns sit inside the capital-market decree

Decree 44/2025 includes crypto-asset service providers within its scope and contains digital-operational-resilience reporting provisions. Whether a particular 44/2025 provision is affected by 33/2026 must be determined from the operative provisions and annex amendments of the amending decree. A firm should therefore not treat CASP or DORA returns as amended merely because they sit inside 44/2025.

The same reading applies to the central-counterparty content the decree carries. A Hungarian central counterparty is subject to the applicable EMIR reporting requirements, while a central-securities-depository operator is subject to EMIR transaction reporting only where it is itself a reportable counterparty or otherwise falls within the relevant EMIR obligation. Those EU obligations are separate from the national supervisory returns under 44/2025. Where an entity has to line those up, our EMIR reporting guide sets out the EU obligation that runs in parallel.

How the amended returns reach the MNB

The affected returns must be mapped individually for submission channel, frequency and deadline. L72 under 54/2024 is quarterly, is submitted through ERA and, for the second to fourth quarters, is due on the 11th day of the second month following the reference period. The frequency and filing deadline of each affected 44/2025 return must be taken from the amended supervisory-reporting annex governing that return. The affected 44/2025 reports are set out in the relevant supervisory-reporting annexes rather than in a single Annex 1 register.

The basic decree also fixes a procedure for notifying the MNB when a serious IT problem obstructs a submission. A reporting team moving to the amended versions benefits from knowing that route before it is needed, because a mid-year template and validation change is a moment when a submission chain is more exposed to failure. The impediment-notification contact and format belong in the cut-over runbook alongside the new templates.

What to have ready before 1 October 2026

The preparation list for these decrees is short and specific. First, identify which stream applies: statistical returns under 54/2024, capital-market supervisory returns under 44/2025, or both. Second, pull the amended texts and the applicable technical helper files from the MNB portal, and diff them against the versions in production. Third, reconcile the amended tables and their completion instructions for each affected return, and re-test the field mapping against the revised instructions rather than the old ones.

For 33/2026, section 6 must be read together with the new section 14(5) of 44/2025. Most provisions entered into force on 15 September 2026, and the specified quarterly reporting changes apply first to the third quarter of 2026; only section 5 and point 6(b) of Annex 2 are deferred to 1 October. The implementation plan must therefore cover the affected third-quarter submissions, including the new quarterly return under section 14(5) of 44/2025, rather than waiting for a fourth-quarter reference period.

Frequently Asked Questions

My firm only files EBA framework returns such as COREP and FINREP in Hungary. Do 32/2026 and 33/2026 affect me?

Those two decrees amend national MNB reporting decrees rather than the EBA framework returns received through STEFI. Submission method is return-specific: L72 under 54/2024 uses ERA, but 54/2024 also contains returns submitted by other electronic channels, and the applicable channel for each return is set by the governing decree. A firm that files only the harmonised prudential returns therefore falls outside the scope of 32/2026 and 33/2026. Confirming the firm carries no statistical or capital-market supervisory returns under 54/2024 or 44/2025 remains worthwhile, because many institutions sit in more than one stream.

We are an EEA branch operating in Hungary. Are we in scope?

The parent decrees name the relevant EEA branch types alongside the domestic institution categories for the returns they order, so an EEA branch can be a data supplier under 54/2024 or 44/2025. Whether a specific branch owes a specific return depends on the reporting population set out for that MNB identifier code in the decree’s annex.

If a return is threshold- or designation-based, does the 1 October change alter when we start reporting?

The two amendments have different application rules. Decree 32/2026 changes L72 from 1 October 2026, while specified quarterly changes under 33/2026 apply first to the third quarter of 2026 and other provisions follow the staggered commencement in section 6. Any separate threshold, designation or reporter-population condition must be checked against the governing return in the amended parent decree. The obligation to file a threshold- or designation-based return still turns on the criteria the parent decree sets for that return, which should be checked against the consolidated text.

When do the amended quarterly returns under 33/2026 first apply?

For the quarterly reports identified in the new section 14(5) of 44/2025, the amended structures and completion instructions apply first to the third quarter of 2026. Reporters should therefore use the amended requirements for that reference period, including the new quarterly report under section 14(5) of 44/2025 where applicable, rather than waiting for a fourth-quarter return.

Where is the authoritative text, given the decrees were published as amendments?

The MNB’s data-reporting portal publishes consolidated versions of both parent decrees that incorporate the amendments, including a 1 October 2026 version, and the full legal text of each decree is available on the national legislation database. The consolidated version is the practical reference; the amending decree itself shows exactly which provisions changed.

Does 33/2026 change our MiFIR transaction reporting?

No. MiFIR transaction reporting under Article 26 of Regulation (EU) No 600/2014 is a separate EU-level return with its own fields and validation. A change to a national capital-market supervisory return under 44/2025 does not by itself alter the MiFIR transaction report, which continues on its own rules.

Key Takeaways

  • 32/2026 (IX. 14.) amends the basic statistical reporting decree 54/2024 and takes effect on 1 October 2026; it changes one reporting obligation, L72, the quarterly mortgage funding adequacy ratio report.
  • 33/2026 (IX. 14.) amends 44/2025 under staggered commencement: most provisions entered into force on 15 September 2026, specified quarterly reporting changes apply first to the third quarter of 2026, and only section 5 and point 6(b) of Annex 2 are deferred to 1 October 2026.
  • Both decrees were promulgated on 14 September 2026 and both rest on section 171(1)(i) of Act CXXXIX of 2013 on the MNB.
  • The implementation dates must be mapped separately: 32/2026 enters into force on 1 October 2026, while affected quarterly reporting under 33/2026 already reaches the third quarter of 2026.
  • Reconcile the amended tables and completion instructions against the applicable legal text, and check any technical aids or ERA guidance that apply to the affected return.
  • The affected national returns discussed here must be kept separate from EBA-framework COREP and FINREP submissions received through STEFI; the applicable MNB submission channel must be taken from the governing return.
  • Crypto-asset service providers and digital-resilience returns sit inside 44/2025, so a firm reading only its EU obligations can miss the national return.

Sources and References

Reading the 1 October cut-over

The two amendments require separate implementation dates. For 32/2026, the amended L72 requirements enter into force on 1 October 2026. For 33/2026, most provisions entered into force on 15 September and the quarterly reports identified in the new section 14(5) apply the amended structures and instructions first to the third quarter of 2026; only the expressly deferred provisions take effect on 1 October. The implementation plan should therefore be built at provision and return level rather than around a single 1 October cut-over.

Disclaimer: The information on RegReportingDesk.com is for educational and informational purposes only. It does not constitute legal, regulatory, tax, or compliance advice. Always consult your compliance officer, legal counsel, or the relevant supervisory authority for guidance specific to your institution.

Similar Posts