Main Developments in Competition Law and Policy 2025 – Hungary

Abstract

In 2025, one of the most important innovations in Hungarian competition legislation was that the HCA (Hungarian Competition Authority) – following an accelerated sector inquiry and even without establishing a specific infringement – can intervene in the conduct of "undertakings of paramount significance" across markets in the mining of solid mineral resources and the construction industry, including through the imposition of structural obligations. Furthermore, the special, "alternative" regime for Foreign Direct Investment (FDI) screening was elevated to a statutory level, while during the transitional period lasting until the summer of 2025, the government decree-based FDI regulation was significantly tightened by extending deadlines and broadening the state's right of first refusal.

In 2025, the HCA imposed a total of nearly HUF 3.8 billion (approximately EUR 9.5 million) in fines on 29 undertakings, while granting over HUF 3.3 billion in fine reductions for cooperation and compliance efforts, clearly demonstrating the growing importance of cooperation tools (leniency applications, settlement procedures, compliance programs and consumer compensation). Major enforcement cases of the year included a garbage truck cartel, the Paradox vertical security technology case, the abuse of dominant position procedure regarding hasznaltauto.hu. Alongside traditional cartel and dominance enforcement, the HCA devoted an increasing share of its 2025 activity to unfair commercial practices. During the year, the HCA closed prominent consumer protection cases involving Lidl’s “wholegrain” bakery claims, Microsoft’s AI development commitments, and online fashion retail proceedings against Answear and About You. Additionally, the HCA opened new investigations into major platform and retail operators, including Airbnb, Booking.com, Ryanair, Google and Douglas.

Legislative Changes

New mining and construction tool: UPSCAM in Hungarian law

Act XCVIII of 2025 comprehensively amended Act LVII of 1996 on the Prohibition of Unfair Market Practices and the Restriction of Competition (Competition Act), introducing the category of "undertakings of paramount significance" for cross-market influence regarding the mining of solid mineral resources and the construction sector. Pursuant to the amended Section 43/F, if an accelerated sector inquiry reveals a market distortion in the given sector that has existed for at least two years and cannot be fully remedied by a competition supervision procedure, the HCA may impose independent structural or behavioural obligations on undertakings with cross-market significance operating in the mining or construction markets. The HCA may oblige the affected enterprise to introduce access obligations, terminate certain contractual practices (e.g., exclusivities), and even – in extreme cases – divest assets or business quotas, without having to prove a classic cartel or abuse of a dominant position infringement. The sectoral focus of the provision (mining and construction) aligns with the economic policy objective of maintaining competitive and predictable access to strategic raw materials and construction capacities, while the legislator also incorporated procedural safeguards (deadlines, professional consultation, and judicial review).

Main elements of the 2025 FDI regime

In 2025, Hungary continued to operate two parallel FDI screening systems: the general regime based on the EU FDI Regulation (2019/452/EU) and the special FDI regime covering a wide range of sectors introduced during the Covid crisis. As of 2025, the latter is no longer solely codified by a government decree but by Act L of 2025, which maintains the special regulation until the end of 2026 and continues to subject EU and third-country investments in strategic sectors (e.g., energy, infrastructure, raw materials) to an extended scope of control. The special FDI regime underwent further – temporarily stricter – amendments in the summer of 2025 via Government Decree 163/2025. (VI. 23.): the standard 30-working-day assessment deadline for the Minister of National Economy was raised to 45 working days, and the possibility of an extension was broadened to up to three times 30 working days, while the duration of information requests does not count towards the deadline. The same amendment extended the state's first refusal mechanism, previously applicable mainly to solar power plants, to any transaction blocked by the Minister in an FDI decision, meaning the state can potentially enter a vetoed transaction as a buyer. However, from August 19, a new FDI Act will replace the "alternative" FDI decrees tied to the special legal order, which – according to available analyses – returns to earlier, less stringent procedural rules: standard investigation deadlines are shortened, and the general mechanism of the right of first refusal is phased out, while the protection of strategic sectors remains a paramount priority. In practice, this means that in the second half of 2025, aligning the timing of transaction closings with the screening regimes became particularly important when structuring FDI procedures – especially in transactions involving natural resources, energy, or critical infrastructure.

Enforcement Trends

In 2025, the HCA imposed a total of approximately HUF 3.7826 billion (approximately EUR 9.5 million) in fines against 29 undertakings, while rewarding compliant behaviour and cooperation with over HUF 3.3 billion (approximately EUR 8.25 million) in fine reductions. Nearly half of the cases concluded during the year related to unfair commercial practices against consumers, which, however, accounted for only about one-quarter of the fines imposed, while the largest fines continued to be associated with public procurement cartels and anticompetitive agreements. In its communications, the HCA emphasized that the active use of fine-reducing mechanisms (leniency, settlement procedures, compliance programs, and consumer compensation) not only expedites procedures but also serves to preserve jobs and economic stability. The presidential speech delivered at the 7th Hungarian Competition Law Forum highlighted that digitalization and artificial intelligence are bringing about a fundamental transformation in competition law and consumer protection, which is expected to realign the focal points of the HCA's investigations in the future.

Antitrust Cases

Medical equipment cartel: fine reduction in a repeated procedure

In 2025, the HCA conducted a repeated procedure in a high-value public procurement cartel case concerning diagnostic imaging equipment (e.g., MRI, CT), after the Supreme Court (Kúria) upheld the decision establishing the anticompetitive agreement but ordered the authority to recalculate the fine for certain undertakings. In the repeated procedure, three involved undertakings – GE Hungary, Premier G. Med, and Medirex – no longer disputed the facts, cooperated with the HCA, waived their right to appeal, and in return, the Competition Council imposed a total fine of HUF 547.8 million (approximately EUR 1.37 million) on them, significantly mitigating the previous amount of over HUF 1.6 billion (approximately EUR 4 million) The HCA made it clear that uncovering public procurement cartels remains a top priority; however, the procedure also exemplifies that within the framework of judicial control and repeated procedures, it encourages cooperation and the subsequent restoration of compliant behaviour. The court's judgment simultaneously reinforced the HCA's legal position regarding the establishment of the infringement and created an opportunity to adjust the fine to a more proportionate level reflecting the cooperation.

Garbage truck cartel: procurement market allocation and procedural fines

At the end of the year, the HCA concluded another large-scale public procurement cartel case known as the "garbage truck cartel," in which the involved companies illicitly coordinated EU funded public procurements for garbage trucks and sewer cleaning vehicles. According to the competition authority, seven undertakings participated in the cartel, six of which received a total of nearly HUF 1.3 billion (approximately EUR 3.25 million) in competition supervision fines, while the HCA imposed an additional, record-breaking HUF 270 million (approximately EUR 0.68 million) procedural fine for obstructing access to data obtained during the on-site inspection; thus, the total value of the sanctions exceeded HUF 1.5 billion (approximately EUR 3.75 million). The uncovered conduct affected at least 35 public procurements in the 2014–2015 period; the domestic distributor of Renault chassis (Volvo Hungária) and two superstructure manufacturers (MUT Kft., Seres Gépipari Kft.) coordinated their bids through regular personal meetings, capacity sharing, and tender allocation, which qualified as a classic market allocation cartel. The case also received international attention, with several professional platforms highlighting the HCA's practice regarding dawn raids, evidence gathering, and procedural fines, viewing it as a precedent in the fight against public procurement cartels.

Paradox case: vertical restraints and repeated procedure

In 2025, the HCA reached a new stage in its procedure against the Paradox security technology group and its Hungarian distributors (Power, Trióda), in which the authority established vertical restraints (passive export restrictions, minimum installer margins, online sales restrictions) that had existed for nearly a decade. The earlier decision was partially annulled by the court due to procedural and market definition aspects; however, in the repeated procedure, the HCA repeatedly established the anticompetitive practice based on contracts, emails, and documents obtained during the on-site inspection, imposing a total fine of HUF 365.5 million (approximately EUR 0.91 million) on the members of the Paradox group. The significance of the case is outstanding in multiple respects: on the one hand, it points out that passive sales bans and online price display restrictions carry serious EU and domestic legal risks even in a narrow, technical market; on the other hand, it illustrates that the HCA does not dismiss a case even after judicial annulment if vertical restraints can be proven again based on available evidence. In cases of long-term, multi-channel anticompetitive behaviour, the duration of the conduct and the sensitivity of the affected markets remain aggravating factors in determining the fine.

Hasznaltauto.hu: exclusivity and online platform dominance

A notable abuse of dominant position case of 2025 concluded regarding the market-leading online vehicle advertising platform hasznaltauto.hu, where the HCA imposed a fine of HUF 550 million (approximately EUR 1.38 million)  on the former Norwegian-owned operator, Adevinta Classified Media Hungary Kft. The HCA found that for years, the so-called "exclusive package" contained conditions that essentially prevented business advertisers from simultaneously advertising on competitor platforms, which substantially hindered market entry and the strengthening of competitors. In this case, the authority not only examined the existence of a dominant position and the anticompetitive effects of exclusivity based on detailed economic data, but also evaluated data- and multi-sided market-specific aspects related to digital platforms (e.g., network effects, switching costs). The decision aligns well with the HCA's legal policy direction, which places special emphasis on the contractual practices, bundling, and exclusivity constructs of major online platforms, as well as the access conditions provided for SMEs.

Merger Control

4iG / PR-Telecom: conditional approval in the fixed telecommunications market

In 2025, the HCA approved the acquisition of control by 4iG Távközlési Holding Zrt. over PR-Telecom Zrt. subject to conditions, after the investigation found that the merged entity's market share exceeded the risk thresholds set in the HCA's guidelines in several retail fixed internet and television service markets. PR-Telecom serves approximately 55,000, mainly residential subscribers across 270 municipalities, thus the transaction could have had significant competition effects on prices and service quality at the local level. Therefore, the HCA imposed behavioural and – in certain areas – access-related commitments aimed at preventing potential price increases, ensuring network access for competitors, and maintaining subscribers' choices. The decision indicates that the authority continues to react sensitively to concentration in digital and telecommunications markets – independent of the FDI regime – and, if necessary, manages the further growth of market power with a complex, multi-element remedy package.

Unfair Commercial Practices

According to the HCA's summary communication for 2025, nearly half of the cases concluded during the year pertained to consumer protection, including misleading information, so-called "dark pattern" practices, and the lack of transparent pricing. The authority specifically highlighted that direct consumer compensation voluntarily undertaken by businesses – for example, in the form of refunds or discounts – led to significant fine reductions in a portion of the cases, amounting to approximately HUF 800 million (approximately EUR 2.0 million) in total, which represented a direct, tangible benefit for consumers. Although fines imposed in consumer protection cases are, on average, lower than in cartel or dominance cases, the HCA's strategy is clearly aimed at strictly sanctioning practices that distort the everyday decisions of households (e.g., hidden fees, manipulative user interfaces, misleading advertisements).

The cases listed below illustrate the authority’s enforcement activity. They first provide an overview of proceedings concluded in 2025, followed by proceedings initiated in 2025 that remain pending.

Lidl – “wholegrain” bakery products

In 2025, the HCA closed a procedure against Lidl Hungary concerning four bakery products marketed with the “wholegrain” designation – including a roll, a baguette, a seeded scone and a cocoa roll – where the composition did not live up to the implied health and quality benefits. The investigation revealed that only around 30–33% of the flour content of the products was actually wholegrain, while the remainder consisted predominantly of conventional refined flour, which, according to the HCA, could mislead health-conscious consumers into believing that they were purchasing substantially higher fibre products. In light of the several year duration of the conduct and the wide – potentially vulnerable, e.g. diabetic or insulin resistant – consumer group concerned, the authority imposed a fine of HUF 186 million (approximately EUR 0.47 million), underlining that it applies a particularly low tolerance threshold to claims suggesting health benefits or superior quality.

Microsoft – commitment on Hungarian language AI development

In July 2023, the HCA launched an investigation against Microsoft’s European subsidiary, Microsoft Ireland Operations Limited, on suspicion that the company engaged in unfair practices toward Hungarian consumers in connection with the “new Bing” service. According to the authority, Microsoft may not have informed consumers about the service with the level of expertise and professional diligence reasonably expected. The procedure against Microsoft was closed by way of commitments: the technology company undertook to create a structured dataset comprising at least 10 billion Hungarian words, to train its artificial intelligence-based systems on this corpus and to make the dataset available to other market players. According to the HCA, this solution simultaneously contributes to improving the quality of Hungarian language AI services and to enhancing transparency for users with regards to automated decision-making processes and data usage, thereby addressing key consumer protection concerns. The case illustrates the authority’s broader policy approach – already visible in 2024 – of being willing, in relation to major technology undertakings, to accept forward looking, system level commitments instead of relying exclusively on a purely repressive enforcement toolbox.

Answear – price indications and promotional practices

In the case of online fashion retailer Answear, the HCA assessed whether the retailer’s combination of general discounts, promotional messaging and use of reference prices created an overall impression of “permanent sales” and whether the scope and duration of discounts were communicated in a sufficiently clear and transparent manner. The HCA closed the case without establishing an infringement by accepting commitments: Answear had already abandoned a number of the questioned price indication practices during the investigation and undertook to align its discount communication with a detailed and verifiable formula (requiring at least 30 days of “original price” before a maximum of 60 days of discount period, with a further 60 days in case of an additional price reduction). In the HCA’s view, this model helps ensure that the reference price reflects a sufficiently long period of actual sales at the higher price, so that the advertised discount corresponds to a genuine saving, and it is expected to make a tangible contribution to curbing “fake discount” type practices in the e commerce segment.

About You – combined consumer compensation and fine

In the About You case, the HCA examined the combined effect of the fashion platform’s discount communication, countdown timers, scarcity messages and other behavioural design tools which, taken together, were considered problematic from the perspective of the professional diligence requirement. According to the authority, the practice exerted undue psychological pressure on consumers and created the impression of higher savings than actually achieved, in particular through “now or never” type messages and the communication of almost constant promotions. Under the final outcome, the company agreed to provide consumer redress exceeding HUF 500 million (approximately EUR 1.25 million) to several hundred thousand Hungarian customers in addition to paying a fine of HUF 505 million (approximately EUR 1.26 million) to the Hungarian state budget and to introduce a comprehensive consumer protection compliance programme; the HCA presented the case as an example of its now well established practice of combining direct consumer compensation with deterrent level monetary sanctions.

Below we highlight several cases initiated by the HCA in 2025 on the basis of suspected unfair commercial practices.

Airbnb – language and structure of consumer information

The summer of 2025 was kicked off by the HCA with the launch of a competition supervision proceeding against Airbnb Ireland UC, focusing on suspected misleading practices linked to the platform’s information environment. The authority is examining the extensive and fragmented set of rules, general terms and user notices available on Airbnb’s website and mobile application – some of which are accessible only in English – and whether, as a result, Hungarian users are properly informed about key aspects of the service, in particular booking requests, cancellations and refunds, in line with the professional diligence requirement. The HCA also assesses whether Airbnb clearly indicates when certain accommodations can likewise be booked via other platforms or directly from providers and has framed the case as part of its broader focus on large digital platforms, where the language, structure and actual comprehensibility of consumer information are scrutinized alongside pricing and other contractual conditions.

Booking.com – device‑dependent pricing and digital platforms

Alongside Airbnb, Europe’s and Hungary’s leading online accommodation booking platform, Booking.com, likewise did not escape the HCA’s scrutiny in 2025. The new competition supervision procedure launched that year is based on the suspicion that certain services of the platform may be offered under different conditions depending on whether consumers use the mobile application or the desktop interface, even though the underlying service is identical, and that Booking.com provides unclear information on the fees of certain services and the discounts available under the various tiers of its Genius loyalty program. The HCA is therefore scrutinizing not only whether the conditions and effective availability of discounts are sufficiently transparent and whether key information is disclosed at an appropriately early stage of the booking process, but also the broader presentation of offers, including device‑dependent pricing and the ranking of search results. This is not the first time that Booking.com has faced enforcement in Hungary. According to the HCA, the undertaking has previously paid a total of around HUF 3 billion (approximately EUR 7.5 million) in competition fines into the Hungarian central budget for various infringements related to unfair commercial practices on the Hungarian market.

Health claims and dietary supplements

In September 2025, the HCA launched a competition supervision procedure against three undertakings distributing food and dietary supplements (BGB Interherb, Swan Med Hungary, Nutrisslim), based on the suspicion that they utilized health claims that do not comply with sectoral rules and may qualify as the prohibited attribution of therapeutic effects. According to the authority, the advertisements for certain products may have unjustifiably implied the existence of a disease-preventing or curative effect, and messages related to Swan Med's "DotsDiet" products suggested that a balanced, mixed diet alone is insufficient for adequate nutrient intake, which qualifies as a particularly concerning claim. The HCA also objected that the EU organic logo and the EFSA logo were used unauthorizedly for certain products, while the commercial communication could have also provided a misleading picture regarding environmental impacts and consumer reviews by exclusively publishing positive feedback. The case effectively illustrates that the authority reacts with a low tolerance threshold in the intersection of "consumer health" to health claims that are not in line with the relevant sector-specific legislation and is prepared to initiate parallel procedures against multiple independent undertakings.

Ryanair: online booking, baggage, and suspected "dark patterns"

In August 2025, the HCA launched a competition supervision procedure against Ryanair DAC, suspecting the company of engaging in unfair commercial practices at several points on its Hungarian-language online ticket booking interface. According to the authority's preliminary assessment, the airline failed to provide sufficiently clear information that the various fare packages ("Regular", "Plus", "Flexi Plus") and additional services (priority boarding, baggage, Fast Track) are payable separately for each passenger and route, which can be particularly misleading for bookings involving multiple passengers and return tickets. The HCA also objected that the design of the interface – colors, highlights, labels – is suspected of exerting psychological pressure on consumers to choose more expensive packages and may employ "dark pattern"-like solutions. Thus, the investigation focuses not only on specific informational deficiencies but also on the UX-level design of the entire booking process, which may distort consumers' transactional decisions.

Google: phishing advertisements under a bank brand name

In November 2025, the HCA initiated a competition supervision procedure against Google Ireland Limited, as it is suspected that advertisements for phishing sites attempting to obtain data from consumers by misusing the name of MBH Bank could appear on the Google Ads advertising platform without adequate filtering. According to the authority, starting from March 2025, several domains (e.g., mbhbank.nu, mhbbauk.com, mhhbunk.com) could have appeared as paid advertisements in prominent positions for search terms related to MBH Bank, which likely led to fraudulent, phishing-oriented sites. According to the HCA's statement of objections, Google failed to act with the expected professional diligence regarding both the prior screening of advertisements and the rapid blocking of identified phishing advertisements and accounts, which may have contributed to consumers navigating to risky sites and entering their banking login credentials. The initiation of the procedure here merely signifies suspicion; however, it clearly demonstrates that the HCA also investigates the responsibility of platform operators if content severely endangering consumer safety can appear en masse through their advertising systems.

Douglas: "Up to ...%" promotions and exclusivity claims

In December 2025, the HCA initiated a competition supervision procedure against "Parfümerie Douglas" Illatszer Kereskedelmi Kft., suspecting that the undertaking's promotional communication and exclusivity claims may mislead consumers. According to the authority, promotions advertised with "Up to ...%" discounts could have created the impression that discounts of up to 30–70% were achievable, while a portion of the affected products was presumably never actually available for purchase at the maximum discount. The HCA also identified systemic problems in the promotional practices: in some campaigns, the proportion of discounted products may have been disproportionately high compared to non-discounted products, and promotional periods may have been longer than non-promotional periods, which can distort consumer price perception with the feeling of being "always on sale." A further concern was that the labels "Douglas Exclusive" and "Douglas Online Exclusive" on Douglas's online platforms and app could have created the impression that the given products are available exclusively in the chain's stores, although this was not true for a significant portion of the products; according to the HCA, the undertaking thereby failed to act with the expected professional diligence when verifying the truthfulness of the claims.

The weight of the consumer protection focus in the HCA's practice

The above cases collectively show that the HCA's consumer protection focus in 2025 strengthened across three main dimensions: the protection of health- and environment-conscious consumers, the transparency of digital and platform-based services, including the potential use of dark patterns, and the stricter control of "fake discounts" and exclusivity claims. In connection with the initiation of the proceedings, the authority consistently emphasized that a competition supervision procedure itself does not constitute the declaration of an infringement; however, such cases serve as a strong preventive signal for all market players, particularly for businesses operating within the digital ecosystem.

Sector Inquiries and Competition Policy Focuses

The HCA continued to actively utilize the powers provided by the Competition Act in 2025, launching a total of four accelerated sector inquiries to uncover market anomalies. The procedures centered around two main focal points: suppressing food inflation and reducing the proportion of single-bid public procurements. To ensure the purity of public procurement markets and the efficient use of public funds, the authority launched a comprehensive analysis of the procurement market for passenger and commercial vehicles in March, and subsequently of the public procurement market for mosquito abatement services in October. Meanwhile, in the spirit of consumer protection, the domestic markets of two fundamental food groups, milk and dairy products, and table eggs, were also scrutinized in April due to significant price fluctuations and sudden surges in consumer prices. These accelerated sector inquiries served as vital tools for stimulating market competition. The procedures concerning public procurements (which complemented the investigation into medical imaging equipment initiated in late 2024) closely aligned with Hungary's commitments to the European Commission, which aimed to curb single-bid procedures. During the food market inquiries, the competition authority analyzed every level of the value chains in detail – from producers to retailers. The HCA's objective on both fronts was to formulate recommendations by identifying structural problems and potential anticompetitive, "profit-driven" practices, to protect Hungarian consumers from excessive price increases, and to restore fair competition in the affected sectors.