A new Hungarian law requires the introduction of an internal whistleblowing system for specific employers. In this newsletter we summarise the most important information on this.

The law allows all entities to set up an internal whistleblowing system. Employers with 50 or more employees must set up a reporting system until 17 December 2023. Employers with up to 250 employees and employers that are subject to the Act on the Prevention and Combating of Money Laundering and Terrorist Financing must have an internal whistleblowing system in place until 24 July 2023.

The internal whistleblowing system is a legal and organisational forum, which shall be completely independent of the entity. By using the system, whistleblowers can lodge complaints about the operation of the company or their legal relation with the company in a manner that complies with GDPR rules and protects the identity of the whistleblower.

The system may be operated by a designated person or department within the employing company who cannot be instructed concerning this activity, or by a whistleblower lawyer or other external organisation.

The above requirement is in line with relevant EU legal trends and international trends; several multinational companies currently have such a whistleblowing system in place, but this shall be operated in accordance with mandatory Hungarian legal requirements. The competent government agency will monitor compliance with the requirements for the establishment and operation of the whistleblowing system.

Once a notification is received by the whistleblowing system, the designated body has 30 days to investigate it, which may be extended if reasonably justified. The employer shall ensure that the infringing situation and the reasons for it are remedied and that any damage related to this is also remedied.


This summary is intended to raise awareness and does not constitute legal advice.

If you have any questions or need further information, please do not hesitate to contact us.

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