Hungarian competition law and enforcement trends for 2026

Noteworthy legislative changes in 2025

The Hungarian legislator introduced the concept of "undertakings with paramount significance" into competition law in December 2025, granting the HCA new powers. In certain accelerated sector inquiries – currently limited to the mining and construction industries – the HCA may designate an undertaking as having "paramount significance across markets" and impose behavioural or even structural remedies without finding a competition law infringement (e.g. a cartel or an abuse of dominance).

When assessing whether a company qualifies as having "paramount significance", the HCA may consider factors including market share, financial strength and access to resources, vertical integration and operations in related markets, as well as access to data relevant to competition. This list is not exhaustive, leaving the authority with broad discretion. As part of its evaluation, the HCA must also seek the views of the Supervisory Authority for Regulated Activities.

If the HCA concludes that an undertaking contributes to serious and persistent distortions of competition – generally lasting two years or recurring within three – it can impose proportional remedies, including transparency obligations, access requirements for competitors or bans on self-preferencing. Where behavioural remedies are impossible or disproportionately burdensome, the HCA may even force the company's owners to sell shares or divest assets, in whole or in part.

You can find a more detailed summary here. 

Enforcement trends

In 2025, the HCA adopted decisions in 33 cases involving 67 undertakings in competition supervision proceedings. In two-thirds of these decisions (21 cases), the HCA found an infringement, and in 19 decisions it imposed fines on 29 undertakings, totalling approx. EUR 9.8m. Nearly half of the authority's closed cases (16 matters) concerned unfair commercial practices (UCP) in 2025, accounting for 25 % of the total competition fines imposed (approx. EUR 2.45m). The figures indicate that fines imposed in antitrust or cartel cases were significantly higher in 2025 than those imposed in UCP cases, but this changes from year to year.

Antitrust – cartel

Among other actions, the HCA closed several major cartel cases during 2025, including a competition-restricting cooperation among manufacturers and distributors of medical devices in August 2025, and the garbage-truck cartel case concluded in early December 2025, in which the HCA imposed fines in excess of EUR 3.9m on six undertakings. The HCA is also re-examining the alleged cartel conduct of Nitrogénművek Zrt. in the artificial fertiliser market after the court ordered it to conduct a repeated proceeding. This decision serves as an example that the courts scrutinise the HCA's decisions in their proceedings if legal review is initiated against the HCA's decisions.

Abuse of dominance

The HCA imposed a fine of approximately EUR 1,350,000 on Használtautó.hu Kft., the operator of Hungary's leading online vehicle advertising platform, for abuse of dominance. The proceeding established that the "exclusive package" included an exclusivity clause that prevented business advertisers from appearing on competing platforms. Használtautó.hu held a market share of at least 70 % in the Hungarian online vehicle classifieds market. The HCA concluded that this exclusive arrangement was capable of foreclosing competitors and hindering market entry, and that the dominant undertaking had infringed both Hungarian and EU competition law.

The HCA also conducted an abuse of dominance proceeding against Coca-Cola Hungary, which ended in November 2025 with commitments.

In 2026, the HCA will continue to take action against abuse of significant market power. In February 2026, it launched two proceedings on the market for over-the-counter medicines, on suspicion that both anti-competitive conduct and abuse of dominance may be contributing to high prices.

Unfair commercial practices against consumers

The HCA concluded three competition supervision proceedings initiated by the HCA in 2023 in the clothing sector. In 2023, the HCA simultaneously opened investigations against three major online fashion retailers – CCC, Answear and About You – concerning their promotional and pricing practices. The HCA suspected that the undertakings had maintained discounted prices for excessively long periods, thereby potentially distorting consumers' price perceptions.

The HCA emphasised that there is no uniform benchmark for determining when a promotion becomes unlawfully prolonged; such assessments must be conducted on a case-by-case basis. The cases concerning CCC and Answear were closed after the HCA accepted the undertakings' commitments, whereas the HCA found an infringement in the About You case. To decrease the fine, About You acknowledged the infringement, waived its right to appeal, and undertook to implement a comprehensive consumer-protection compliance programme. In addition, it committed to paying compensation to its Hungarian consumers. The cases serve as a clear warning to market participants that prolonged discounting, artificial urgency techniques and opaque reference-pricing practices may entail significant competition-law and consumer-protection risks.

Merger control

In 2025, the HCA acknowledged or cleared 62 concentrations by issuing official certificates in the eight-day fast-track procedure and granted clearance of a further merger in a Phase I proceeding. This continues a trend in the HCA's merger control practice of clearing concentrations quickly and efficiently. An effective pre-notification system plays a significant role in this, somewhat compensating for the still relatively lengthy filing form compared to other countries.

Sector inquiries

The HCA conducted three accelerated sector inquiries over a 15-month period to identify the causes of single-bid public procurements and to develop proposals to strengthen competition. These proceedings followed the conditionality procedure launched by the European Commission in 2022, which highlighted shortcomings in Hungary's public procurement system, particularly the low level of competitive intensity. In 2024, the Hungarian Government asked the HCA to carry out targeted investigations in three affected markets: public procurement of imaging diagnostic equipment, passenger cars and trucks, and mosquito-control services. In all three cases, the HCA put forward proposals aimed at boosting competition, such as encouraging partial bids, improving the timing of procurements, and launching training and support schemes. The findings suggest that the competitive concerns observed in the affected markets stem primarily from structural and market-specific factors rather than unlawful conduct. Nevertheless, the HCA continues to actively use accelerated sector inquires, in which it is entitled to resort to dawn raids.  

The HCA also initiated accelerated sector inquiries into the Hungarian market for milk and other dairy products and eggs, demonstrating its continued focus on the food sector and food prices in Hungary.

You can find a more detailed summary here.

Outlook and focus for 2026

In 2026, the HCA is expected to continue its robust and active enforcement against cartels, with a particular focus on infringements affecting public procurement. Based on the authority's public statements at the end of 2025, it intends to maintain heightened scrutiny of construction and other markets involving the use of public funds. At present, there are ten ongoing cartel proceedings in the construction sector alone, with case handlers examining more than 500 public procurement tenders within the framework of these investigations. A significant number of these cases are expected to enter a substantive phase or reach a conclusion in 2026, foreshadowing further decisions and imposition of fines. In public procurement cartels companies must also be aware of the risk of criminal liability and exclusion from public procurement procedures, in addition to competition law sanctions.

At the same time, according to the HCA's late 2025 press release, cooperation-based enforcement will remain a key feature of its approach in 2026. The HCA will continue to actively promote its leniency policy, which offers companies that disclose infringements or cooperate effectively during proceedings the possibility of a reduction in fines or even full immunity. Settlements can result in 10-30 % reductions of the fines, and a combination of the two can lead to a significant reduction.

We also expect that in 2026 the HCA will continue to place strong emphasis on enforcement against unfair commercial practices affecting consumers. Last but not least, the HCA is likely to make use of its newly granted powers in relation to undertakings with paramount significance. 

authors: Anna Turi, Tamás Vetró