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Pay Later or Regulated Credit? Hungary Redraws the BNPL Line

Hungary
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Buy Now, Pay Later (BNPL) is a short-term deferred payment solution that allows consumers to receive goods or services immediately and pay later, typically interest-free if payment is made on time.

In Hungary, BNPL has mainly been used in online retail by consumers, especially younger digital shoppers, through offers such as “pay in 30 days” or instalment payments at checkout. Until recently, these products were widely used by large online merchants and fintech providers since they boosted sales while appearing simpler than traditional consumer credit.

Until 2025, BNPL largely fell outside Hungarian consumer credit regulation if the payment deferral was short-term and interest-free. Under the Consumer Credit Act (Act CLXII of 2009), many BNPL structures were exempt from licensing, creditworthiness checks and extensive consumer disclosures, which allowed “pay later” options (often up to 30 days or more) to operate in a regulatory grey area. This changed in December 2025, when the Hungarian Parliament adopted amendments to the Consumer Credit Act by introducing the first explicit, BNPL-focused regulatory framework, aiming to close loopholes primarily used by large online platforms.

Under the new rules, most BNPL arrangements will qualify as regulated consumer credit, unless they fall within narrowly defined short-term exemptions. For large online merchants, interest-free deferred payment outside consumer credit law will generally be limited to 14 days, while longer deferrals or third-party BNPL providers trigger full consumer credit obligations. The new regime is expected to apply from 20 November 2026, aligning with broader EU consumer credit reforms, and will be binding on BNPL providers, large e-commerce platforms and, to a more limited extent, smaller merchants offering deferred payment options to Hungarian consumers.

By Borbala Maglai, Attorney at Law, KCG Partners Law Firm

Hungary Knowledge Partner

DLA Piper is a global law firm with lawyers located in more than 40 countries throughout the Americas, Europe, the Middle East, Africa, and Asia Pacific. This positions us to help clients with their legal needs around the world.

With more than 60 lawyers, including 14 partners, and a staff of over 140, DLA Piper Hungary is one of the largest international law firms operating in Hungary. What makes us stand out is that we offer not only legal services but also tax and business advisory support in a fully integrated manner. We maximize synergies between legal, tax, and business advisory services to offer a unique service for our clients, particularly in regulated industries such as energy, infrastructure, life sciences, banking, and telecommunications.

We are a true full-service firm, providing our private and public sector clients with advice on all aspects of their business. This includes transaction-related advice, people and employment, commercial dealings, litigation, information technology, media and communications, intellectual property, insurance, tax, real estate, and restructuring plans.

DLA Piper Hungary has received numerous professional awards and is consistently ranked among the top law firms in Hungary by international rankings. We are ranked #1 by Mergermarket among the law firms active in Hungary based on the volume of M&A deals handled between 2005 and 2024.

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