2024 brought with it several important changes to Hungarian consumer protection regulations, most notably the changes to mandatory warranty rights. The Hungarian Consumer Protection Authority (“HCPA“) is also devoting significant effort into enforcing these rights in 2025.
As online sales remain a key driver for consumer spending, the HCPA keeps a strong focus on e-commerce platforms and online sales that target Hungarian consumers. As part of its annual “review plan”, the HCPA recently issued a list of areas that will receive increased scrutiny, which include:
- the manipulation of or tampering with consumer reviews;
- price display and regulations related to price monitoring systems;
- compliance with applicable marketing and advertising regulations (in particular if they target or can potentially harm minors);
- a comprehensive and sweeping compliance review of domestic as well as international e-commerce platforms;
- a review of vendor compliance with warranty and refund-related regulations;
- compliance with product safety and labelling regulations; and
- any form of “greenwashing”.
This increased scrutiny is in line with the launch of recent proceedings initiated by the Hungarian Competition Authority (“HCA“) against two major online sales platforms.
A recent proceeding against a Romanian-based international sales platform aimed to verify whether the company had fulfilled the commitments it made in 2021, particularly the nearly HUF 3 billion program it had planned as a means of support for Hungarian businesses. Based on earlier findings by the HCA, the platform’s pricing practices did not ensure that “original” prices reflected the actual typical prices of products.
The HCA also launched an investigation into a Polish online marketplace that operated in Hungary in Hungary as well, suspecting that the company misled consumers with its “Lowest Price Guarantee” campaigns. According to the HCA, the online marketplace did not provide adequate information about the terms of the price guarantee and customers found it difficult to access crucial details. Furthermore, the warranty system included restrictive conditions that made it harder for consumers to enforce their claims and use the coupons they were issued.
In summary, it appears that the relevant Hungarian authorities will continue to remain focused on online sales and compliance with applicable consumer protection, unfair competition and marketing regulations in 2025.
By Miriam Fuchs and Peter Ihasz, Senior Associates, and Bence Andras Kiraly, Associate, Wolf Theiss
