The activities the MNB authorises follow PSD2 directly. Initial-capital tiers transpose Article 9(1) PSD2: EUR 20,000 for a PI providing only money remittance, EUR 50,000 for a PI providing only payment-initiation services, and EUR 125,000 for a PI operating payment accounts, executing credit transfers, direct debits, or card payments, or issuing and acquiring payment instruments. The third tier is the one most acquirer theses sit on. Own funds are then maintained on a continuous basis under one of the three PSD2 calculation methods, with active issuers and acquirers commonly running on the volume-linked Method B that scales required own funds to the average monthly payment volume executed.

Customer payment funds must be safeguarded: held in a segregated account at a credit institution, or covered by an insurance policy or comparable financial guarantee from an institution outside the PI’s group. The acquirer inherits the named safeguarding-bank relationship at signing, which is why we screen banking continuity before any target reaches the brief. ICT and operational-resilience expectations follow DORA (Regulation EU 2022/2554), which has applied to Hungarian PIs since 17 January 2025; the MNB has been explicit on its supervisory disclosures that incident-reporting readiness and third-party ICT-provider registers are now part of the live file. AML/CFT supervision runs in parallel under Hungary’s AML Act, with MNB on-site reviews testing transaction-monitoring rules, sanctions screening cadence, and the seniority of the appointed compliance officer.

One nuance worth flagging early. A Hungarian PI safeguards client funds primarily on Hungarian-bank counterparties, which produces a forint-denominated safeguarding overlay even when the PI’s commercial flows run in euro. That detail is operationally cheaper than EUR-area peers, since Hungarian credit-institution custody is materially less expensive than Frankfurt or Luxembourg. It also creates an FX-management line item for any foreign acquirer running multi-currency books, a question experienced acquirers ask in the first call and one no de-novo licensing page raises.

Acquisition runs through a share purchase of the entity holding the MNB authorisation, with prior MNB approval under the qualifying-holdings regime. Hungarian law defines a qualifying holding as 10 per cent or more of capital or voting rights, or any holding sufficient to exercise significant influence over management. The fit-and-proper assessment covers beneficial owners, the proposed members of the management body, group-structure transparency, the source and provenance of funds, and the strategic plan for the PI post-acquisition. The MNB consults the home supervisor of any EU-regulated acquirer. The assessment clock under the EBA/ESMA/EIOPA Joint Guidelines runs sixty working days from a complete file, extendable by thirty working days in defined cases. Subsequent crossings of the 20%, 33%, and 50% thresholds, and any agreement giving the buyer control, also require prior MNB approval; notification to the MNB is due within thirty days of execution of the transfer agreement.

One procedural note worth flagging early. MNB filings can be conducted in English at the supervisory-correspondence level, but statutory documents (articles of association, shareholder resolutions, audited accounts of the acquirer) are commonly requested with sworn Hungarian translation. That is a real difference from peer regulators that fully accept English files. Planning sworn translation early removes the most common cause of clock pauses. See the four-step acquisition process on the homepage for the standing checklist that runs in parallel.