Hungary's insolvency legislation has undergone significant revision, with amendments that directly alter how creditors participate in insolvency proceedings. International businesses with Hungarian counterparties, subsidiaries, or outstanding receivables face changed procedural rules. Acting without understanding these changes risks losing enforcement rights that cannot be recovered after key deadlines pass.
Hungary's amended insolvency legislation, effective from early 2025, introduces revised rules governing proof of debt submission, creditors meeting procedures, and the powers of the administrator and liquidator. Creditors must file claims within tightened statutory windows or risk permanent exclusion from distributions. International companies holding Hungarian receivables should treat compliance with the new rules as an immediate operational priority.
This alert explains what changed, which businesses are affected, and the concrete steps required before compliance deadlines close.
What changed and when it took effect
Hungary's insolvency law amendments entered into force in early 2025. The changes affect two distinct procedures under Hungarian insolvency legislation: csődeljárás (reorganisation proceedings) and felszámolási eljárás (liquidation proceedings).
The most significant change concerns the proof of debt process. Creditors must now submit their claims in a prescribed electronic format through Hungary's centralised court portal. Paper submissions are no longer accepted in most proceedings. Claims filed outside this system are treated as invalid regardless of their substantive merit.
The amendments also modify the role of the administrator in reorganisation proceedings. Administrators now hold broader powers to challenge pre-insolvency transactions concluded within an extended look-back period. This period has been extended relative to prior law, exposing a wider range of intercompany payments and security arrangements to clawback risk.
In liquidation, the liquidator is now required to convene a creditors meeting within a shorter timeframe after appointment. The first creditors meeting must occur within 45 days of the liquidator's appointment. Creditors who do not attend or submit written representations lose the right to challenge the liquidator's asset valuation in subsequent proceedings.
The restructuring plan approval process has also changed. Under the revised rules, a restructuring plan can now be approved by a qualified majority of creditors by value, without requiring unanimity among all creditor classes. This reduces the blocking power of minority creditors but also limits their ability to negotiate individual arrangements outside the formal plan.
International creditors operating through EU-based entities should note that the amendments align several procedural requirements with the EU Restructuring and Insolvency Directive. However, Hungary's implementation contains additional domestic conditions not found in the Directive text itself.
Who is affected and which thresholds apply
The amended rules apply to all insolvency proceedings commenced on or after the effective date in early 2025. Proceedings already underway continue under prior rules unless a court orders transition by reasoned decision.
The changes are most consequential for three categories of international business:
- Foreign suppliers and trade creditors holding unsecured receivables against Hungarian debtors – the tightened proof of debt deadlines apply immediately upon the opening of proceedings.
- Intercompany lenders and group treasury entities – the extended clawback window exposes intragroup payments made before the insolvency trigger date to administrator challenge.
- Secured creditors and financial institutions – the revised creditors meeting rules affect voting rights and the ability to block or shape a restructuring plan.
The threshold for mandatory notification to creditors has been lowered. A debtor in reorganisation must now notify all creditors holding claims above a reduced minimum value within five business days of court acceptance of the reorganisation petition. Creditors below this threshold are notified by public register entry only.
For foreign creditors, the risk is practical as much as legal. A creditor that misses the proof of debt window because it was unaware that proceedings had opened – or because it submitted documents in the wrong format – forfeits its right to participate in distributions. Courts in Hungary have consistently declined to admit late claims except in cases of demonstrable court error. The consequence is the permanent loss of recovery on that receivable.
To receive an expert assessment of your creditor position under the amended Hungarian insolvency legislation, contact us at info@ferrazwhitmore.com.
Immediate actions for international companies
Businesses with Hungarian exposure should act on the following points without delay.
Audit Hungarian counterparty exposures. Identify all outstanding receivables, loans, and contractual obligations owed by Hungarian entities. For each exposure, determine whether any counterparty is showing signs of financial distress – delayed payments, restructuring announcements, or court register notifications are the earliest indicators.
Register for court portal access. Foreign creditors must obtain access to Hungary's centralised court insolvency portal before proceedings open. Registration after the fact does not extend filing deadlines. Engaging a local representative with portal access is strongly advisable for creditors without a Hungarian legal presence. Our insolvency and restructuring practice in Hungary provides creditor representation across both reorganisation and liquidation proceedings.
Review intercompany transaction exposure. Group treasury teams should map all payments made to or from Hungarian subsidiaries within the extended look-back period. Transactions that could be characterised as preferential or undervalue should be assessed against the new administrator challenge powers before a claim is filed against your entity.
Update internal monitoring protocols. Subscribe to the Hungarian company register notification service for all material counterparties. Court acceptance of a reorganisation petition or appointment of a liquidator triggers the proof of debt clock immediately. Businesses relying on manual monitoring frequently miss these events. For context on related corporate disputes in Hungary, procedural timelines are equally strict across insolvency-adjacent litigation.
Prepare standardised proof of debt templates. Under the amended rules, the prescribed electronic format requires specific data fields that differ from standard invoice or contract documentation. Preparing compliant templates in advance avoids last-minute errors that result in claim rejection. For a comparative perspective, our alert on insolvency amendments in Portugal covers parallel developments in another EU civil law jurisdiction.
The compliance deadline for existing proceedings is the relevant court-set date within those proceedings. For new proceedings commenced after early 2025, the statutory proof of debt window runs from the date of the official creditor notification – typically 30 to 40 days. Missing this window is not recoverable.
About Ferraz & Whitmore
Ferraz & Whitmore is an international law firm based in Lisbon, advising business clients across 46 jurisdictions on insolvency, restructuring, and creditor rights matters. Our team combines Portuguese civil law expertise with English common law tradition to deliver cross-border insolvency solutions in Hungary and across Central and Eastern Europe. As an international law firm in Hungary advising foreign creditors, we support clients through proof of debt processes, creditors meeting representation, and administrator or liquidator engagement. Our attorneys have experience before Hungarian courts in both reorganisation and liquidation proceedings, and our cross-border practice covers the full range of EU restructuring legislation. We work with international entrepreneurs, institutional investors, and in-house legal teams who require a lawyer in Hungary with multi-jurisdictional capability. To discuss your creditor position or restructuring exposure in Hungary, contact us at info@ferrazwhitmore.com.
Disclaimer: This publication is provided for informational purposes only and does not constitute legal advice. The information herein should not be relied upon as a substitute for professional legal counsel tailored to your specific circumstances. Ferraz & Whitmore assumes no liability for actions taken or not taken based on the contents of this material. For advice regarding your particular situation, please contact info@ferrazwhitmore.com.