In brief
Important amendments to Hungarian Government Decree no. 13/2011 (“Decree”) on the authorization of trade in dual-use items have entered into force. Together with Regulation (EU) 2021/821, which establishes the Union regime for controlling the export, brokering, technical assistance, transit and transfer of dual-use items, the Decree forms the foundation of the national legal framework governing dual-use product export controls.
Main changes
On 25 December 2025 and 1 January 2026, the following important amendments of the Decree came into force:
- Deadline extension: The statutory deadline for all export authorization proceedings is extended from 25 to 45 days.
- Simplified reporting: Annual exports under Union General Export Authorizations must be reported once — by 31 January of the following year. (Reporting of exports under Global Export Authorizations remains semi-annual.)
- New grounds to revoke authorizations: Issued export authorizations may be revoked if their use results in criminal offense (e.g., offenses involving dual-use items, violation of international economic sanctions).
- Stricter registry requirements: Exporters may be removed from the exporter register not only after five years of inactivity, but also for failing to report changes in registered data within eight days or for failing twice consecutively to meet reporting obligations under the Union general or global export authorizations.
- Enhanced authority oversight: The Export Control Authority (Budapest Főváros Kormányhivatala or BFKH), in cooperation with the Customs Authority (Nemzeti Adó- és Vámhivatal or NAV), may verify during customs procedures whether the conditions laid down in the sanctions provisions are met and that related obligations are fulfilled.
- New grounds to impose fines: Activities requiring notification to authorities but not requiring authorization (e.g., related to Paks II under Article 12h of Regulation (EU) 833/2014) may incur fines of up to HUF 600,000 if not notified within two weeks.
- General clause to impose fines: In addition to specific grounds, the Decree also introduces a general clause under which a fine of up to HUF 5 million can be imposed for breach of obligations arising from international sanctions. In practice, this is intended to cover any breaches of sanctions-related obligations by exporters.
Recommended actions
- Revise internal export timelines: Allow additional time to obtain the necessary export authorizations due to the extended statutory deadlines.
- Prepare for more rigorous scrutiny: NAV and BFKH will more closely monitor compliance with all international-sanctions-related obligations and conditions. More frequent checks of export documentation (e.g., export-related contractual clauses, enhanced due diligence materials and stakeholder risk-assessment documents) are expected.
- Be compliant: In light of the newly introduced general clause on fines, revising all export documentation templates is strongly recommended to mitigate related risks. In particular, we recommend: (i) revising clauses prohibiting re-export to Russia and Belarus pursuant to Article 12g of Regulation (EU) 833/2014 and Article 8g of Regulation (EC) 765/2006; and (ii) reviewing all documents related to enhanced due diligence of all export transaction participants pursuant to Article 12gb of Regulation (EU) 833/2014 and Article 8ga of Regulation (EC) 765/2006.
Related content
- Government Decree no. 13/2011 on the authorization of trade with dual-use items (in Hungarian)
- Explanatory memorandum to Government Decree 390/2025 (XII. 10.) amending Government Decree 13/2011 (II. 22.) on the authorisation of the external trade in dual-use items (in Hungarian)
- Directive (EU) 2024/1226 of the European Parliament and of the Council of 24 April 2024 on the definition of criminal offences and penalties for the violation of Union restrictive measures and amending Directive (EU) 2018/1673
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