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New Decrees on ESG Consultants and Educational Institutions Entered into Force

Hungary
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In the Hungarian Gazette of 8 August 2024, four long-awaited decrees were published, which supplement and detail the provisions of the Hungarian ESG Act.

The decrees contain provisions in particular on the accreditation procedure and registration of ESG consultants, accreditation requirements and education of ESG consultants and criteria for institutions providing education for ESG consultants. Three of the four decrees entered into force on 9 August and one entered into force on 12 August.

Detailed procedural rules for the accreditation of institutions providing education for ESG consultants have been laid down. Accreditation under the Government decree is carried out by the Enterprise Development Agency (Magyar Gazdaságfejlesztési Ügynökség) and applications for accreditation may be submitted by recognised upper education institutions. The second (NGM) decree sets out provisions on the requirements for the accreditation of institutions providing education, the register of accredited institutions, the education of ESG consultants and fees for education and examination. Requirements for accreditation include, inter alia, that the applicant institution is not subject to bankruptcy or liquidation proceedings, is a taxpayer without public debt, and has at least two instructors who are registered as accredited ESG consultants under the ESG Act. The applicant shall also declare that it keeps the ESG course material up to date and will take on the task of providing further education for ESG consultants, by providing at least fifty hours of training and organising a professional conference. The register of accredited institutions is kept by the Enterprise Development Agency. The specific conditions for ESG consultant education and the minimum requirements for the course material are set out in Annex 1 of the NGM decree.

The requirements for accreditation as an ESG consultant are set out in an NGM regulation, under which both natural and legal persons can be accredited. According to this NGM regulation, in procedures initiated by 30 June 2025, the accreditation of ESG consultants is not conditional on the acquisition of a qualification, but only on the proof of a specific period of professional practice. In addition to other conditions for accreditation, legal entities must employ at least two natural persons who are registered as ESG consultants and who are employed or otherwise engaged in an employment relationship with the legal entity for at least 30 hours per week.

The fourth (SZTFH) decree sets out the rules of procedure for accreditation as an ESG consultant and the registration of ESG consultants, which is carried out by the Supervisory Authority for Regulated Activities (SZTFH).

We are still waiting for the publication of regulations which set out important detailed rules for the application of the provisions of the ESG Act, thus monitoring the legislation is highly recommended.

By Eszter Kamocsay-Berta, Managing Partner, KCG Partners Law Firm

Hungary Knowledge Partner

Nagy és Trócsányi was founded in 1991, turned into limited professional partnership (in Hungarian: ügyvédi iroda) in 1992, with the aim of offering sophisticated legal services. The firm continues to seek excellence in a comprehensive and modern practice, which spans international commercial and business law. 

The firm’s lawyers provide clients with advice and representation in an active, thoughtful and ethical manner, with a real understanding of clients‘ business needs and the markets in which they operate.

The firm is one of the largest home-grown independent law firms in Hungary. Currently Nagy és Trócsányi has 26 lawyers out of which there are 8 active partners. All partners are equity partners.

Nagy és Trócsányi is a legal entity and registered with the Budapest Bar Association. All lawyers of the Budapest office are either members of, or registered as clerks with, the Budapest Bar Association. Several of the firm’s lawyers are admitted attorneys or registered as legal consultants in New York.

The firm advises a broad range of clients, including numerous multinational corporations. 

Our activity focuses on the following practice areas: M&A, company law, litigation and dispute resolution, real estate law, banking and finance, project financing, insolvency and restructuring, venture capital investment, taxation, competition, utilities, energy, media and telecommunication.

Nagy és Trócsányi is the exclusive member firm in Hungary for Lex Mundi – the world’s leading network of independent law firms with in-depth experience in 100+countries worldwide.

The firm advises a broad range of clients, including numerous multinational corporations. Among our key clients are: OTP Bank, Sberbank, Erste Bank, Scania, KS ORKA, Mannvit, DAF Trucks, Booking.com, Museum of Fine Arts of Budapest, Hungarian Post Pte Ltd, Hiventures, Strabag, CPI Hungary, Givaudan, Marks & Spencer, CBA.

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