Is cold email legal in Hungary? B2B rules for 2026
2026-10-25 · updated 2026-10-25 · 8 min read · Adam Axelsson, founder of Revexa
To company addresses, yes: Hungary's consent rule for marketing email, section 6(1) of Act XLVIII of 2008 on commercial advertising (Grt.), protects only natural persons. A company's info@ address needs no consent, as long as the email is labelled as advertising and names the real sender, and (in our reading) you stop when the company says no. Sole traders (egyéni vállalkozó) need prior, express consent, and for named employees the law is unclear. An email that only asks for consent counts as advertising itself, in our reading the law has no soft opt-in, and we found no guidance on LinkedIn.
Checked on 25 October 2026 against the law texts and the regulators' guidance. This is not legal advice.
Unlike Austria and Poland, Hungary does not require consent for company addresses. All countries: cold email laws by country.
Hungary at a glance
| Situation | Rule | Source |
|---|---|---|
| Generic company address (info@) | No consent needed; label it as advertising, show the real sender, stop when the company objects (our reading) | Grt. § 6(1); Ekertv. § 14/A; Eht. § 162(2) |
| Named employee | Unclear (our cautious reading: consent) | Grt. § 6(1); NMHH |
| Sole trader (egyéni vállalkozó) | Prior, express consent | Grt. § 6(1); Act CXV of 2009 § 2(1) |
| Email asking for consent | Counts as advertising; needs prior consent where § 6 applies | Ekertv. § 14(2); NMHH |
| Existing customers (soft opt-in) | No exception in the law (our reading) | Grt. § 6 |
| LinkedIn and social DMs | No guidance found (our reading: covered for natural persons) | Grt. § 6(1); Ekertv. § 14(1) |
| Regulator | NMHH (consent for electronic advertising); consumer protection authority (labelling); NAIH (GDPR) | Grt. § 24(4); Ekertv. § 16/A(1) and (3) |
| Maximum fine | HUF 50,000 to 500,000 per NMHH decision, again for repeat breaches; GDPR fines on top | Ekertv. § 16/D(2) |
What the law says
The ePrivacy Directive requires consent for marketing email only for "subscribers who are natural persons" (Article 13(5)). Hungary implements it across three acts. Section 6(1) of the Grt., in the version in force on 25 October 2026:
"Ha külön törvény eltérően nem rendelkezik, reklám természetes személynek mint reklám címzettjének közvetlen megkeresése módszerével (a továbbiakban: közvetlen üzletszerzés), így különösen elektronikus levelezés vagy azzal egyenértékű más egyéni kommunikációs eszköz útján ... kizárólag akkor közölhető, ha ahhoz a reklám címzettje előzetesen egyértelműen és kifejezetten hozzájárult."
Our translation: "Unless a separate act provides otherwise, advertising may be communicated to a natural person, as its recipient, by direct approach (direct marketing), in particular by electronic mail or another equivalent individual means of communication, ... only if the recipient has given prior, unambiguous and express consent."
Consent can be withdrawn at any time, free of charge (6(3)); senders must keep a register of consents (6(5)) and say in each message where to withdraw, both by post and by email (6(6) and (7)).
The e-commerce act (Ekertv., Act CVIII of 2001) defines electronic advertising as advertising sent through any information society service or electronic communications, voice calls excepted (section 14(1)), and adds:
"Elektronikus hirdetésnek minősül az olyan közlés is, amelynek célja kizárólag a Grt. 6. §-ának (1) bekezdésben előírt hozzájárulás kérése."
Our translation: "A communication whose sole purpose is to request the consent required by section 6(1) of the Grt. also counts as electronic advertising" (14(2)). Every electronic advertisement, whoever receives it, must be identifiable as advertising and show the real sender (14/A(1)).
The electronic communications act (Eht., Act C of 2003) bans direct marketing outside section 6 of the Grt. to a subscriber that has said it does not want it (section 162(2)): in our reading, the opt-out protecting companies. Official texts in the National Legislation Database: Grt., Ekertv., Eht..
What the regulators say
NMHH, the National Media and Infocommunications Authority, enforces section 6 for email and other electronic advertising (Grt. section 24(4); Ekertv. section 16/A(3)). Its page on electronic advertising draws the line plainly:
"A jogi szabályozás tiltja az elektronikus hirdetések kéretlen küldését, ha azokat nem cégnek, kapcsolattartónak, hanem egyszerű magánembernek küldik."
Our translation: "The law prohibits sending unsolicited electronic advertising if it is sent not to a company or a contact person but to an ordinary private individual" (NMHH, undated page). Its procedural guide (updated 23 February 2026) adds that NMHH has no competence where the advertisement was not sent to "természetes személy elektronikus elérhetőségére" (a natural person's electronic address), nor over a foreign advertiser's message not aimed at Hungary, such as one in another language (NMHH). In our reading, the foreign-language point limits who can act, not the rule. A natural person's address published on a website is not consent (NMHH).
The consumer protection authority enforces most of the rest of the advertising act (Grt. section 24(1); the central bank does so for financial services) and, by default, the labelling rule in Ekertv. section 14/A, which section 16/A(1) gives to the authority under the unfair commercial practices act (Act XLVII of 2008). GVH, the competition authority, acts under that act when a practice can significantly affect competition; that act protects consumers only. We found no guidance from either on B2B email.
Named employees, sole traders and the first email
- Named employees: unclear. Section 6 protects a natural person as recipient, and a firstname.lastname@ address belongs to one. NMHH's overview leaves a company's "kapcsolattartó" (contact person) outside the ban, but its procedural guide turns on whether the address is a natural person's, and we found no decision. Our cautious reading: consent.
- Sole traders: an egyéni vállalkozó is a natural person carrying on business (Act CXV of 2009, section 2(1)), so consent first.
- The first email: asking for consent by email is itself electronic advertising (Ekertv. 14(2)). NMHH calls permission-request emails unlawful and says they need "előzetes (!)" (prior) consent too (NMHH). A generic company address falls outside the consent rule.
LinkedIn and social media messages
No guidance found from NMHH, NAIH or a Hungarian court. Section 6(1) covers email "or another equivalent individual means of communication", and the e-commerce act covers advertising through any information society service; NMHH's own examples are email, SMS, MMS and fax. Our reading: a LinkedIn sales message to a natural person in Hungary needs prior consent, and so does one that only asks for it.
GDPR and NAIH
NAIH, the data protection authority, accepts legitimate interest for direct marketing only with a balancing test. In a 2022 newsletter decision it wrote that a company relying on it "must support this with a balancing test under recital (47) of the GDPR", and that after an objection it "has no discretion" over deleting the data (NAIH-1091-10/2022, our translation, PDF).
When the data come from another source, say where you got them "at the latest at the time of the first communication" (GDPR article 14(3)(b)). NAIH fined Amplifon Magyarország HUF 80 million on 11 August 2022, partly for missing article 14 information in letters to people whose addresses came from the Interior Ministry (B2C, post; NAIH-5802-9/2022, PDF). Legitimate interest does not replace the section 6 consent (our reading); more in GDPR and B2B email under legitimate interest.
Fines and real cases
NMHH can order a breach to stop, ban further sending and impose an "elektronikus kereskedelmi bírság" of HUF 50,000 to 500,000, again for repeat breaches (Ekertv. section 16/D); proceedings must open within one year of the advertisement (16/C(4)). The injured party can also go to court (Grt. section 24(5)), and NAIH can fine under GDPR article 83.
We found no NMHH, NAIH or court decision on B2B email to a company or a named employee. NMHH lists 61 e-advertising decisions, the newest from 2023, and those we read concern private recipients:
- Droppy Kft., K/23230-7/2023: HUF 400,000 for a repeat breach: a coupon newsletter sent without consent on 28 October 2023, and failing to honour unsubscribes (B2C) (NMHH).
- Saldo Zrt., EF/1946-6/2014, dated 31 March 2014: HUF 75,000 for emailing a tax journal offer to a natural person it had been ordered in 2012 to stop emailing; a professional product, but a private recipient, so not B2B in our count (NMHH).
Checklist for B2B email to Hungary
- Check the legal form: a Kft. or Zrt. at info@ is outside the consent rule, an egyéni vállalkozó is not.
- Get prior, express consent before emailing a natural person, keep a register, and never treat a published address as consent.
- Do not email a natural person to ask for consent.
- Label every email as advertising, show the real sender and stop when a company says no.
- Give natural persons an email and a postal address for withdrawal in every message.
- Document your legitimate-interest test, say where you got the data and keep a suppression list.
How Leo handles Hungary
Leo, the buying-signal agent Revexa builds, blocks only Germany automatically (UWG §7), not Hungary. Leo writes to named people, so in our cautious reading most Hungarian leads need consent, and you read and approve every draft in review mode, so whether a Hungarian lead has consented is yours to check before you approve. Leo writes to each lead in the lead's own language when your website exists in that language, and in English otherwise. It is the wrong choice if you need software that checks Hungarian consent for you.
More countries: Czech Republic, Estonia, Greece and Romania.
Common questions
Is B2B cold email legal in Hungary?
To company addresses, yes. Section 6(1) of the advertising act (Grt.) requires prior, express consent only when the recipient is a natural person. Sole traders need consent, named employees are unclear, and the law has no soft opt-in for existing customers (our reading).
Do I need consent to email a named employee in Hungary?
Possibly. The law protects natural persons, and a named work address belongs to one, but NMHH describes the ban as covering private individuals rather than a company's contact person. With no decision on the point, the cautious choice is consent.
Can I send an email asking for consent in Hungary?
Not to a natural person. Section 14(2) of the e-commerce act treats a message whose only purpose is to ask for consent as electronic advertising, and NMHH says such messages need prior consent themselves.
What are the fines for cold email in Hungary?
NMHH can fine HUF 50,000 to 500,000 per decision, again for repeat breaches, and NAIH can fine under GDPR. We found no published fine for B2B email.