I. THE VALUATION
I.1 Regulatory Framework
| a) Is there a legal framework in your Member State for the valuation of real estate for lending purposes (loan origination)? If yes: • Is this framework specifically for the valuation of real estate for lending purposes or are provisions enshrined in a broader piece of legislation? • Is it limited to the transposition of European or International Standards or is it broader in nature? • Please provide references and indicate whether it applies to both residential and commercial property. If there are differences between both property types, please explain. |
The Hungarian property valuation activity in general is regulated by a decree issued by Misnistry of Finance (25/1997. (VIII. 1.) PM decree on the methodological principles for determining the collateral value of real estates.) The decree covers all the valuation processes including residential and non-residential (except agricultural lands) cases as well. (source (HUN): http://net.jogtar.hu/jr/gen/hjegy_doc.cgi?docid=99700025.PM ) Agricultural lands valuation should be done according to guidelines of decree issued by Ministry of Agriculture (54/1997. (VIII. 1.), what determines the framework of land valuations (including lands, fields, meadows, pastures, orchards, forests, fishing lakes and lakes) (source (HUN): http://net.jogtar.hu/jr/gen/hjegy_doc.cgi?docid=99700054.FM ) Additionally, all the Hungarian Mortgage Banks have to have their own inner regulation on determining collateral value, what must be approved by supervisory body (National Bank of Hungary). In addition there is a recommendation of the Hungarian National Bank (No. 18/2022 (XII.1.) on the management of real estate-related risks by financial institutions, which follows EU legislative changes and recommendations. The above mentioned regulatory instruments apply exclusively to property valuations conducted for credit institutions; however, they are frequently referenced when preparing Hungarian real estate valuations for other purposes. For business-oriented property valuations, these documents are regarded as the primary regulatory frameworks. The regulation itself does not refer to EVS or any other European standard. Compliance with international standards is a requirement imposed by banks, as stipulated in the relevant contracts. In addition, the Hungarian National Bank, acting as the supervisory authority, also expects adherence to these standards. |
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| b) If there is no specific legal framework, is the valuation of real estate for lending purposes covered by other means, e.g. self-regulation, sector recommendations or supervisory guidance? | We have legal framework. Financial institutions generally require compliance with international standards in relation to property valuations. |
| c) Do national valuation standards exist? Is there any cross-reference to European and/or International Valuation Standards (EVS/IVS)? | There is no national valuation standard. However, the relevant provisions of international standards are reflected in the recommendations issued by the Hungarian National Bank. |
| d) How has the regulator in your Member State transposed Article 19(1) of the MCD regarding “reliable standards” for the valuation of residential property (into legislation or delivered through a professional body)? Indicate whether and how “reliable standards” are defined and whether and how the content of those standards are prescribed. | Hungary implemented the MCD through amendments to its Act on Credit Institutions and Financial Enterprises and related ministerial decrees. Specifically, the Minister of Finance Decree 25/1997 (VIII.1.) on the methodological principles for determining the mortgage lending value of property was updated to align with the MCD. This decree sets out the rules for valuation methods used by credit institutions when granting mortgage loans. Hungarian law does not use the exact phrase “reliable standards,” but the concept is embedded in the requirement that valuations must be objective, independent, and based on market data. |
I.2 Valuation Bases & Methodology
| a) What valuation bases (Market Value, Mortgage Lending Value, etc.) are typically used in your Member State for the valuation of property for lending purposes (please disregard at this stage the specific requirements of Art. 229 CRR considering that the Property Value is not an independent basis of value). |
Market Value The market value is defined as the price which might be attained as of the date on which the valuation was processed, in the context of a business relationship and taking into account all legal facts, real qualities, other relationships and location of the real estate or another subject of the valuation, regardless of non-standard or personal relationships. Influences from exceptional circumstances of the market, personal relationships of the seller or of the purchaser or the influence of special popularity are not reflected in the market value. Extraordinary circumstances are deemed to be e.g. condition of distress of the seller or purchaser, or consequences of natural or other calamities. Personal relationships are understood to be, in particular, property relationships, family relationships or other personal relationships between the seller and purchaser. A special popularity is understood to be a special value attached to the property or service in light of the personal relationships to it. Market value is determined by a valuer making a prudent assessment of the property. Prudent assessment requires the following approaches: - Review of the future marketability of the property - Consider only the long term sustainable aspects of the property - Consider the normal and local market conditions - Highest and best use principal is not applicable (only the current use of the property may be considered) - Cost approach should be used as a control value only - If possible, all three valuation approaches should be applied (market, income and cost approach)* * In case of residential premises under 30million HUF, it is possible to determine and accept the value with the use of only one method (Market Comparison Method). Property professionals do not have information about the financial arrangements or about the borrower. Consequently, the valuer does not take into account the risks such as borrower risks, financial risks etc. Mortgage Lending Value The definition of MLV is written in a decree of Ministry of Finance 25/1997 for non-agricultural real estates and in the decree of Ministry of Agriculture 54/1997 for agricultural lands. In general the mortgage lending value may not exceed a usual price or market value of the real estate being assessed. The mortgage lending value is the property value gained via a careful assessment. During the calculation the specific risks originating from the long-term loans disbursed by mortgage banks and such features and yields of the property are taken into consideration that in the future any owner might face. When determining the mortgage lending value, in addition to the risks routinely analyzed, special attention must be paid to the following: - The risk of the long term stability of the value of the property; - The risk due to the unreliability of market value; - The risks due to the unreliability of other data; - the effects related to the enforcement of the claim (protection, sales costs, preservation). In order to mitigate the aforementioned risks: - a forecast should be prepared for the long term (at least for the loan period) regarding the market environment and the use and condition of the property; only those factors which are permanently valid may be taken into account; - Only the use of the property at the time may be taken into account and not the potential alternative use as result of a possible development, except for properties on building sites, which have not yet been constructed or completed; - If the circumstances refer to a right not registered in the land registry or an unrecorded fact, the situation must be clarified by contacting the related authority or examining the contract in case of a contract-based right; - In the interests of the reliability of the different market data, for all the applied market data including the sales-purchase comparison data, leasing data and building/construction costs at least 3 (5recommended) comparative sets of data should be provided and documented in a way that they can be accountable later; - 1All the data used in the valuation report must be identified in an accountable manner, and the accuracy of this data must be documented and assessed. Source: decree issued by Misnistry of Finance (25/1997. (VIII. 1.) PM decree) http://net.jogtar.hu/jr/gen/hjegy_doc.cgi?docid=99700025.PM |
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| b) Based on what definition? Please provide the definition and reference to where it can be located. | The market value of the property as defined in point 76 of Article 4(1) of Regulation (EU) No 575/2013 of the European Parliament and of the Council of 26 June 2013 on prudential requirements for credit institutions and investment firms and amending Regulation (EU) No 648/2012. |
| c) In case other valuation bases are used in your Member State for the valuation of property for lending purposes, please specify the effect, if any, on the final valuation. | Property valuations related to banks primarily focus on Market Value and Mortgage Lending Value. In exceptional cases - typically unrelated to lending purposes or not exclusively for that purpose - additional value types my be determined. These categories are also defined by the European Valuation Standards (EVS), such as Liquidation Value, Special Value, Technical Cost Value, Rental Value, etc. Such cases are rare and generally arise in response to specific client requests. |
| d) Depending on the valuation base used, which valuation approaches or methods (comparison, income, cost, etc.) are typically applied in your Member State to value properties for lending purposes in each category? |
a. Residential Properties: I. Comparison method II. Statistical-based valuation III. Investment/Income method IV. Depreciated replacement cost method b. Commercial Properties: I. Comparison method II. Depreciated replacement cost method III. Investment/Income method |
I.3 Valuation Report: Form & Content
| a) Does the legal or professional framework in your Member State specific to the valuation of properties provide minimum requirements in terms of the form and content of the valuation report? If yes, please indicate what these minimum requirements are. |
The valuation report prepared for mortgage lending purposes should contain the following: - Naming of principal; - Subject of the valuation; - Identification of the property, the valued legal title; - The exact task of the valuer (determining the market value and mortgage lending value for bank loans); - Usage of the property (used by the owner, rented out, kept for investment purposes); - Valuation methodology or methodologies used and the related justification; - Proposed mortgage lending value based on the established market value; - Date of site visit and the date of preparation of the report; - The rights relating to the use of the valuation report (not to be provided…); - Documentation and identification of the sources of the data used; - The site visit and its date; - Author and the participants in compiling the material, and the proof of their professional certification; - The authenticated or electronic signature of the valuer to validate the established value; - Description of the property according to the land registry and in real terms, the description of construction authority provisions, building rules and their expected changes; - Geographical situation, demography, economy of the environment in which the property is located and the description of other important issues from the point of view of the valuation; - Description of the economic environment in which the property is located that determines the current use of the property, its value and the future possibilities; - Description of the real estate market situation, including factual data; - Description of the immediate environment in which the property is located, including the situation of the property in the settlement network and its situation within the settlement, its accessibility, public transport connections, infrastructure; - Description of the use of the property, including the past, present and future users, the way in which the property is used, the intensity of use and the related financial consequences; - Description of the land, including the size, shape, relief, greenery, available public utilities, the extent to which it has been built on, the proportion of the land that can be built on, the buildings and features; - Description of the buildings, applying the “from far to close” principle, a detailed description of the primary and secondary building structures, and a description of their condition; - Definition of the applied measures to ensure comparability (areas: gross, net, useful…); - Protection of the property (either monumental or natural protection); - In the valuation report the presumptions must be listed based on which the valuation is valid. The steps and calculations of the valuation must be described in detail, in a straightforward and verifiable manner in the valuation report. The valuation report must be supported by annexes. - Copy of the authenticated title deed not older than 90 days before determining the mortgage lending value in accordance with the *national and banking provisions; - Copy of the original land registry map and an extract of the regulation plan if this is necessary for the identification of the property or for the valuation procedure; - Technical documentation and architectural drawings of the property. - Photos of the property, inside and outside - Contracts and other documents that are relevant to understand the legal situation of the property, including documents about mortgages; - Any other fact or data considered during the valuation Supporting documents for the compilation and verification of the external Valuation In particular the following supporting documents are required: - Copy of cadastral map from the Real Estate Register - Extract(s) from the Real Estate Register relating to any and all relevant units, buildings and lands (including co-owned properties), not older than 3 months - Purchase contract/acquisition title - Demolition decision / zone decision / construction permit / use permit decision / permit for change of use - Construction plans – sections, designs, views - Technical report / real estate description - Declaration of individual ownership (in case of an apartment ownership-structure) - Construction contract, including annexes / time schedule / cost budget - Lease Contract(s) / survey of rents. - Contracts for the establishment of the rights corresponding to easements - Contracts for the establishment of pre-emptive right |
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| b) Should the form and content of valuation reports be prescribed, are there differences between residential and non-residential properties? Please describe as appropriate. | The content of valuation for lending purposes is strictly prescribed by regulator and mortgage banks as well. |
| c) If the form or content of the valuation report are not prescribed, what form does the valuation report typically take? Please specify differences between residential and commercial property valuation reports. |
I.4 Technology & Valuation
| a) Does the legal or professional framework in your Member State provide specific rules/guidance on the use of digital valuation tools (AVMs, Artificial Intelligence etc.)? If yes, what does this consist of and is it restricted to a particular type of property? Please specify whether there is a correlation with the requirements of Article 208(3a) CRR and of section 7.4 of GLOAM or whether the latter provisions are of stand-alone application in your Member State. | It is possible to use AVM. The legal and regulatory references are the follows: Ministry of Finance Decree 25/1997 (5th appendix) and the bank's internal regulations. |
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| b) For what purpose are digital tools and/or AI employed in your Member State? - Mortgage origination, monitoring and review of property values, revaluation etc. - Capital requirements, covered bond funding, securitisation transactions, mortgage portfolio risk management etc. |
Any of the listed issues can be helped or done by digital tools. |
| c) Scope of digitisation: Please determine the scope of automated and digitised tools in your Member State. Are they confined to data collection, do they deliver reliable property values or are they even used to produce full or partial valuation reports including description of locations, infrastructure, building characteristics etc.? If the latter is the case, is internal data used or it is permitted to purchase data from an external data provider? |
AVMs can be used for mass mass or portfolio evaluations and with certain restrictions for loaning activities as well. Starting from November 2021, AVMs may also be prepared for first time valuations of the property set defined in Decree No. 25/1997 of the Ministry of Finance, in accordance with Recommendation No. 15/2021 of the Hungarian National Bank and the internal guidelines stipulated in OTP’s internal regulations. Statistical valuation can be applied if the property to be appraised: - is an apartment (not a family house or other type of real estate), - the floor area is maximum 150 m2 - is located in capital or its agglomeration, or in the country's major cities, - and is located in a settlement where at least 10 properties were sold in the last 1 year, and the registered purchase prices differ by no more than 30%. The requested loan amount and the encumbrances already registered on the property together cannot exceed 60% of the property's estimated value (mortgage lending value). This methodology cannot be used for ongoing constructions, only for completed properties! |
| d) Quality requirements: How are the reliability of the tools and their outputs assessed, e.g. by controlling the inputs, back-testing, supervision and/or plausibility checks by valuers etc.? | In banking operations mostly AVM results are examined afterwards by checking the values in a normal way. AVM is considered pretty accurate if it is based on an appropriate database. |
| e) Do you foresee an increase in the use of automation and digitisation of property valuation processes in the future? Please describe potential technological developments which could impact the valuation profession and accelerate its transformation, notably through the use of AI. | The future of the real estate valuation profession locally and in a wider range also will be shaped by the rapid advancement of data science and geospatial technologies, the integration of AI-driven solutions into our processes, the evolution of drone and laser technologies, and increasingly efficient communication. |
I.5 ESG, climate risk, transformation risk
| a) How are ESG factors and climate risk taken into consideration in the valuation process? Do Market Values and/or Mortgage Lending Values reflect the ESG characteristics of properties? | The classification of real estate assets from an ESG (Environmental, Social, and Governance) perspective requires a comprehensive evaluation of multiple factors. Energy performance certifications, specialized classifications, and other analyses, solutions serve as essential references in this process. These sources provide objective benchmarks that support informed decision-making and ensure alignment with sustainability standards and regulatory requirements. |
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| b) Are there rules in your Member State requiring assessment of EU Taxonomy alignment of a property in the valuation report and the subsequent impact of compliance/non-compliance on property values? |
No, Hungary does not currently require valuers to assess EU Taxonomy alignment or its impact on property values in official valuation reports. However, ESG and Taxonomy compliance are becoming significant in financing and investment decisions, which indirectly influences valuation practice. Future regulatory developments under CSRD may increase demand for such assessments, but formal valuation standards have not yet incorporated them. Banks and investors may request sustainability data or certifications. There are also institutes what use their own calculation models on determining ESG related factors that can affect a property and its value. |
| c) Are digitised tools and AI applied in order to capture and/or measure the impact of ESG factors and climate risk on property values? | not yet |
I.6 Market Initiatives
| a) Please describe any market initiatives which have been undertaken in your Member State (including cross border initiatives) and which have promoted market best practices and/or transparency of valuation practices. |
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II. THE VALUER
II.1 Regulatory Framework
| a) Is property valuation a regulated profession in your Member State (through legal, regulatory or statutory rules)? |
Under Hungarian regulations, engaging in professional real estate valuation activities requires at least a secondary-level general education and a specialized qualification in valuation, as well as registration in the central commercial register (National Register of Real Estate Valuers). Key applicable laws and recommendations include: - Decree No. 25/1997 (VIII.1.) of the Ministry of Finance (Annex 4 specifies the content and formal requirements of valuation reports, applicable for mortgage lending value determinations and generally followed in practice) - Decree No. 54/1997 (VIII.1.) of the Ministry of Agriculture - Act XXX of 1997 - Act LXXVIII of 1997 - Government Decree No. 253/1997 (XII.20.) - RICS Valuation Standards (Red Book, 6th edition, April 2010) - TEGoVA European Valuation Standards (EVS) - IVSC International Valuation Standards (IVS 2010) - Recommendation No. 11/2018 of the Hungarian National Bank (on managing real estate-related risks by financial institutions) - Recommendation No. 15/2021 (X.29.) of the Hungarian National Bank (on managing real estate-related risks by financial institutions) |
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| b) Is the use of the title of valuer protected in your Member State? If yes, by whom? | Yes, the valuer’s role is protected to some extent. Valuers have to have education an licence. To practice the profession, one must be listed in the official chamber register (National Register of Real Estate Valuers) |
| c) If the title of valuer is not protected in your Member State, how do lenders ensure that they work with ‘qualified’ valuers? Are there ‘professional’ certifications for property valuers in your Member State? If yes, please name them. | |
| d) Is the regulatory or professional framework the same for all valuers, whether they value residential and/or commercial property? Or are there differences? Please describe as appropriate. | There is no difference in the legal framework. In Hungary, colleagues are usually only allowed to value non-residential properties after sufficient professional experience. |
II.2 Qualification and Independence
| a) The qualified valuer • How has the regulator in your Member State transposed the requirements of Article 19(2) of the MCD, of Articles 229(1) and 208(3b) of the CRR regarding the instruction of “professionally competent valuers” or valuers who possess the “necessary qualifications, ability and experience” (transposition through legislation or by self-regulation)? Indicate how professional competence and qualification requirements are prescribed. |
Hungary enforces the requirement for “professionally competent valuers” through a combination of national legislation (Government Decree 462/2015), professional self-regulation, and direct application of CRR. Competence is defined by independence, formal qualifications, and experience, with standards prescribed via law and professional guidelines aligned to IVS/EVS and RICS. |
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| a) The qualified valuer • If professional competence, qualification, ability and experience requirements are not prescribed, what is general practice with regard to professional qualifications? |
In addition to advanced real estate appraiser training, banks require liability insurance. Also, the appraiser must be a member of a professional professional organization (MAISZ, TEGoVA, RICS). Professional experience is also a basic requirement for cooperation. A clean criminal record is also required. |
| b) The independent valuer • How has the regulator in your Member State transposed the provision in Article 19(2) of the MCD or in Articles 229(1) and 208(3)(b) of the CRR regarding “sufficient independence from the credit underwriting process” or “independence from the loan processing and loan decision process” (through legislation or delivered through self-regulation)? Indicate whether and how the requirement is defined and whether and how it is prescribed. |
Points X. and XI. of Recommendation of the Hungarian National Bank - No. 18/2022. (XII.1.) apply here (on the management of real estate-related risks of financial institutions). Banks typically regulate this issue in their own regulations. |
| b) The independent valuer • If “sufficient independence” is not prescribed, what is general practice to ensure the valuer is unbiased and not subject to undue pressure? |
Financial institutions typically guarantee the involvement of independent contributors in their service contracts for lending and valuation. |
II.3 External vs. Internal
| a) Does the legal or professional framework in your Member State specific to the valuation of property for lending purposes lay down rules for banks and lenders as to whom they may use to value properties? • If yes, do credit institutions have the possibility to employ both internal and external valuers? • Is one type of valuer typically employed more frequently than the other? |
The Bank’s internal regulations set out the professional requirements for valuers and define the procedure for selecting the individual responsible for the valuation. Yes. No. |
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| b) If there is/are no legislation/rules regarding the use of external and internal valuers, what is typical practice? | Most financial institutions (the most significant real estate valuation clients in terms of numbers) work with contracted partners. In the vast majority of cases, the procedure is done by external evaluators, but there are also cases when an internal professional makes the report. |
II.4 Professional Indemnity Insurance
| a) Does the legal or professional framework in your Member State specific to the valuation of property for lending purposes require: • Valuers to have professional indemnity insurance cover? • Lenders to use only valuers covered by professional indemnity insurance? |
Yes. Yes. |
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| b) If there are no such requirements, how are lenders/valuers covered for the risk? • Is/are there legislation/rules in your Member State determining the responsibility of the valuer vis-à-vis his client? If yes, please describe the legislation/rules and the responsibility of the valuer. |
We are not aware of such a rule. Generally, the provisions of the Civil Code and the Criminal Code apply. |
III. VALUATION & CAPITAL REQUIREMENT
| a) Property Value How are the Property Value requirements of Article 229(1) CRR transposed in your Member State: • by calculating the Mortgage Lending Value • by Market Value adjustments ◦ adjustments determined by the valuer on a single property by property basis ◦ adjustments determined by the credit institution on a portfolio level based on internal historic market data series ◦ adjustments determined by the credit institution on a portfolio level based on data provided by external research institutes or data providers |
Hungary does not issue separate legislation; Article 229(1) CRR applies directly. From January 2025, Hungarian banks must use the Basel III-aligned “Property Value” concept for immovable property collateral, ensuring independent, conservative valuations, historical averaging, and sustainability adjustments. MNB supervises compliance, and banks are updating internal policies accordingly. Hungary has its own legislation for calculation the mortgage lending value. This is written in the 25/1997 Ministry of Finance decree. This is not considered to be equal with the property value. The Market Value adjustment is not reqired according to the referring guidance of the Hungarian National Bank (MNB). No. Yes. No |
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| b) Monitoring of property values Has the regulator in your Member State laid down criteria regarding "more frequent monitoring where the market is subject to significant changes in conditions"? |
Hungary applies the CRR directly. Institutions must set internal criteria for “significant changes,” typically linked to MNB housing market indicators and macroeconomic factors. There is no fixed percentage in law, but thresholds like 10%+ price movement or major economic shocks are commonly used in practice. |
| b) Monitoring of property values Has the regulator in your Member State laid down criteria regarding “advanced statistical or other mathematical methods” complying with the technical requirements of Article 208(3a) CRR? |
Hungary applies CRR Article 208(3a) directly and supplements it with ministerial decree and MNB supervisory expectations. There is no separate Hungarian legal definition, but institutions must comply with EU-level technical criteria and MNB guidance, which require robust model governance, validation, and transparency. |
| b) Monitoring of property values Please provide an overview of the different statistical methods/tools complying with Article 208(3a) CRR applied by lenders in practice. |
The most typical statistical method used in Hungary for the revaluation of real estates is indexation. |
| c) Review of property values and revaluation • Has the regulator in your Member State laid down criteria which define “review” of the property valuation? If so, what are the minimum and maximum periods within which a review must be conducted? Based on which criteria? |
Hungary applies CRR directly: residential property valuations must be reviewed at least every 3 years, commercial annually, and more frequently if market conditions change significantly. The Hungarian regulator has not issued separate numeric thresholds but expects banks to define internal criteria based on market indicators and risk factors. |
| c) Review of property values and revaluation • Has the regulator in your Member State laid down criteria which define “material decline relative to general market prices”? How are ESG-related considerations assessed as an indicator for a material decline? |
Hungary has not set a statutory percentage for “material decline”. Relying on MNB supervisory expectations published in its recommendation banks defining internal threshold(often around 10%). ESG considerations are increasingly integrated through MNB’s 2024 ESG Recommendation, requiring data collection and risk assessment, but they serve as qualitative indicators rather than fixed triggers for valuation review. |
| c) Review of property values and revaluation • Please provide a description of how ‘reviews’ are carried out in your Member State, e.g. by a new full-size valuation report, a desk-top valuation, a valuation certificate, a plausibility assessment or alike. What criteria are used to determine how the reviews are to be carried out? |
In Hungary, reviews can be full on-site valuations, desktop valuations etc. MNB expects banks to define internal policies about what kind of valuations they accept in different cases. |
| c) Review of property values and revaluation • For the calculation of average values in accordance with Article 229 (1)(e) CRR in the context of upward revisions of values, are there any guidelines from regulators or lenders addressing the data points to be used and the comparability of properties? Please indicate whether there are requirements from regulators or lenders for ‘sufficient data’ and ‘unequivocal increases of value’. |
The Hungarian practice follows CRR Article 229(1)(e) strictly: upward revaluation requires averaging at least three comparable data points over 6–8 years and is only allowed if there is unequivocal value increase (e.g., energy efficiency improvements). If sufficient data is missing, upward revision is prohibited except for documented improvements. MNB has not issued separate numeric thresholds but expects banks to define internal comparability criteria and evidence requirements. |
IV. VALUATION OF THE COVER POOL
| a) Are valuation rules for cover assets provided at national level in accordance with Article 6(5a) CBD? Are they provided by national covered bond legislation or by professional guidance/standards? | Hungary transposed the EU Covered Bond Directive (Directive (EU) 2019/2162) through amendments to the Act XXX of 1997 on Mortgage Loan Companies and Mortgage Bonds (Mortgage Bank Act). |
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| b) What valuation bases apply for the valuation of cover assets (Market Value, Mortgage Lending Value)? | Hungarian legislation applies the Market Value principle for the valuation of cover assets in covered bond programs. Valuation must be based on prudent market value, excluding speculative elements or forced-sale assumptions. |
| c) In the case of Market Value valuations, are there any prudential or longer term/sustainable features of the property to be considered? If yes, to what extend? | The Hungarian practice uses Market Value with prudential conservatism. Sustainability features (energy efficiency, ESG) are relevant only for green covered bonds and eligibility criteria, not for the general valuation basis.Long-term aspects are considered indirectly through conservative valuation practices, not as a statutory requirement. |
| d) How is the requirement that the valuation shall be carried out by a valuer who possesses the necessary qualifications, ability and experience transposed in your Member State (Article 6(5b) CBD)? Are there specific qualification requirements for valuers? |
The Mortgage Bank Act (Act XXX of 1997) and supervisory rules require independent valuers for covered bond-related valuations, compliance with recognized professional standards (e.g., International Valuation Standards (IVS), RICS Red Book) and specific qualifications such as - relevant university degree (real estate, economics, engineering). - professional certification or membership in a recognized body, - demonstrated practical experience in property valuation for financial institutions. There is no separate statutory license for covered bond valuations, but competence is enforced through internal bank policies and Hungarian National Bank supervision |
| e) How is the requirement that the valuer shall be independent from the credit decision process transposed in your Member State (Article 6(5c) CBD)? |
Hungary has transposed the EU requirement that the valuer must be independent from the credit decision process into its national framework. The Mortgage Bank Act (Act XXX of 1997) and supervisory rules require: - valuations for cover assets to be performed by an independent valuer, not involved in loan origination or credit approval. - mortgage banks to implement internal governance procedures ensuring organizational separation between valuation and credit decision-making. Independence is typically achieved by outsourcing valuations to external appraisers or assigning them to internal units that are structurally separate from lending departments. Banks must have documented conflict-of-interest policies and procedures to prevent valuers from participating in credit decisions. |
| f) Are there differences in valuation rules and/or qualification requirements with regard to the property type (residential vs. commercial properties) or to the loan amount? | Hungarian law does not differentiate qualifications by property type or loan amount. |
| g) Are there specific monitoring, review and revaluation requirements for cover pool assets at national level (see Article 129(3) CRR referring to Article 208 CRR)? | Hungarian law requires regular revaluation of cover assets. Valuations must reflect prudent market value, independent valuers must perform valuations and updates etc. |
| h) Do regulators of your Member State provide a waiver from the limitation of calculating average values for cover assets in case of upward revision of values (Article 129(3) second subpar. CRR)? | The Hungarian regulator has not introduced a waiver related to Article 129(3) second subparagraph of the CRR concerning the calculation of average property values for cover assets. |
V. OTHER
REGULATORY HARMONISATION AND NATIONAL DIVERGENCES
| 1. What challenges does your Member State face in harmonising with EU regulations (e.g. legal, technical, market-related)? | Hungary has successfully implemented the EU framework, but faces legal interpretation issues, technical compliance costs, and market structure limitations. |
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DATA QUALITY, TRANSPARENCY AND COMPARABILITY
| a) What data sources are typically used by valuers in your Member State, and to what extent do they comply with Article 208(3a) of the CRR? |
We consider it extremely important to use accurate and well-documented data when preparing property valuations. A real, official database of comparable sales transactions is available for valuations. In addition, data from major real estate listing portals is also commonly used. Furthermore, official construction costs are calculated based on an engineering publication issued annually. Statistical data is sourced from the Central Statistical Office and from publicly accessible or subscription-based or paid databases. |
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| b) What measures have been taken to improve transparency and comparability of valuation data within your Member State? | Hungary has improved transparency and comparability through national bank's regular housing market reports and mandatory data reporting, adoption of international valuation standards and ESG data integration. |
| c) Is there a central database or platform for sharing valuation data in your Member State? | No, there isn't. |
EDUCATION, TALENT PIPELINE AND PROFESSIONAL DEVELOPMENT
| a) What training programs or continuing education opportunities are available for property valuers in your Member State? | In Hungary, real estate valuation can be studied through the following programs: state-accredited real estate brokerage and valuation training; state-accredited advanced real estate asset valuation training; and, within university adult education, the real estate manager program is available. In addition to these, the Hungarian Real Estate Association accredits Advanced Real Estate Valuation qualifications (EUFIM). RICS accreditation (MRICS/FRICS/AssocRICS) is also available. |
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| b) Is there collaboration between universities, professional bodies, and regulators to ensure a sustainable pipeline of qualified valuers? | We maintain collaborations with professional associations and governmental institutions; however, there is considerable potential for further development in this area. |
| c) How does the EU regulatory environment influence the development and attractiveness of the valuation profession? | On one hand, we believe that processes are becoming more efficient and standardized, which is highly positive; however, in many cases, they tend to become overly bureaucratic and more complex. In Hungary, at banking property valuations, the recommendations of EVS, IVS, and the Red Book also can be followed. Additionally, the Hungarian National Bank periodically updates its detailed guidelines on real estate valuation, which also take EU requirements into account. |
FUTURE TECHNOLOGICAL AND REGULATORY DIRECTIONS
| 1. What technological developments are expected to impact valuation processes in your Member State over the next five years? | The future of the real estate valuation profession will be shaped by the rapid advancement of data science and geospatial technologies, the integration of AI-driven solutions into our processes, the evolution of drone and laser technologies, and increasingly efficient communication. |
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