The EU AI Act introduces the first comprehensive and binding regulatory framework for artificial intelligence in the European Union. From 2026, Hungarian companies that develop, deploy or use AI systems will be subject to extensive legal, governance and documentation obligations, with enforcement risks comparable to those under GDPR.
For boards and senior management, AI compliance is no longer a future technology issue but a current regulatory, governance and liability risk. Early legal positioning will be critical in managing enforcement exposure and avoiding operational disruption.
Scope of application
The AI Act applies broadly across sectors, regardless of whether AI systems are developed in-house, sourced from third parties or embedded in standard software. Hungarian companies using AI in functions such as HR, financial assessments, fraud detection or customer profiling may fall within scope.
Importantly, the mere use of AI can trigger compliance obligations, even where the system is developed or provided outside Hungary or the European Union.
Provider and deployer roles: a decisive legal threshold
The AI Act distinguishes between AI providers and AI deployers, with significantly different obligations. In practice, contractual arrangements or system modifications may elevate deployers to provider or quasi-provider status.
Correct role qualification is therefore a threshold legal issue, as misclassification may result in regulatory sanctions and governance exposure.
Risk-based classification and high-risk AI
The AI Act adopts a risk-based framework, under which compliance obligations depend on the applicable risk category. High-risk AI systems are subject to the most extensive requirements. AI used in HR, financial decision-making, compliance monitoring or access-to-services contexts is particularly likely to qualify as high-risk.
High-risk AI: compliance implications
High-risk AI systems require documented risk management, appropriate data governance, detailed documentation and effective human oversight throughout the system lifecycle. Retrofitting compliance after deployment is typically costly and legally risky, underscoring the importance of early legal assessment.
Governance and board oversight
The AI Act places strong emphasis on internal governance and accountability. Existing GDPR frameworks are not sufficient on their own and must be supplemented with AI-specific controls. In high-risk use cases, AI oversight is increasingly viewed as a board-level responsibility.
Third-party AI and contractual exposure
Reliance on external AI vendors does not eliminate regulatory responsibility. Hungarian companies remain accountable where they deploy third-party AI systems in their operations. Supplier contracts and licensing arrangements should therefore be reviewed to ensure appropriate transparency, cooperation and allocation of compliance responsibilities. Vendor-related risk will remain a key focus area in regulatory enforcement and contractual disputes.
Enforcement risk and liability exposure
Non-compliance with the AI Act may result in administrative fines of up to EUR 35 million or 7% of global annual turnover, as well as reputational harm, suspension of AI systems and contractual liability.
For senior management, the regulation also raises broader issues of corporate governance, oversight duties and internal accountability, increasingly relevant in enforcement proceedings.
How we assist
We advise Hungarian and international clients on:
- AI Act interpretation and legal risk classification
- provider and deployer role analysis
- governance and compliance framework design
- AI-related contractual structures and vendor negotiations
- alignment between the AI Act, GDPR and sector-specific regulation
Our approach combines deep regulatory insight, practical implementation experience and board-level risk awareness, enabling clients to integrate AI compliance into sustainable business strategy.