The latest DLA Piper GDPR Fines and Data Breach Survey provides a comprehensive overview of data protection enforcement trends across Europe, including the Central and Eastern European (CEE) region. CEE countries are in the mid-range in terms of total GDPR fines imposed since the regulation became applicable in 2018 and for last year, but enforcement activity is steadily increasing. Here are the latest trends and legal developments in Austria, the Czech Republic, Hungary, Poland, Romania, and Slovakia.

Following the year-end legislative news, several changes affecting so-called "green taxes" came into force at the beginning of 2025. The most significant of these is the effective abolition of the dual obligations of the Extended Producer Responsibility (EPR) and the Environmental Product Charges (EPC), except for plastic carrier bags, and the introduction of the EPR penalty rates that have been expected since the introduction of the EPR. At the same time, there are also many changes to the EPR rules.

Decathlon Hungary Legal Counsel Timea Balazs has become the company’s new Head of Legal and Compliance.

From 1 January 2025, third-country nationals will no longer be entitled to claim certain personal income tax (PIT) benefits. Third countries are non-EEA countries and countries that have not concluded a bilateral social security agreement with Hungary.

A new amendment to the ESG Act has entered into force, which, in addition to changes to the personal and material scope of the Act, contains provisions primarily aimed at easing the burden on businesses and the application of the Act. According to the proposal of the Act, the amendments are necessary in light of the experience gained in the practical application of the ESG Act since its entry into force. The changes entered into force on 19 January, except for the amendment on fines. The main amendments are summarised below, without being exhaustive.

The global minimum tax initiative aims to ensure that large multinational corporations operating across multiple jurisdictions pay a corporate tax rate of at least 15%.

Digital transformation has become a priority for all major companies. This is being driven only further by the spread of artificial intelligence's commercial use cases and ever-tightening data protection and cybersecurity regulations. However, procuring enterprise software (concerning both the development of custom-made software and "off-the-shelf" software developed for mass use) may give rise to various legal issues. Promptly identifying and addressing these issues can help prevent considerable legal and operational expenses, as well as other inconveniences.

The world of data centres is evolving at an unprecedented pace, driven by the ever-increasing demand for AI solutions. At the same time, sustainability challenges, energy efficiency and security of supply are becoming increasingly in focus due to the significant energy demands of data centres. The growth potential of the sector remains attractive, with 70% of investors expecting further growth over the next two years, according to a recent international report* by DLA Piper.

Last summer, the deposit return system (DRS) was introduced, under which 0.1-3 litres of drink products with a mandatory redemption fee can be bought in shops at a price increased by the redemption fee.

In 2024, EU data protection authorities imposed a total of EUR 1.2 billion in fines. This brings the total value of fines to EUR 5.88 billion since the GDPR became applicable, DLA Piper's latest report reveals.* The technology sector has been hit the hardest, with data protection focusing on managerial responsibility and privacy issues in AI tools.

Schoenherr, working with Argo, has advised Group Vandamme on the sale of its Hungarian activities to ADM. Baker McKenzie advised the buyer.

The Hungarian Government has made a significant amendment just weeks into 2025 by increasing the VAT exemption threshold for small and medium-sized enterprises (SMEs). Despite the autumn tax package for 2025 remaining silent on this matter, the new limit has been set at HUF 18 million, up from the longstanding HUF 12 million. This increase applies retroactively from 1 January 2025. Taxpayers have until the end of February to opt in for the exemption.

Captive insurance has experienced significant growth globally in recent years, driven by hard market conditions, emerging risks and increased volatility. Statistics reveal a steady increase in the number of captives over the past four years, rising from 5,879 in 2020 to 6,181 by the end of 2023, according to the Captive Managers and Domiciles Rankings + Directory 2024 published by Business Insurance.[1] Captive insurance companies are also increasingly used by Forbes 1000 and Fortune 500 companies to manage complex and emerging risks.

Hungary introduced new regulations for employing guest workers from third countries. These updates specify eligible countries and permit requirements to align with Hungary’s labour market needs and compliance standards.

Eva Kovacs has joined Jalsovszky as a Managing Associate and the firm’s new Head of Real Estate Practice.

Jipyong Partner Ji Hye Lee has joined Oppenheim’s Korea desk in Budapest.

DLA Piper has advised the Government Debt Management Agency (AKK), acting on behalf of the Republic of Hungary, on an international syndicated revolving credit facility agreement for a total amount of EUR 1.5 billion with 13 undisclosed Hungarian and international banks. CMS advised the coordinating banks.

The Hungarian Act on Fees and Duties will be changed significantly as of 28 January 2025, which will also affect the fees for court proceedings.