Is it legal to record a meeting in Hungary?

Btk. § 422, Tiltott adatszerzés, prohibited acquisition of data. § 422(1) punishes whoever, "személyes adat, magántitok, gazdasági titok vagy üzleti titok jogosulatlan megismerése céljából", for the purpose of the unauthorised acquisition of knowledge of personal data or a private, economic or business secret, (b) titokban, secretly, observes or records by a technical device what happens in another's dwelling or an enclosed place belonging to it. § 422(1a)(b) extends the same to what happens, outside a public place, in another's room or area or in a vehicle. § 422(3) punishes forwarding or using data so acquired.

How it is framed. Around covertly obtaining knowledge you are not entitled to, not around recording another person's words. The chapter heading places it with Poland's Art. 267 and the Dutch Arts. 139a to 139c rather than with Germany's StGB § 201. Nothing in § 422 protects the spoken word as such.

The live criminal exposure in Hungary is elsewhere: § 223, disclosing a private secret learned through one's occupation.

Yes on the criminal layer, on two independent grounds, either of which is enough: § 422 requires a purpose of unauthorised acquisition of knowledge, which a participant entitled to hear what is said does not have; and it requires the observation or recording to be done titokban, secretly, which an announced recording is not.

But Ptk. § 2:48(1) is the constraint, and it is unqualified. It requires consent to make and to use a voice recording. Three things follow. There is no "unauthorised", no harm requirement and no reasonableness qualifier: making the recording without consent is already the interference. The exceptions do not help, because a meeting of colleagues or clients is neither a crowd recording nor a public appearance in public life. And it mirrors Slovakia's Občiansky zákonník § 12(1) almost exactly, for the same reason: both are personality-right provisions covering the making and the use in one breath.

§ 2:46 supplies the surrounding right to a private secret, and states that unauthorised acquisition and use, publication, or communication to an unauthorised person are in particular violations of it.

The defence is hozzájárulás, consent, under Ptk. § 2:48(1), and no form is prescribed. An announcement additionally defeats § 422's secrecy element, so it does two jobs at once.

Whether consent may be implied from continuing to speak after an announcement: no authority found. Hungarian practice on képmás recognises implied conduct in some settings, but we opened no Kúria decision and no regulator position on implied consent to a hangfelvétel. Whether a calendar-invite line is enough: also no authority, and note the interaction with the workplace rule below, where the notice must be in writing and in advance and the invite may well be the wrong writing.

Before we start: I record my meetings so I can write up notes afterwards. It runs on my laptop, the audio is transcribed on this machine and never uploaded, and the audio itself is not saved anywhere, only the text, in a file I keep. Is everyone alright with that? If anyone would rather I didn't, say so now and I'll turn it off.

GDPR applies as well, and the analysis is the ordinary European one: a meeting recording is personal data about every identifiable speaker, a transcript without speaker labels is still personal data, the household exemption is read narrowly and a work meeting has a direct connection to a professional activity, you need a lawful basis, and Art. 13 wants the information at the time the data are obtained, which for an always-on recorder means before the substance of the meeting. The European framework covers all of that once rather than on every country page.

Hungary has the most specific statutory notice rule in this region, and it is a written rule.

Mt. § 9(2): an employee's personality right may be restricted where the restriction is absolutely necessary for a reason directly connected with the purpose of the employment relationship and is proportionate to achieving the aim, and the employee must be informed in writing in advance (előzetesen írásban tájékoztatni kell) of the manner, conditions and expected duration of the restriction, and of the circumstances substantiating its necessity and proportionality. Mt. § 11/A(1) adds a second written-notice duty.

So in the workplace the consent gate is displaced by a necessity-and-proportionality test plus prior written information, which is a different and in some ways harder test to satisfy for a note-taking tool.

Employee representation is a works council opinion, requested at least fifteen days before the decision, on both the data protection policy and monitoring devices, under Mt. § 264. That is an opinion right rather than a consent right.

NAIH, the Hungarian data protection authority. Nothing specific on meeting recording or on implied consent to a voice recording was opened in our research, so we state nothing about its position. That is a gap.

Start with what does not help, because it is what our own positioning tempts us into claiming. Earkeep transcribes on your own device, never writes the audio to disk and sends nothing anywhere. On the criminal layer in Hungary that changes nothing at all. A recording made without the other speakers' consent is the same act whether it was processed on your laptop or uploaded to somebody's cloud, because the provision is about making the recording rather than about where it ends up.

Where the architecture genuinely helps is data protection: no transfer, no third party in the chain, no processor agreement to sign, and nothing to reconcile if someone asks you to delete what was said. And in the conversation itself, "it stays on my laptop and the audio is never saved" is a shorter thing to explain than what a cloud notetaker requires, which makes the agreement easier to actually obtain.

Earkeep announces itself to nobody. There is no bot in the participant list and no banner on anyone else's screen, so where the announcement is what makes the recording lawful, the whole of it depends on you saying something. What the app gives you is somewhere to go when the answer is no: a pause from the live edge that releases the microphone and the system audio stream, so the operating system's own recording indicator visibly goes dark; a never-record marking for a meeting on a connected calendar; and a purge that takes the lines out of the file on your own disk with no server copy anywhere. It does not make any recording lawful, and no tool can.

• Btk., Act C of 2012 (§ 422)
• Ptk., Act V of 2013 (§§ 2:46, 2:48)
• Btk. on njt.hu, the canonical database (not reachable in our research)
• GDPR, EUR-Lex

• European recording laws: the four layers, the controller question, and all 32 countries.
• Telling people you're recording: the scripts, and the three ways to stop.
• Private by design: why the audio never leaves your computer.

This page is legal information, not legal advice. It summarises provisions and guidance rather than replacing them, and we are not lawyers. If the answer matters, ask someone who can be held to their answer.