In 2024, consumer protection authority placed a strong focus on examining online stores. According to a recent announcement by the Minister of National Economy, such inspections are expected to increase further in the coming year. Additionally, 2025 will see the establishment of a consumer protection super authority, with the primary goal of safeguarding consumers in the digital space. For online store operators, it is crucial to prepare for the key practices and shortcomings that attract regulatory scrutiny.
Throughout 2024, both the consumer protection authority and the Hungarian Competition Authority (GVH) actively monitored online stores and marketplaces. In the first half of the year alone, consumer protection authorities conducted nearly 300 inspections, primarily through test purchases.
While consumer protection fines have so far been moderate, GVH-imposed penalties have been significantly higher. For instance, booking.com received a fine of HUF 382.5 million for unfair communication practices and psychological manipulation of consumers. Previously, fines exceeding HUF 100 million were imposed on Elittárs, a dating platform, and two online stores selling Elf Bar products. Elittárs was penalized for misleading consumers into believing its services could be used for dating without purchasing a subscription. The two online stores were fined for creating the false impression that Elf Bar products could be legally ordered in Hungary.
Based on past cases, regulatory findings typically fall into a few well-defined categories:
Consumer Reviews and Ratings
Consumer reviews play a significant role in influencing product and service choices in online marketplaces. Authorities pay close attention to ensure these reviews are genuine and not misleading. Businesses are expected to display both positive and negative reviews and to clearly outline their evaluation criteria and methodology for consumers.
Hidden Consumer Manipulation
An increasing trend among digital service providers is the use of subtle, so-called "dark pattern" techniques to manipulate consumers online. These include practices like urging purchases with countdown timers or scarcity messages such as "only two tickets left at this price." Similar manipulative tactics involve emphasizing specific information or offers with visually striking designs while concealing cheaper options. Another deceptive method is overwhelming consumers with excessive information, leading to confusion and distraction.
Proper Disclosure
Regulatory practices emphasize that, beyond general disclosure obligations, digital goods and service providers must inform consumers about specific conditions of use. For example, they should highlight how the digital product or service functions, any applicable technical safeguards, compatibility and interoperability of the products and services. Online marketplaces must also disclose the main parameters determining the ranking of offers in search results and clarify whether the seller is a business or an individual. This distinction is critical, as additional consumer rights apply only when purchasing from a business.
Price Display Practices
Authorities closely monitor practices where businesses create the impression of a discount that does not exist. Examples include displaying a manufacturer’s higher suggested retail price or showing a fictitious "original" price that was never applied. Similarly, listing multiple prices (e.g., original price, discounted price, promotional price, coupon price) can confuse consumers and disrupt their decision-making process. According to regulations, merchants must clearly indicate the lowest price applied during the 30 days preceding a promotion and show the discounted price relative to this baseline.
The Super Authority Is Coming
From January 1, 2025, a newly established body, the National Trade and Consumer Protection Authority (NKFH), will oversee whether online store operators comply with these rules. One of the NKFH’s goals is to focus increasingly on consumer protection in the digital space. E-commerce will be a priority area for inspections in 2025. Drawing on experiences from foreign counterparts, new types of inspections are also expected, including verification of customer reviews displayed on online stores.