Hungary Golden Visa Approved Funds: The MNB Register and How to Choose (2026)
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Hungary Golden Visa Approved Funds: The MNB Register and How to Choose (2026)
Only real estate funds registered with the Hungarian National Bank (MNB) qualify for the EUR 250,000 Hungary Golden Visa route, and the MNB register is the definitive list of them. There is no second list, no unofficial list, and no shortcut around checking the register yourself. This guide explains how the register works, what Act XC of 2023 requires of a qualifying fund, and how to evaluate one before you subscribe.
This guide is general information about the Hungarian Guest Investor Programme and is not legal, tax, financial or investment advice. Fund performance is not guaranteed and capital is at risk. Programme rules and fund registrations can change. Obtain independent professional advice and verify any fund against the official MNB register before making any application or investment decision.
What makes a fund “approved” for the Hungary Golden Visa?
A fund is not approved because a website says so, because an agent recommends it, or because it markets itself to golden visa applicants. It is approved because it is registered with the Hungarian National Bank and meets the conditions the programme sets for qualifying investment vehicles. Everything else is marketing.
The MNB register: the official list and where to find it
Act XC of 2023 defines the qualifying investment as units issued by a real estate fund registered by the Hungarian National Bank, so the MNB’s register of these funds is where eligibility is verified. The register is published by the MNB itself at mnb.hu, and a fund’s registration there, together with the statutory conditions described below, is what determines whether it currently qualifies. It is a live record. Funds can be added, and a fund’s status is a matter of its current entry rather than of what was true when an article was written.
We take a deliberate position on this, and it is worth stating plainly. This guide names no funds. Not one. Any list of “approved Hungary Golden Visa funds” published by an advisory firm, ours included, is a snapshot filtered through commercial interest, and it ages the moment it is published. The MNB register is the list. Our job is to teach you to read it, and to give you a framework for choosing between the entries on it.
The statutory requirements
The qualifying conditions sit in Act XC of 2023, the law that governs the programme, and its implementing Government Decree 35/2024 (II. 29.). The requirement investors most need to understand is the portfolio composition rule: a qualifying fund must hold at least 40% of its net asset value in investments in residential-function property located in Hungary. The law also requires the investor to subscribe the units directly and to hold them continuously for at least five years, on a blocked securities sub-account, and it requires the fund’s manager to appear on the qualified market operators list kept under Hungary’s defence and security procurement law.
That threshold is not incidental. It is the policy logic of the entire route. Hungary redirected the programme away from individual property purchases and toward pooled capital deployed into domestic residential stock, which is why the direct property-purchase route was removed with effect from 1 January 2025 while the fund route was retained. When you subscribe to an approved fund, the 40% floor is what makes your capital count for immigration purposes. Verify the current text of the requirement against Act XC of 2023 as published on njt.hu rather than relying on any secondary summary.
How the EUR 250,000 fund route works
Subscription, holding period and what you actually own
The mechanics are straightforward in outline. You subscribe at least EUR 250,000 into a registered fund and receive fund units. You do not own a specific apartment, you own a proportional interest in the fund’s portfolio, and the manager makes the underlying property decisions. Under Act XC of 2023 the units must be held continuously for at least five years, and the implementing decree requires them to sit on a blocked securities sub-account for that period. The holding requirement is a condition of the permit rather than a feature of the fund.
That is genuinely different from owning real estate, and it cuts both ways. You have no maintenance obligations, no tenants and no local management burden. You also have no control over which assets are held, when they are sold, or at what price. For a deeper treatment, see our guide to the Hungary Golden Visa real estate fund.
Fund route vs the EUR 1,000,000 donation route
The alternative qualifying route is a non-refundable donation of EUR 1,000,000 to a public-interest trust. The arithmetic explains why almost nobody uses it: the donation is four times the size and is spent for good, while the fund subscription is an invested position, recoverable in principle at the end of the term subject to fund performance and liquidity. The donation route’s only real advantage is simplicity, since there is no fund to assess and no market risk to carry. For a candid comparison of the two, see our guide to the best investment options for the Hungary Golden Visa.
How to evaluate an approved fund: a framework, not a tip sheet
Registration on the MNB register tells you a fund qualifies for immigration purposes. It tells you nothing about whether it is a good place for a quarter of a million euros. Those are two separate questions, and conflating them is the single most expensive error in this market.
| Dimension | What to establish | Why it matters |
|---|---|---|
| Manager and governance | Track record, assets under management, ownership, depositary, audit arrangements, regulatory history | You are buying the manager’s judgement more than any specific building |
| Portfolio strategy | Actual holdings, how the 40% residential floor is met, development risk versus income-producing assets, geographic concentration | Determines the real risk profile behind an identical headline threshold |
| Fees | Subscription fee, annual management fee, performance fee, exit or redemption charges | Fees compound against you over a multi-year holding period |
| Liquidity and exit | Redemption terms, notice periods, gating provisions, expected fund term | Determines whether “recoverable in principle” is meaningful in practice |
| Registration status | Current entry on the MNB register, verified directly | Immigration eligibility depends on it and it can change |
Manager track record and fund governance
Ask how long the manager has operated in Hungarian real estate, what they managed before the Guest Investor Programme existed, and what their assets under management look like excluding golden visa subscriptions. A manager whose entire business is immigration-driven capital is running a different business from one for whom this is an additional distribution channel. Neither is disqualifying. They are simply not the same risk. Governance detail is not paperwork either: who the depositary is, who audits the fund, how valuations are performed, and what the governing documents permit the manager to do without investor consent are the questions that decide what happens when conditions are difficult rather than easy.
Portfolio strategy and the residential allocation
Two funds can both satisfy the 40% residential requirement and carry completely different risk. One might hold completed, tenanted Budapest apartment blocks generating rent. Another might hold development land and construction projects that will become residential property. The immigration outcome is identical. The investment outcome is not remotely comparable. Establish what is actually in the portfolio today, how the residential floor is currently satisfied, and what proportion of the remaining assets sits in commercial, development or cash positions.
Fees, liquidity terms and exit mechanics
Fee structures in this segment vary widely, and headline management fees are rarely the whole picture. Establish the full stack: what you pay to enter, what you pay annually, what the manager earns on performance, and what it costs to exit. Then read the liquidity terms with equal attention, including what notice redemption requires and whether the manager can suspend it. The critical alignment question is whether the fund’s term and redemption terms match the holding period your permit requires. A mismatch in either direction is invisible at subscription and expensive to discover later.
Questions to ask before you subscribe
Put these in writing and keep the answers. What is your current entry on the MNB register, and can you point me to it directly? How is the 40% Hungarian residential requirement satisfied in the current portfolio? Who is the depositary and who audits the fund? What is the total fee load, including exit? What are the redemption terms and can they be suspended? How does the fund’s term align with the holding period the permit requires? What happens to my units if the fund’s registration status changes?
A manager who answers these clearly and in writing is telling you something. So is a manager who does not.
Risks to understand before investing
Capital is not guaranteed
This needs saying without hedging, because the market around this programme is not always candid about it. Fund performance determines your returns and your liquidity. Capital is at risk. The EUR 250,000 is recoverable in principle at the end of the term, subject to the fund’s performance and its ability to meet redemptions, which is a materially weaker proposition than “you get your money back”. Real estate values move, funds can gate redemptions, and a subscription made to solve an immigration problem is still an investment decision with investment consequences.
Regulatory and programme-level risk
A fund’s registration status is not permanent, and the immigration consequences of a change in status are a matter for the authorities rather than the fund manager. Separately, the programme operates in a European policy environment where residence-by-investment schemes face sustained scrutiny. The observable direction of travel across the EU has been restructuring and threshold change rather than abrupt closure, and Hungary shows no current closure indicators, but a plan that only works if nothing ever changes is not a plan.
Verifying a fund before you commit
Do this yourself, and do it late rather than early. Go to the MNB register directly, confirm the fund’s exact legal name rather than its marketing name, and confirm its current entry. Then confirm it again shortly before you subscribe, because what matters is status at the moment of investment, not status at the moment of research. Treat any “approved fund list” published on a commercial site, including any list an adviser hands you, as a starting point for verification rather than as evidence. If a promoter’s confidence in a fund’s status does not survive a direct check against the register, that is your answer.
Costs beyond the fund subscription
The EUR 250,000 is not the whole budget. Above it sit government fees for the Guest Investor Visa and the residence permit application, the fund’s own subscription and annual management costs over the holding period, and the professional, translation, legalisation and due-diligence costs of preparing a compliant file. Advisory fees are quoted per engagement rather than as a published price. For the full stack, see our guide to Hungary Golden Visa cost and requirements.
Frequently asked questions
Which funds are approved for the Hungary Golden Visa?
Only real estate funds registered with the Hungarian National Bank (MNB) qualify. The MNB register is the official, current list. Verify any fund against it directly rather than relying on a list published elsewhere.
Where do I find the official list of approved funds?
On the MNB website at mnb.hu. Treat any list published on a commercial or advisory site as unofficial, and check the register itself before committing.
What must an approved fund invest in?
Under Act XC of 2023, a qualifying fund must hold at least 40% of its net asset value in residential-function property in Hungary. Verify the current requirement against the law as published on njt.hu.
How much do I need to invest in an approved fund?
EUR 250,000 is the minimum qualifying subscription on the fund route.
Is my capital guaranteed?
No. Fund performance determines returns and liquidity, and capital is at risk. Assess the fund’s strategy, fee load, redemption terms and exit mechanics before subscribing, and take independent investment advice.
Can I buy property directly instead of using a fund?
No. The direct property-purchase route was abolished on 1 January 2025. An MNB-registered fund subscription is now the property-linked path into the programme.
The bottom line
The Hungary Golden Visa fund route is well designed and, at EUR 250,000, among the lowest entry points in the active EU set. The risk in it is not the threshold. It is the gap between a fund qualifying for immigration purposes and a fund being a sound place for the money, and that gap is where an entire promotional industry operates.
The defence is simple and it is entirely in your hands. Verify registration against the MNB register yourself, evaluate the fund as an investment on governance, strategy, fees and liquidity, and get the answers in writing. Then move to the paperwork, which we cover step by step in our guide to the Hungary Golden Visa application process. For the full programme picture, start with our guide to the Hungarian Guest Investor Programme, and if you are still weighing the decision, read our honest assessment of whether the Hungary Golden Visa is worth it. As a Budapest-based team, we help families run that verification and evaluation before anything is committed, and advisory fees are quoted per engagement.
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