Data reconciliation for pre-paid, SIM-card based subscription contracts

Last updated: 9 April 2018

The NMHH Decree laying down detailed rules, which entered into force on 12 January, related to the provisions for mobile telephone agreements for prepaid SIM cards included in the Act on Electronic Communications. The published Decree contains no material changes compared with the draft Decree issued for public consultation. Provisions limiting the number of agreements per subscriber and requiring data reconciliation also take effect.

Pursuant to the Act, only a limited number of prepaid SIM cards can be registered under the name of a subscriber. The Act also requires data reconciliation upon the conclusion of a new subscriber agreement, which must be annually repeated for existing agreements. Furthermore, service providers must review existing agreements and identify their existing subscribers by 30 June 2017 or their agreements will be terminated.

New information on data reconciliation! How does the reconciliation take place?

Via Telekom

Magyar Telekom dispatches text messages to all concerned Domino clients to draw attention to the reconciliation. In the case of the blue mobile and MOL mobile services, Magyar Telekom is the service provider, therefore the Telekom Domino, blue mobile and MOL mobile subscriptions are jointly considered in relation to the limitations set by law. Personal data may be quickly and comfortable reconciled through theés website. Additionally, clients can personally reconcile data during opening hours at Telekom retail outlets as well as from 7 am to 10 pm every day via the +36-80-630-045 telephone number.

Via Telenor

Telenor notifies all concerned clients of the tasks at hand via text message and provides detailed information through its website on the documents required for the reconciliation and the contact information of its customer service outlets. There is still some time left until the deadline of 30 June, however, these tasks shouldn’t be put off until the very last moment. The online interface ( is already available, which allows for data reconciliation 0-24 hrs, even from the comfort of homes. Furthermore, clients may also arrange such matters during opening hours at Telenor retail outlets. Telenor recommends visiting their outlets during less frequented periods between 11 am and 3 pm in order to avoid any cues.

Via Vodafone

In the case of Vodafone, data reconciliation is required for all prepaid subscriptions, even for Tuti cards purchased prior to 1 January 2017. This may be arranged with personal identification documents through the telephone customer service, by dialling 1270 through the Vodafone network, in person at Vodafone outlets or through the soon-to-be released online interface. All information on the data reconciliation process is listed at the website. Vodafone keeps its subscribers’ convenience in mind by doing everything it can to ensure that none of its clients’ contract would be terminated by failing to reconcile their data due to circumstances beyond their control.

1. How many prepaid subscriptions are allowed per subscriber?

The NMHH Decree stipulates that the maximum number of prepaid mobile SIM cards (prepaid subscriber agreements) allowed per mobile service provider is 10 for individual subscribers and 50 for business subscribers. Subscribers who currently have prepaid subscriptions in excess of this limit must declare which ones they intend to keep. Prepaid subscriptions in excess of this limit shall be terminated as of 1 July 2017, with the option to purchase other, e.g. postpaid subscriptions instead.

2. Will there be any changes to the locations to purchase SIM cards or top up balances?

No. The applicable legislation remains unchanged: the same points of sale are available to purchase subscriptions (e.g. stores of service providers, retailers, filling stations) and top up balances.

3. Should subscribers keep in mind that data reconciliation is needed or will they be notified by service providers?

For existing prepaid subscriptions, service providers must notify subscribers at least twice that subscriber agreements for prepaid SIM cards will be terminated as of 1 July 2017 in the absence of a declaration. When concluding new agreements, service providers automatically reconcile data with subscribers before starting to provide services, as they have done previously. However, subscribers will be responsible for remembering to provide data for the purpose of the reconciliation after being notified by their service provider. All the latest information on data reconciliation, refreshed on a daily basis, is listed at the website.

4. What is the deadline for service providers to reconcile data with their concerned subscribers?

If a subscriber already has an existing prepaid agreement as of 1 January 2017, the service provider must reconcile such subscriber’s data by 30 June 2017. Should a subscriber conclude a new agreement (purchasing a prepaid mobile subscription) subsequent to 1 January 2017, the service provider is required to reconcile data with the subscriber prior to contracting and providing services to said subscriber.

5. Do I have to be present in person for data reconciliation?

As a prepaid subscriber, you do not have to be present in person for data reconciliation at the service provider if you are a Hungarian citizen and have an official Hungarian form of identification (identity card, driving licence, passport, etc.) It is sufficient for the service provider to request the provision of data on the official form of identification of the person signing the prepaid subscriber agreement by phone, via email or any other manner specified by the service provider and check its validity in the public registry. Anyone can test the verification process themselves at

Foreign nationals who do not have an official Hungarian form of identification must be present in person for data reconciliation as official forms of identification issued by other countries cannot be verified through the Hungarian registry. They are required to present their entry or residence documents in person at the service provider.

6. Do existing subscribers need to reconcile their data?

Yes. Data reconciliation is also required retrospectively for existing subscribers and must be performed by service providers by 30 June 2017. For new agreements, service providers reconcile data with subscribers before concluding an agreement.

7. What will happen after 30 June 2017?

If a subscriber’s identity is not verified by then, all of subscriber’s prepaid agreements will be terminated at that deadline and the subscriber will not be able to use any prepaid SIM cards.

Likewise, all prepaid subscriber agreements will be terminated, thereby prohibiting subscribers from using prepaid SIM cards, if subscribers who have more prepaid mobile SIM cards than allowed, although having successfully reconciled their data, fail to declare by 30 June 2017 which ones they intend to keep up to the maximum permitted number.
If data reconciliation is successful, subscribers will next be required to reconcile their data again one year after making a declaration. Service providers will send separate notifications to that effect.

8. Is data reconciliation required only once or does it have to be repeated?

Data reconciliation must be performed once a year. For new subscriptions, data reconciliation must take place before concluding the agreement, followed by repeating the process once a year. For prepaid agreements existing as of 1 January 2017, it must be carried out by 30 June 2017, then similarly once a year.

9. Why is the new legislation necessary?

Thanks to the legislative amendment, it is now possible to prohibit individuals and companies from purchasing a number of prepaid SIM-card subscriptions that is more than realistic and resell them, and a smoother administration also requires subscribers being identified as accurately as possible, a standard practice for utility providers, e.g. gas or electricity suppliers.

10. Can I be contacted in person by my service provider?

It is important to note that service providers do not contact subscribers in person at their homes or workplaces for the purpose of data reconciliation. Such calls are most probably made with malicious intent. If you are unsure as to the true nature of such calls, please contact your service provider.

+1 Where is the original text of the Decree available?

The text of the decree is listed on the website of the NMHH (see under the title of Related legislation on the right).

Additional information is available through the website of the service providers.