Opinion of the European Central Bank of 12 June 2023 on the minimum reserve requirements of the Magyar Nemzeti Bank (CON/2023/16)
Date: 2023-06-12
Institutions: European Central Bank
Subjects: legal basis

EN 

ECB-PUBLIC 

OPINION OF THE EUROPEAN CENTRAL BANK 

of 12 June 2023  

on the minimum reserve requirements of the Magyar Nemzeti Bank 

(CON/2023/16) 

Introduction and legal basis 

On 25 May 2023, the European Central Bank (ECB) received a request from the Magyar Nemzeti Bank 

(MNB) for an opinion on a draft MNB decree (hereinafter the ‘draft decree’) amending the MNB Decree on 

the calculation, method of allocation and placement of minimum reserves. 

The ECB’s competence to deliver an opinion is based on Articles 127(4) and 282(5) of the Treaty on the 

Functioning of the European Union and Article 2(2) of Council Decision 98/415/EC1, as the draft decree 

relates to instruments of monetary policy of a Member State that has not adopted the euro. In accordance 

with  the  first  sentence  of  Article 17.5  of  the  Rules  of  Procedure  of  the  European  Central  Bank,  the 

Governing Council has adopted this opinion. 

1. 

Background and purpose of the draft decree 

1.1 

In 2005 the Governor of the MNB adopted Decree 10/2005 on the calculation, method of allocation 

and placement of minimum reserves2, which was amended several times 3. The ECB adopted several 

opinions in relation to the proposed draft changes 4. 

1.2  As noted in the explanatory memorandum accompanying the draft decree, the purpose of the current 

amendment is to ‘ensure that the level of the reserve requirement for maintenance periods better 

reflects the development of the reserve base of credit institutions’ and to ‘reduce the likelihood and 

magnitude of ad hoc turbulence in financial markets impairing monetary policy’. Prior to the present 

proposed amendment, the reserve base of credit institutions subject to reserve requirements was 

determined based on the monthly outstanding data for the last calendar day of the reference period 

preceding the relevant calendar month. The draft decree is introduced in the light of recent regulatory 

changes in Hungary. First, the reserve ratio was increased5, in relation to which the ECB adopted 

Opinion CON/2023/6. Second, the negotiability of discount bills issued by the MNB was restricted 

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Council Decision 98/415/EC of 29 June 1998 on the consultation of the European Central Bank by national authorities 
regarding draft legislative provisions (OJ L 189, 3.7.1998, p. 42). 
10/2005. (VI.11.) MNB rendelet a kötelező jegybanki tartalék kiszámításáról, illetve képzésének és elhelyezésének 
módjáról, published in Magyar Közlöny 2005/78. 
The amendments on which the ECB adopted opinions were introduced by 43/2018. (XI.21.) MNB rendelet a kötelező 
jegybanki  tartalék  kiszámításáról,  illetve  képzésének  és  elhelyezésének  módjáról  szóló  10/2005.  (VI.  11.)  MNB 
rendelet  módosításáról,  published  in  Magyar  Közlöny  2018/182,  and  36/2022.  (IX.  15.)  MNB  rendelet  a  kötelező 
jegybanki  tartalék  kiszámításáról,  illetve  képzésének  és  elhelyezésének  módjáról  szóló  10/2005.  (VI.  11.)  MNB 
rendelet módosításáról, published in Magyar Közlöny 2022/150. 
Opinions CON/2005/14, CON/2018/48 and CON/2022/33. All ECB opinions are available on EUR-Lex. 
6/2023. (III. 8.) MNB rendelet a kötelező tartalékráta mértékéről, published in Magyar Közlöny 2023/34. 

 
 
 
 
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and an interest rate cap on certain demand deposits was extended 6, in relation to which the ECB 

adopted  Opinion  CON/2023/10.  To  react  to  these  regulatory  changes,  and  in  order  to  prevent 

excessive adjustments of credit institutions’ balance sheets (i.e. around the last calendar day of the 

reference period preceding the relevant calendar month), the MNB is planning to introduce a monthly 

averaging calculation method based on daily balance sheet items subject to reserve requirements 

that  will  be  applicable  to  every  subjected  credit  institution.  As  a  provisional  solution  until  the 

infrastructural developments are completed for the new calculation method, the draft decree provides 

that  the  credit  institution  balance  sheet  date  will  be  temporarily  fixed  as  a  calculation  basis  for 

required reserves as of 31 March 2023 on a spot basis and without recourse to averaging.  

1.3  The draft decree also proposes to introduce an additional way to comply with reserve requirements 

in the form  of term deposit instruments  with an original  maturity of at  least 14 days and  up  to  an 

amount equivalent to 15 % of the minimum reserve requirements. 

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Observations 

2.1  The ECB notes that the draft decree does not determine when the monthly averaging method would 

be introduced to calculate the basis of required reserves, thus ceasing the application of a fixed credit 

institution balance sheet as of 31 March 2023 as a calculation basis. The ECB understands that the 

latter is a provisional solution, that the MNB is consulting with credit institutions on an ongoing basis 

on when the monthly averaging calculation method can be introduced, and that the MNB is committed 

to keeping the transition period as short as possible. 

2.2  The ECB has noted in earlier opinions 7 that Member States whose currency is not the euro retain 

their powers in the field of monetary policy according to national law 8. Once the euro is introduced, 

Hungary’s monetary policy will be the single monetary policy and will need to be consistent with the 

Eurosystem’s  operational  framework.  Credit  institutions  should  therefore  be  familiar  with  the 

requirements that would apply to them once the single monetary policy is implemented in Hungary. 

This opinion will be published on EUR-Lex. 

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A Kormány 89/2023. (III. 22.) Korm. rendelete gazdasági, finanszírozási tárgyú intézkedésekről, published in Magyar 
Közlöny 2023/41. 

See, for example, paragraph 2 of CON/2023/6, paragraph 2.6 of Opinion CON/2022/38 and paragraph 2.1 of Opinion 
CON/2022/33. 
Article 282(4) of the Treaty on the Functioning of the European Union and Article 42.2 of the Statute of the European 
System of Central Banks and of the European Central Bank. 

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Done at Frankfurt am Main, 12 June 2023. 

[signed] 

The President of the ECB 

Christine LAGARDE 

ECB-PUBLIC 

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