The social security booklet (TB-kiskönyv), a document long established in the Hungarian legal system for recording social security entitlements, will soon become a thing of the past. In May 2025, the Hungarian Parliament adopted a legislative amendment that provides for the phasing out of the social security booklet. The aim is to reduce administrative burdens and prioritize digital data processing. According to the new law, the paper-based social security booklet will be discontinued and fully replaced by an electronic register, the so-called “e-social security booklet,” which will include an expanded data set compared to the traditional booklet. The relevant data (e.g., social security entitlements, sick pay, accident benefits, CSED, GYED, GYOD, etc.) are already accessible through government-managed digital databases. However, the current step will integrate these into a unified digital system, enabling employers and authorities to access them directly and electronically.
Currently, the data recorded in the social security booklet is accessible through two separate electronic registers. Data concerning insurance relationships are stored in a register maintained by the National Health Insurance Fund (NEAK), while data related to monetary health insurance benefits (sick pay, CSED, GYED, accident-related sick pay, etc.) are managed within the Health Insurance Monetary Benefits subsystem operated by the Hungarian State Treasury. Prior to the amendment, payers (entities authorized to disburse benefits) do not have electronic access to the historical data necessary for determining eligibility, and therefore had to request such information via supplementary procedures, placing additional administrative burden on both the payers and the government offices.
Under the amendment, NEAK will provide payers with access to both social security entitlement data and monetary benefit information via an electronic query interface. In addition, individuals will be able to view their own data through the “Patient Path” (Betegéletút) service. The purpose of the amendment is to regulate the use and authorization of the query interface, establish data protection provisions relating to the e-social security booklet, define the data contained within it, and regulate the process of data transmission from the mentioned databases, including the purpose and duration of data processing.
What does this mean for employers?
Administrative burdens on employers will indeed decrease, as they will no longer be required to issue, manage, maintain, or hand over a social security booklet when establishing an employment relationship. However, this does not mean that employers will have fewer obligations from a data protection perspective – in fact, new responsibilities may arise. Payers will be able to query e-social security booklet data via the electronic interface created and maintained by the health insurance authority, following electronic authentication, provided they are listed in the official register of the Treasury as authorized payers. Through the query interface, payers may only access the data of those insured individuals who, at the time of the query, are employed by the entity operating the payer and are entitled to social security benefits.
Based on the text and justification of the legislation, it appears that employers who are not authorized payers will no longer have any responsibilities related to the e-social security booklet.
Privacy notices must be updated
Employers will likely need to update the privacy notices they provide to employees, as the phasing out of the social security booklet and introduction of the e-social security booklet will change both the scope and source of the processed data. Instead of referring to the previous paper-based document, the data management notice must now refer to the electronic social security registry, as well as the digital data flow between the employer and government authorities.. It is also essential that employees are informed about how, through which system, and for what purposes the employer accesses their electronic social security data, and what safeguards are in place to ensure the security of their personal data.
According to the legislation, the e-social security booklet will contain, for each insured person with a social security (TAJ) number, the following data:
a) The insured person’s identification data and TAJ number,
b) Regarding the person’s insurance relationships:
ba) Name and tax number of the employer,
bb) Legal title code of the employment relationship.,
bc) Duration of the employment relationship,
bd) Duration of the suspension of the employment relationship,
be) Job position according to the employment relationship (FEOR = Hungarian Standard Classification of Occupations),
bf) Working hours extent according to the employment relationship,
c) Regarding the insured person’s monetary health insurance and accident-related sick pay:
ca) Legal basis of the benefit,
cb) Duration of benefit payment,
cc) Daily base amount of the benefit,
cd) Name of the determining authority,
ce) Name and tax number of the employer, if the benefit is determined by the health insurer,
cf) For child care-related benefits, child care sick pay, infant care benefit, child care benefit, adoption benefit, the child’s birth name, place and date of birth, and TAJ number, if available.
Main legal implications of the change
- The discontinuation of the social security booklet does not affect employers’ obligation to report to the National Tax and Customs Administration (NAV).
- Employee insurance status will now be verified digitally, eliminating the need for a physical document to track employment relationships.
- In the future, obligations are expected to apply only to employers operating as payers.
- Employee privacy notices must be revised accordingly.
- The fate of previously issued and employer-retained social- security booklets remains an open question.
Conclusion
The elimination of the social security booklet is a logical step in the digitalization process, but it does not imply reduced responsibility for employers. Ensuring data protection compliance remains critical, especially in handling employees’ personal data. It is advisable to review and, if necessary, update the current privacy notices to align with the requirements of the new digital social security system. If you require assistance in updating your data protection documentation or applying these changes in practice, please do not hesitate to contact us.