What Does the New Fee Regulation Really Mean?
For a long time, the digitalisation of public services was primarily treated as a technological challenge. In recent years, the focus has largely been on how physical services can be made accessible through digital channels, simplifying and accelerating administrative processes.
The new fee regulation transforming the operation of the National Mobile Payment System, however, sends a clear message: digital operation today is no longer merely a technological issue, but a defining factor of competitiveness.
This regulation goes far beyond traditional price‑setting. It introduces a fundamentally new operational logic.
It does not only standardise pricing, eliminate convenience fees and increase transparency, but establishes a new operational model that fundamentally reshapes the market of digital public services—certainly in the case of services accessed via mobile payment.
From Regulation to Platform Logic
One of the most significant innovations of the fee regulation is that it implicitly reinterprets the functioning of the market through a platform-based logic. Digital access to public services no longer appears as a collection of isolated services but as a unified, regulated foundation layer upon which services are delivered.
This model is built on two clearly distinct layers:
This approach clearly follows the logic of the platform economy: a stable, regulated infrastructure supporting a competitive, innovation-driven ecosystem.
In this interpretation, the National Mobile Payment System is no longer simply a service—it is a digital platform upon which an entire service ecosystem is built.
Where Competition Now Takes Place
One of the most profound impacts of the fee regulation is the redefinition of competition.
Under the previous model, competition often did not materialise through service quality, but rather through various—often opaque—pricing elements. Convenience fees, exchange‑rate‑based markups and other distorting mechanisms not only undermined user experience, but also distorted market functioning.
The new model eliminates this logic. With the protection of regulated prices and full transparency, competition is redirected towards service quality, integration capabilities and customer experience.
This shift represents not only a major step forward from a consumer‑protection perspective, but also acts as a genuine innovation incentive. Competition moves away from pricing structures and towards the level of user value. For market participants, growth is no longer achieved through price mechanics, but through the value delivered to users.
The Emergence of a Platform‑Based Ecosystem
A key element of the new operating model is the strengthening of the partnership ecosystem. The platform’s shared revenue model and the involvement of resellers create a structure that is inherently scalable.
Market participants do not operate in isolation, but build services on a shared platform—competing and cooperating at the same time. This model simultaneously provides stability and openness: the regulated foundation guarantees uniform operation, while the innovation layer enables continuous development.
This duality is precisely what makes digital platforms one of the most important instruments of the modern economy.
The Competitiveness Dimension
The true significance of the fee regulation becomes evident in this context.
Market consolidation, the elimination of distortive mechanisms and transparent operations are important achievements in themselves. However, the real value lies in the emergence of a platform-based operational model capable of fostering long‑term innovation and strengthening the digital economy.
Digital access to public services thus becomes not only more efficient, but evolves into an infrastructure layer on which new services, business models and market participants can build.
In this sense, the regulation does not restrict the market—it elevates it to a higher level of functioning.
This is what makes platform‑based operation a genuine tool of competitiveness: it enables not only efficiency gains, but the creation of entirely new markets and services.
European Context and Exemplary Value
The emerging model aligns closely with the European Union’s digitalisation and competitiveness objectives. Transparent operations, stronger consumer protection and support for innovation are all priorities increasingly emphasised in EU regulation.
What makes the domestic approach distinctive, however, is that these principles are not merely reflected in regulation, but are embodied in a functioning, real‑world operational model.
In this sense, the Hungarian model does not only align with European directions—it offers a working example of their practical implementation.
Digital Sovereignty and Future Vision
Platform‑based operation also opens up an additional dimension of strategic importance: digital sovereignty.
Ensuring that digital access to public services is delivered through a domestic, regulated and controlled platform creates the opportunity for value creation, customer relationships and data assets to remain within the national ecosystem.
In the long term, this approach can not only improve service quality, but also contribute to strengthening the digital economy as a whole.
From this perspective, the new fee regulation is not the conclusion of a process, but the beginning of a new era—one in which the National Mobile Payment System is no longer merely a set of services, but a digital platform capable of connecting public services, market innovation and competitiveness objectives.
Digital platforms do not merely serve the economy—increasingly, they define its competitiveness and sovereignty.