Courier fleets have changed within a few years: alongside small cars and mopeds, e-scooters, electric bicycles and cargo bikes have arrived, some owned by the company and some as the couriers' own equipment. As a broker, I see that these devices are simply missing from most companies' vehicle lists – they have no number plates and do not have to be registered for road use, so they do not come up as an insurance question either. Yet the motor vehicle definition of the Act on compulsory motor third-party liability insurance (kgfb / MTPL) now also extends to the more powerful micromobility devices, and after a pedestrian has been hit, the question will not be whether the scooter was “just a scooter”, but who its keeper is and whether it had cover.
- Under the motor vehicle definition of the Gfbt. (Act LXII of 2009), a device driven solely by a motor requires compulsory motor third-party liability insurance (kgfb / MTPL) if its design speed exceeds 25 km/h, or if it weighs more than 25 kg and is faster than 14 km/h – pedal-assisted bicycles (pedelecs) do not fall into this category.
- The policy is taken out by the keeper – for an unregistered device, under the Gfbt. this is the owner or the user: the company for its own devices, the courier for their own scooter; the commissioning company can require proof of cover in its contract.
- Without insurance, the injured party is paid by the Compensation Account, which can claim the amount back from the uninsured keeper; MTPL does not cover the courier's own injuries – that is what accident cover is for.
Which devices are subject to the MTPL obligation?
Under the current definition in Section 3 of Act LXII of 2009 on compulsory motor third-party liability insurance (Gfbt.), a motor vehicle is any vehicle propelled exclusively by mechanical power on land but not running on rails – regardless of whether it has been entered in an official register – with a maximum design speed exceeding 25 km/h, or with a maximum unladen weight exceeding 25 kg and a maximum design speed exceeding 14 km/h. The Act leaves out of the definition wheelchair vehicles intended exclusively for use by persons with reduced mobility, electrically assisted bicycles (pedelecs) and e-moped vehicles driven by a person with reduced mobility. According to statements by MABISZ (the Hungarian insurers' association) and the trade press, the obligation has applied since 16 July 2024; it is worth checking the current text in the National Legislation Database (Nemzeti Jogszabálytár), because the regulation of micromobility – on the traffic rules side as well – is still changing.
Applied to a courier fleet: an e-scooter designed for more than 25 km/h requires MTPL even if it is light; larger scooters and seated scooters weighing over 25 kg require it once their design speed exceeds 14 km/h. A classic pedelec – where the motor assists only while the rider is pedalling and cuts out at 25 km/h – is not a motor vehicle, so most courier e-bikes and pedal-assisted cargo bikes do not require MTPL. The situation is different if the device can also run on the motor alone, with a throttle and without pedalling: then the design speed and weight on the manufacturer's data sheet decide, and a heavy cargo bike with a throttle may fall within the definition. Electric mopeds (legally mopeds or light motorcycles) were motor vehicles even before. Where the data sheet leaves doubt, it is worth clarifying the classification with the insurer or with MABISZ before the device goes on the road – because the obligation depends not on the KRESZ (Hungarian Highway Code) category but on the Gfbt. definition.
Who is the keeper: the company or the courier?
Under Section 4 of the Gfbt., the keeper of every motor vehicle based in Hungary is obliged to take out the insurance contract and to keep it in force by paying the premium. Under the Act's definitions, the keeper is the person entered in the official vehicle document, failing that the owner, and for a motor vehicle not entered in an official register, the owner or the user of the vehicle – so for a scooter without a number plate, both the person who owns the device and the person who uses it. If the company bought the device and provides it to the courier, the company is the keeper as owner and in practice fulfils the obligation; since the Act also names the user, it is worth stating in the vehicle use policy and in the contract with the courier that the company takes out the MTPL policy and keeps it in force. If the courier works with their own scooter as a sole trader or subcontractor, the obligation lies with the courier, but the commissioning company is not unaffected either: if the courier causes damage without insurance, the injured party and the manager of the Compensation Account will look for those liable, and the company, at the end of the contractual chain, can easily end up in a dispute. For rented or shared devices, insurance is typically the responsibility of the lessor or operator, but this has to be checked in the rental terms. For clarifying the roles, the article on keeper, owner and leasing provides a framework.
What happens after an accident without insurance?
MTPL covers the damage the courier causes to others: a pedestrian's injury, a dent in a parked car, a shop window. If there is no insurance, the injured party does not go uncompensated: under Section 35 of the Gfbt., the manager of the Compensation Account steps in even if the device that caused the damage was never registered, but under the Act's recourse rules it can claim back the amount paid from the uninsured keeper – and, in the cases listed in Section 34, for example drunk driving, from the driver. In addition, the statutory fee for the uninsured period (fedezetlenségi díj) is payable for the time without cover. If the courier is an employee, under Section 6:540 of the Hungarian Civil Code (Ptk.) the employer is liable towards the injured party for damage caused by the employee in connection with their employment; with a subcontracted courier (engaged under a service agreement), under the Ptk. the principal may be liable towards the injured party together with the courier, and is released from liability only if it proves that it was not at fault in selecting, instructing and supervising the courier – this is already the territory of employer's liability. And what comes as a surprise to most companies: the MTPL policy on the courier's own scooter does not cover the courier's own injuries, because it applies to damage caused to others – that is what the group accident insurance described in the article on accident cover for drivers is for.
How does all this fit into the fleet?
Micromobility devices have no number plates, so insurers typically issue the policy on the basis of the manufacturer's serial or frame number, as a separate micromobility MTPL product; whether these can be brought within the framework of the fleet contract or exist as separate policies alongside the courier cars varies from insurer to insurer. The Hungarian market offers casco (comprehensive motor insurance) for these devices only to a limited extent, so theft and vandalism are typically the company's own risk or a matter for the property insurance of its premises. The practical key is the vehicle list: include every device with its type, the manufacturer's design speed and weight, the owner (company or courier), the policy number and the premium payment status. MTPL cover terminates for non-payment of the premium after the statutory grace period, and with a courier working with their own scooter, the company notices this only if it asks for proof of cover. The advice on driver rotation and staff turnover in the article on courier and delivery fleets applies here too: a high-turnover courier workforce means a high-turnover pool of devices.
What should you do in practice?
First, take an inventory of the devices: what belongs to the company, what belongs to the couriers, what is rented. Second, check the manufacturer's data sheet for each type – design speed, unladen weight, whether it can run on the motor alone – and use this to establish which devices fall under the Gfbt. definition. Third, take out MTPL for the company's devices and record the policies in the vehicle list. Fourth, include the courier's obligations in subcontracting and service agreements: valid MTPL for their own device, proof of the policy and of premium payment, notification when a device is replaced. Fifth, extend your internal claims procedure to scooter accidents: photos, witnesses, the injured party's details, reporting via the insurer's claims line. If you get stuck on the classification or on fitting the devices into the fleet framework, I help where I can – and the insurer pays only for what is an insured event under your contract, so an uninsured scooter is not a trivial risk but an item on the company's own balance sheet.
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Sources
- Gfbt. – Act LXII of 2009 (Hungarian MTPL Act), Section 3 (definitions of motor vehicle and keeper), Section 4 (insurance obligation), Section 34 (recourse), Section 35 (Compensation Account) (njt.hu)
- Hungarian Civil Code (Ptk.) – Act V of 2013, Section 6:540 (liability for damage caused by an employee) (njt.hu)
- bank360.hu – Compulsory insurance for e-scooters may get off to a bumpy start (start on 16 July 2024, thresholds)
- economx.hu – E-scooter riders: price rises and alarming accident data (July 2026; the effective date and scope of the obligation)
- MABISZ – Association of Hungarian Insurance Companies (information on micromobility MTPL)
