EN ECB-PUBLIC  
 
OPINION OF THE EUROPEAN CENTRAL BANK 
of 19 March 2021 
on the mandate and tasks of the M agyar Nemzeti Bank relating to  environmental sustainability 
(CON/2021/12) 
 
Introduction and legal basis 
On 18 December 2020, the European Central Bank (ECB) received a  request from the Hungarian 
Ministry of Finance for an opinion on a draft law amending the Law on the Magyar Nemzeti Bank1 
(hereinafter the ‘draft law’). 
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 (TFEU) and the third indent o f Article 2(1) of Council Decision 
98/415/EC2, as the draft law concerns the Magyar Nemzeti Bank (hereinafte r the ‘MNB’). In accordance 
with the first sentence of Article 17.5 of the Rules of Procedu re of the European Central Bank, the 
Governing Council has adopted this opinion. 
 1. Purpose of the draft law 
1.1 According to the explanatory memorandum accompanying the dr aft law, which has been prepared 
by the MNB for the Hungarian Ministry of Finance, the draft law  was conceived by the MNB in line 
with its vision of a green central bank.  
1.2 The draft law would amend the Law on the MNB in three respe cts. 
1.3 First, the draft law provides that, without prejudice to it s primary objective of achieving and 
maintaining price stability, as  a secondary objective, the MNB supports the government’s economic 
policy and its policy related to  environmental sustainability, using instruments at its disposal.  
1.4 The explanatory memorandum emphasises that environmental su stainability concerns are 
expected to have a fundamental impact on price and financial st ability, and, therefore, greater 
emphasis must be placed on these issues by central banks. The e xplanatory memorandum notes 
that integrating environmental sustainability considerations ha s been added to a growing range of 
central bank activities, including incorporating risks arising from climate change into the various 
aspects of financial stability, taking into account the risk ex posures of financial market participants 
identified in relation to climate change, and minimising the ec ological footprint of central bank 
operations. Environmental sustainability also has an effect on monetary policy: environmental and 
                                                 
1  A Magyar Nemzeti Bankról szóló 2013. évi CXXXIX. törvény . 
2  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). 
ECB-PUBLIC  
2 weather processes can lead to an increase in the volatility of food prices, and the structural 
transformation of the economy can have an influence on inflatio n over the longer term. Reference 
is made in this context to the assessment of inter-relationship s between climate change and 
monetary policy as part of the ECB’s strategy review. According  to the explanatory memorandum, 
the MNB is not explicitly entitle d  b y  c u r r e n t  l a w  t o  t a k e  a c t i o n in relation to environmental 
sustainability in the context of monetary policy. Thus, the Hun garian legislator considers it 
necessary to prescribe in the Law on the MNB that the MNB shall  support environmental 
sustainability with the means at its disposal, without prejudic e to its primary objective of achieving 
and maintaining price stability.  
1.5 Second, the draft law enables the MNB to use the revenues f rom supervisory fees, fines imposed 
by the MNB and administrative service fees to offset the impact  of its activities on the environment, 
in order to facilitate and support the implementation of enviro nmental objectives. The explanatory 
memorandum clarifies in this respect that the MNB would like to  provide a positive example in the 
field of environmental protection to institutions under its sup ervision and other domestic 
organisations.  
1.6 Third, the draft law provides that, as instruments of its m onetary policy, the MNB will provide 
energy efficiency consumer loans and, in relation to this task,  the MNB will manage Hungarian 
forint accounts for consumers. The explanatory memorandum expla ins that in Hungary residential 
buildings are responsible for nearly 25 % of the national prima ry energy consumption, and energy 
consumption per dwelling is high compared to the European Union  average. In addition, the 
renewal rate of the housing stock is lower than the regional av erage. The MNB introduced a Green 
Preferential Capital Requirement Programme3 in 2019. The programme ensures that credit 
institutions receive a Pillar II capital requirement reduction on consumer loans serving energy-
efficient home purposes if consumers receive an interest rate s ubsidy. However, up to now banks 
have not incorporated the beneficial features of green mortgage  loans into their lending standards 
and prices. According to the explanatory memorandum, as the cur rent business models of banks 
do not incorporate the positive externalities relating to energ y efficient mortgages, a central bank 
programme that enables direct lending to retail clients would b e needed. This could spur green 
residential real estate constructions and renovations, help ren ew the domestic residential real 
estate stock, and therefore support cutting greenhouse gas emis sions. The programme would also 
incentivise market participant s to provide new green housing lo ans.  
 2. Explicit reference in the M NB’s objectives to support of env ironmental sustainability  
2.1 The ECB welcomes the proposed amendment of the MNB’s mandat e, which provides that, without 
prejudice to its primary objective of achieving and maintaining  price stability, the MNB shall 
support, as a secondary objective, the government’s policy rela ted to environmental sustainability. 
The ECB understands that the purpose of the draft law is to emp hasise the role of environmental 
sustainability amongst the MNB’s secondary objectives. 
                                                 
3 ‘MNB introduces a green preferential capital requirement progr amme’, press releases 2019, available on the MNB’s 
website at www.mnb.hu  
ECB-PUBLIC  
3 2.2 The ECB notes that supporting the general economic policies  of the government, without prejudice 
to its primary objective of achie ving and maintaining price sta bility, is already part of the mandate of 
the MNB. Policies contributing to a high level of environmental  protection that have an economic 
dimension or qualify as general economic policies of the govern ment are implicitly covered by the 
current mandate of the MNB. Hence, the ECB understands that the  draft law does not aim at 
introducing a substantial reform of the MNB’s mandate, but rath er at clarifying the MNB’s existing 
mandate by explicitly specifying environmental sustainability a s a secondary objective of the MNB.  
2.3 The proposed change to the MNB’s mandate provided for in th e draft law is compatible with the 
Treaties. In accordance with Articles 119(2), 127(1) and 282(2)  of the TFEU the primary objective 
of the European System of Central Banks (ESCB) is to maintain p rice stability. Without prejudice to 
the objective of price stability, the ESCB supports the general  economic policies in the Union with a 
view to contributing to the achievement of the objectives of th e Union as laid down in Article 3 of 
the Treaty on the European Union (TEU). The ESCB acts in accord ance with the principle of an 
open market economy with free competition, favouring an efficie nt allocation of resources, and in 
compliance with the principles set out in Article 119 TFEU. Art icle 3(3) TEU in turn provides that the 
Union must, inter alia, work for the sustainable development of  Europe based on balanced 
economic growth and price stability, a highly competitive socia l market economy, aiming at full 
employment and social progress, and a high level of protection and improvement of the quality of 
the environment. In addition, Article 11 TFEU provides that env ironmental protection requirements 
must be integrated into the definition and implementation of th e Union’s policies and activities, in 
particular with a view to promoting sustainable development. In  the same vein, Article 37 of the 
Charter of Fundamental Rights of the European Union stipulates that a high level of environmental 
protection and the improvement of the quality of the environmen t must be integrated into the 
policies of the Union and ensured in accordance with the princi ple of sustainable development.  
2.4 Climate change can specifically impact central banks, and t he manner in which they discharge their 
mandates. Physical risks and transition risks associated with c limate change can potentially cause 
abrupt changes in prices and thereby threaten price stability4. Although methodologies to assess 
the magnitude of climate-related risks for banks and financial stability are still being developed, 
available estimates suggest that the impact of these risks is l ikely to be significant5. This, in turn, 
could impair the transmission mechanism of monetary policy. The  Network of Central Banks and 
Supervisors for Greening the Financial System (hereinafter the ‘NGFS’), an international group of 
87 central banks and supervisors, including most ESCB central b anks, recommends, therefore, 
that central banks consider the possible effects of climate cha nge on the economy. The NGFS 
argues that these effects may be relevant to monetary policy ev en if they only materialise beyond 
the conventional three- to five-year policy horizon6.  
                                                 
4  See Christine Lagarde, ‘Climate change and central banking’, ILF conference on Green Banking and Green Central 
Banking, Frankfurt am Main, 25 January 2021, available on the E CB’s website at www.ecb.europa.eu .  
5  See Isabel Schnabel, ‘Never waste a crisis: COVID-19, climate  change and monetary policy’, virtual roundtable on 
‘Sustainable Crisis Responses in Europe’, INSPIRE Research Netw ork, 17 July 2020, available on the ECB’s 
website at www.ecb.europa.eu .  
6 See ‘Climate change and monetary policy: initial takeaways, te chnical document, June 2020, available on the 
Network of Central Banks and Supervisors for Greening the Finan cial System’s website at www.ngfs.net . f 
ECB-PUBLIC  
4  
3. Offsetting the MNB’s carbon footprint The ECB welcomes the MNB’s initiative to offset its carbon foot print as a complementary measure to the 
accomplishment of its other institutional environmental objecti ves. While many central banks in the ESCB 
seek to offset their carbon footprint as part of good corporate  governance, it is relatively rare for central 
banks’ activities in this area to be specifically mandated by l aw. In this respect, the ECB understands that 
this specific provision in the draft law is introduced to make the MNB’s spending on the offsetting of its 
carbon footprint transparent, and that the draft law does not a uthorise the MNB to use its revenues to 
facilitate and support the implementation of environmental obje ctives generally, but rather only to avoid, 
reduce and offset the impact of the MNB’s own activities on the  environment. 
 4. The MNB’s new task to provide energy efficiency loans to con sumers 
4.1 The draft law confers a new task on the MNB by requiring th e MNB, as part of the instruments of its 
monetary policy, to provide energy efficiency loans directly to  consumers in order to support green 
residential real estate developments.  
4.2 In accordance with Article 42.2 of the Statute of the ESCB,  the central banks of Member States 
with a derogation, including Hungary, retain their powers in th e field of monetary policy according to 
national law. This notwithstanding, the explanatory memorandum accompanying the draft law 
argues that the current business models of banks do not incorpo rate positive externalities relating 
to energy efficient mortgage loans and therefore a central bank  programme that enables direct 
lending to retail clients is needed. In this respect, the expla natory memorandum does not 
convincingly reason that such lending is linked to the primary objective of monetary policy to 
maintain price stability, which would qualify such intervention  as a monetary policy measure. 
Moreover, direct residential real estate lending to consumers i s not expressly among the 
instruments of monetary policy envisaged for the ECB and the NC Bs by the TFEU and the Statute 
of the ESCB. Monetary operations within the ESCB are typically conducted via the banking sector, 
by setting lending or borrowing conditions which are transmitte d to consumers and businesses, or 
via open market operations that affect financing conditions. Su ch operations pursue a monetary 
policy objective, unlike the direct provision of energy efficie ncy loans to consumers, which pursue 
an objective that can be better served by government agencies o r credit institutions. Against this 
backdrop, the ECB emphasises that a proposed conferral of new t asks on a national central bank 
(NCB) participating in the ESCB, including the MNB, must be ass essed against the prohibition of 
monetary financing laid down in Article 123(1) TFEU. For the pu rposes of that prohibition, Article 
1(1)(b)(ii) of Council Regulation (EC) No 3603/93
7 defines ‘other type of credit facility’ as, inter alia, 
‘any financing of the public sector’s obligations vis-à-vis thi rd parties’. 
4.3 Ensuring that Member States maintain a sound budgetary poli cy is one of the key objectives of the 
prohibition on monetary financing, which may not be circumvente d. Therefore, the task of financing 
                                                 
7  Council Regulation (EC) No 3603/93 of 13 December 1993 specif ying definitions for the application of the 
prohibitions referred to in Articles 104 and 104b (1) of the Tr eaty (OJ L 332, 31.12.1993, p. 1). 
ECB-PUBLIC  
5 measures which are normally the responsibility of the Member St ates, and which are financed from 
their budgetary sources rather than by the NCBs, must not be en trusted to NCBs. To decide what 
constitutes financing of the public sector’s obligations vis-à- vis third parties – which can be 
translated as the provision of central bank financing outside t he scope of central bank tasks – it is 
necessary to carry out, on a case-by-case basis, an assessment of whether the task to be 
undertaken by an NCB is a central bank task or a government tas k, i.e. a task within the 
responsibility of the Member State s. In other words, adequate s afeguards must be in place to 
ensure that circumventions of the objective of the prohibition on monetary financing, which is to 
maintain sound budgetary policy by Member States, do not take p lace. 
4.4 As part of its discretion in the exercise of its duty – on the basis of Article 271(d) TFEU and 
Article 35.6 of the Statute of the European System of Central B anks and of the European Central 
Bank (hereinafter the ‘Statute of the ESCB’) – to ensure that N CBs honour the obligations laid 
down by the TFEU, the Governing Council has endorsed safeguards  in the form of criteria for 
determining what may be considered as falling within the scope of ‘the public sector’s obligations 
vis-à-vis third parties’ within the meaning of Article 1(1)(b)( ii) of Regulation (EC) No 3603/93 or, in 
other words, what constitutes a government task, as follows: 
First, central bank tasks are, in particular, those tasks that are related to the tasks that have been 
conferred upon the ECB and the NCB s by TFEU and the Statute of the ESCB. These tasks are 
mainly defined in Article 127(2), (5) and (6), and Article 128( 1) TFEU, as well as in Article 22 of the 
Statute of the ESCB. 
Second, as Article 14.4 of the Statute of the ESCB allows NCBs to perform ‘functions other than 
those specified in [the Statute of the ESCB]’, new tasks, i.e. tasks that are not related to tasks that 
have been conferred upon the ECB and the NCBs, are not preclude d per se. However, new tasks 
that are undertaken by an NCB and which are atypical of NCB tas ks or which are clearly 
discharged on behalf of, and in the exclusive interest of the g overnment or of other public sector 
entities, should be considered government tasks. 
Third, an important criterion for qualifying a new task as atyp ical of an NCB task, or as being 
clearly discharged on behalf of and in the exclusive interest o f the government or other public 
sector entities, is the impact of the task on the institutional , financial and personal independence of 
that NCB. 
In particular, the following asp ects should be taken into accou nt: 
(a) whether the performance of the new task creates conflicts o f interest with existing central 
bank tasks which are not adequately addressed, and its performa nce does not necessarily 
complement those existing central bank tasks. If a conflict of interest arises between existing 
and new tasks, sufficient safeguards to mitigate that conflict should be in place. The 
complementarity between a new task and existing central bank ta sks should not be 
interpreted broadly so that it could lead to the creation of an  indefinite chain of ancillary 
tasks. Such complementarity should be examined in relation to t he financing of those tasks;  
ECB-PUBLIC  
6 (b) whether without new financial resources the performance of the new task is disproportionate 
to the NCB’s financial or organisational capacity, and may have  a  nega ti ve im pa ct o n the 
capacity to properly perform the existing central bank tasks;  
(c) whether the performance of the new task fits into the insti tutional set-up of the NCB in the 
light of central bank independence and accountability considera tions;  
(d) whether the performance of the new task harbours substantia l financial risks;  
(e) whether the performance of the new task exposes the members  of the NCB decision-making 
bodies to political risks that are disproportionate and may als o have an impact on their 
personal independence and, in particular, on the guarantee of t erm of office set out in 
Article 14.2 of the Statute of the ESCB. 
4.5 Tasks related to the tasks conferred upon the EC B and the NCBs by the TFEU and the Statute of 
the ESCB 
As previously noted, direct residential real estate lending to consumers is not expressly among the 
instruments of monetary policy envisaged for the ECB and the NC Bs by the TFEU and the Statute 
of the ESCB. Moreover, it is not clear from the explanatory mem orandum that such lending is 
linked to the primary objective of monetary policy to maintain price stability.   
4.6 Tasks which are atypical of central bank tasks 
Direct residential real estate lending to consumers is atypical  of central bank tasks. With the 
exception of lending by some ESCB central banks to their staff,  no central bank in the ESCB 
currently engages in direct lending to consumers. In certain Me mber States the provision of 
financial support to subsidise energy efficiency loans to consu mers in order to support green 
residential real estate developments is conducted directly by t he State,8 or State-owned entities 
such as development banks9, funds10 or foundations11, also under co-funded Union schemes12. As 
previously noted, monetary operations within the ESCB are typic ally conducted via the banking 
sector, by setting lending or borrowing conditions which are tr ansmitted to consumers and 
businesses, or via open market operations that affect financing  conditions. Such operations pursue 
                                                 
8  For example, in Austria, financial subsidies for housing proj ects are granted and administered by competent 
departments of the regional governments. In France, the Ministr y of Finance in collaboration with the Agency for 
Environment and Energy Management (ADEME) promotes an eco-loan to facilitate energy renovation, granted by 
commercial banks with a financial ceiling, but regardless of in come conditions. 
9  For example, in Germany, depending on the financial support c hosen, either the state-owned promotional bank KfW 
provides a subsidised loan at favourable conditions or the Fede ral Office for Economic Affairs and Export Control 
(Bundesamt für Ausfuhrkontrolle  BAFA) pays State subsidies. In Greece, such financial support in connection with 
energy-efficient housing projects is granted through the Hellen ic Development Bank (HDB). In Latvia, a state-owned 
development finance institution ALTUM is mandated to provide fi nancial aid for energy efficiency improvement 
measures. 
10  For example, in Croatia the 2003 Law on the Fund for Environm ental Protection and Energy Efficiency set up the 
Environmental Protection and Energy Efficiency Fund as a legal entity with public authority for collecting and 
investing extra budgetary resources in programmes and projects supporting environmental and nature protection, 
energy efficiency and the use of renewable energy sources. 
11 For example, in Estonia the KredEx foundation was set up by th e Ministry of Economic Affairs and Communications 
inter alia  with the aim of increasing the energy performance of residentia l buildings in Estonia. 
12  For example, in Ireland the Better Energy Warmer Homes Scheme  (BEWHS) is operated by the Sustainable Energy 
Authority of Ireland (SEAI) and co-funded by the Irish Governme nt and the Union through the European Regional 
Development Fund. 
ECB-PUBLIC  
7 a monetary policy objective, unlike the direct provision of ene rgy efficiency loans to consumers, 
which pursue an objective that can be better served by governme nt agencies or credit institutions. 
4.7 Tasks clearly discharged on behalf of and in the exclusive interest of the government 
As noted above, in those Member States where financial support is provided to subsidise energy 
efficiency loans to consumers in order to support green residen tial real estate developments, this 
support is provided directly by the State, or by State-owned en tities such as development banks, 
funds or foundations.  
4.8 Extent to which performance of the new tasks creates conflicts of interest with existing central bank 
tasks 
As indicated above, central bank operations in the ESCB are con ducted with credit institutions and 
other market participants with a view to maintaining the primar y objective of price stability. While 
the ESCB has a duty, without prejudice to the objective of pric e stability, to support the general 
economic policies in the Union with a view to contributing to t he achievement of the objectives of 
the Union, including working for a high level of protection and  improvement of the quality of the 
environment, it may be questioned whether direct residential re al estate lending to consumers to 
support green residential real estate developments would be in accordance with the principle of an 
open market economy with free com petition, favouring an efficie nt allocation of resources, or if any 
interference with this principle could be justified by the cent ral bank in accordance with 
proportionality standards. Mortgage lending to consumers is typ ically undertaken by credit 
institutions in an open market economy where credit institution s compete with one another for 
mortgage lending business, subject to supervision by the public  authorities responsible for the 
prudential supervision of credit institutions (in Hungary, the MNB) and the protection of consumers. 
In principle, the entry by a central bank into this market woul d distort the market, and raise 
questions as to how the activities of the central bank would be  overseen or supervised. It would 
seem that credit institutions would be better positioned than c entral banks to price mortgage loans. 
Moreover, given that central banks are not the primary actors w hen it comes to economic or 
environmental policies, if the Hungarian authorities perceive t hat there is a need for State 
intervention in the mortgage lending market for green residenti al real estate developments, it would 
seem incumbent on the authorities to explore options other than  direct lending to consumers by 
central banks, such as government subsidies or appropriate lend ing arrangements financed 
through development or other State-owned banks. It would otherw ise not be apparent that the 
departure from the principle of an open market economy could be  justified by the central bank in 
accordance with proportionality standards. It should also be no ted that an arrangement whereby 
the central bank is tasked by law to perform certain non-standa rd tasks stands in stark contrast to 
one where the central bank has the freedom to undertake operati ons, which could be seen as 
diminishing central bank independence. The MNB’s competence to independently decide on 
conducting operations with its monetary counterparts  via regular instruments of monetary policy, 
which may support the Hungarian government’s policy relating to  environmental sustainability, 
should not be prejudiced. 
4.9 Extent to which the performance of the new tasks is disproportionate to MNB’s financial or 
organisational capacity 
ECB-PUBLIC  
8 The principle of financial independence requires NCBs to have s ufficient means to carry out not 
only their ESCB-related tasks but also their national tasks, bo th from an operational and financial 
perspective13. To perform its new task under the draft law, the MNB would be  obliged to dedicate 
substantial additional human and financial resources to manage its new consumer lending 
portfolios. Mortgage lending is a demanding commercial banking business, requiring extensive due 
diligence on the part of lenders, including assessing the credi tworthiness of large numbers of 
individual borrowers in the general population, valuing real es tate in different urban and rural 
locations, mobilising collateral in the form of security intere sts over residential real estate which 
may need to be foreclosed in the event of borrower default, ens uring that the borrower has 
appropriate life and property insurance arrangements in place, attending to any relevant consumer 
protection issues, and so on. Central banks do not have a parti cular operational expertise in this 
intricate business. The performance of these extensive new task s would therefore appear to be 
disproportionate to the MNB’s existing financial and organisati onal capacity, in the absence of 
supplementary means being granted to the MNB.  
4.10 Extent to which performance of the new tasks fits in to the MNB’s institutional set-up, in the light of 
central bank independence and accountability considerations 
Mortgage lending is a matter of great interest to the general p ublic, as a mortgage loan counts 
among the most significant financial commitments undertaken by the individual citizen. The MNB 
would therefore assume the reputational risk of being held acco untable by the general public and, 
indeed, the institutions of government for any perceived shortc omings in the performance of its 
new consumer lending activities. This new task, therefore, does  not appear to smoothly fit into the 
MNB’s existing institutional set-up. 
4.11 Extent to which the performance of ta sks harbours substantial financial risks 
The MNB’s proposed lending activities would mean that the MNB w ould assume substantial credit 
risks on its balance sheet. Based on the nature of such loans, credit risks would remain on the 
balance sheet of the central bank for a prolonged period of tim e, possibly extending to decades. As 
with any mortgage lending portfolio, which is susceptible to fl uctuations in real estate prices and 
general economic developments, this activity could potentially expose the MNB to substantial 
financial risks. This is different from central banks providing  credit to their monetary policy 
counterparts against marketable mortgage-related collateral, wh ere financial risks for the central 
bank are limited through adequate risk management measures such  as minimum credit ratings, 
valuation haircuts which are marked to market and margin calls.  Similar risk management 
measures would be impossible to implement for direct lending to  consumers. Furthermore, while 
central bank credit through monetary policy operations is provi ded on the same conditions to all 
counterparties, for direct lending to consumers the creditworth iness of the individual borrowers 
would impact their eligibility to obtain a mortgage loan, the p rincipal amount of the loan, and in 
some cases also the interest rate. 
4.12 Conclusion 
                                                 
13  See the ECB’s 2016 Convergence Report, p. 25. 
ECB-PUBLIC  
9 The ECB supports the provision of energy efficiency loans, whic h is a reality across the Union 
already and needs to be expanded. The ECB also understands the wish of the Hungarian 
authorities to reach an acceleration of this kind of lending in  Hungary. However, the new task 
proposed to be conferred on the MNB to provide energy efficienc y loans directly to consumers in 
order to support green residential real estate developments is a task which can be more 
appropriately performed by private or state-owned credit instit utions or development banks, rather 
than central banks. Within the framework of the ESCB, direct re sidential real estate lending to 
consumers is not among the instruments of monetary policy expre ssly envisaged for the ECB and 
the NCBs by the TFEU and the Statute of the ESCB. This task is atypical of central bank tasks. 
With the exception of lending by some ESCB central banks to the ir staff, no central bank in the 
ESCB currently engages in direct lending to consumers. In certa in Member States the provision of 
financial support to subsidise energy efficiency loans to consu mers in order to support green 
residential real estate developments is conducted directly by t he State, or state-owned banks or 
development banks. Against this b ackdrop, it is suggested that such a task would be discharged on 
behalf of and in the exclusive interest of the government. Give n the substantial operational 
challenges of the mortgage lending business, this task would, i n the absence of further means 
being granted to the MNB, be disproportionate to the MNB’s fina ncial and organisational capacity, 
and could leave the MNB vulnerable to substantial financial ris ks. The performance of this task 
would also entail reputational risks for the MNB, and would not  fit smoothly into the MNB’s 
institutional set-up. The performance of this task would theref ore be classified as a government, 
rather than a central banking task for the purposes of the proh ibition of monetary financing, and 
would, accordingly, have to be entirely conducted by the State,  rather than with central bank 
resources. Also, the MNB’s competence to independently decide o n conducting operations with its 
monetary counterparts  via regular instruments of monetary policy should not be prejud iced. In 
conclusion, the ECB notes that central banks can independently decide on conducting operations 
with their monetary counterparts via regular instruments of mon etary policy, which may support the 
government’s policy relating to environmental sustainability. H owever, for the reasons indicated 
above, the Hungarian authorities are strongly encouraged not to  allocate to the MNB the task of 
providing energy efficiency loans directly to consumers.  
 This opinion will be published on EUR-Lex.  
  
Done at Frankfurt am Main, 19 March 2021. 
 [signed] 
 The President of the ECB 
Christine LAGARDE