COMMISSION STAFF WORKING DOCUMENT 2024 Rule of Law Report Country Chapter on the rule of law situation in Hungary Accompanying the document COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS 2024 Rule of Law Report The rule of law situation in the European Union
Date: 2024-07-24
Institutions: European Commission, Secretariat-General
Subjects: Hungary, administrative transparency, corruption, democracy, freedom of the press, independence of the judiciary, infringement of EU law, pluralism in the media, rule of law, whistleblowing

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 24.7.2024  SWD(2024) 817 final  COMMISSION STAFF WORKING DOCUMENT 2024 Rule of Law Report        Country Chapter on the rule of law situation in Hungary Accompanying the document COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS 2024 Rule of Law Report                  The rule of law situation in the European Union {COM(2024) 800 final} - {SWD(2024) 801 final} - {SWD(2024) 802 final} - {SWD(2024) 803 final} - {SWD(2024) 804 final} - {SWD(2024) 805 final} - {SWD(2024) 806 final} - {SWD(2024) 807 final} - {SWD(2024) 808 final} - {SWD(2024) 809 final} - {SWD(2024) 810 final} - {SWD(2024) 811 final} - {SWD(2024) 812 final} - {SWD(2024) 813 final} - {SWD(2024) 814 final} - {SWD(2024) 815 final} - {SWD(2024) 816 final} - {SWD(2024) 818 final} - {SWD(2024) 819 final} - {SWD(2024) 820 final} - {SWD(2024) 821 final} - {SWD(2024) 822 final} - {SWD(2024) 823 final} - {SWD(2024) 824 final} - {SWD(2024) 825 final} - {SWD(2024) 826 final} - {SWD(2024) 827 final} - {SWD(2024) 828 final} - {SWD(2024) 829 final} - {SWD(2024) 830 final} - {SWD(2024) 831 final}  
 
 
ABSTRACT 

The 2023 judicial reform is being implemented. The National Judicial Council is exercising 
its new competences to effectively counterbalance the powers of the President of the National 
Office  for  the  Judiciary.  Rules  on  preliminary  references  to  the  Court  of  Justice  of  the  EU 
have  been  clarified,  in  line  with  the  requirements  of  EU  law.  The  transparency  of  case 
allocation  in  the  Kúria  has  further  improved,  yet  concerns  remain  regarding  the  lack  of 
transparency  of  case  allocation  in  lower  courts.  While  the  new  legal  framework  aims  at 
limiting the risk of arbitrary decisions about the career of judges, no further steps were taken 
to  address  concerns  raised  by  the  National  Judicial  Council.  Political  influence  on  the 
prosecution  service  remains,  with  the  risk  of  undue  interference  with  individual  cases.  The 
freedom of expression of judges remains under pressure and smear campaigns against judges 
continue  in  the  media.  The  level  of  remuneration  of  judges  and  court  staff  has  further 
deteriorated. The efficiency of the judiciary in civil, commercial and administrative cases, as 
well as the overall level of digitalisation of the justice system, remain high.  

Hungary has adopted a new anti-corruption strategy for 2024-2025. Legislation on lobbying 
and revolving doors is planned, while enforcement and oversight remain an issue as regards 
asset  declarations.  The  new  Integrity  Authority  reports  certain  obstacles  in  fulfilling  its 
oversight  tasks  effectively,  and  the  impact  in  practice  of  the  Anti-Corruption  Task  Force 
remains  to  be  seen.  Shortcomings  regarding  political  party  and  campaign  financing  remain 
unaddressed.  Some  high-level  corruption  cases  have  reached  the  indictment  stage,  but  the 
lack of a robust track record of investigations of corruption allegations concerning high-level 
officials  and  their  immediate  circle  remains  a  serious  concern.  Court  decisions  reviewing 
prosecutorial  decisions  not  to  investigate  or  prosecute  corruption  are  still  not  binding  and 
have  so  far  not  brought  significant  results,  although  the  possibility  of  judicial  review 
incentivises  prosecutors 
thoroughly.  The  suspension  of 
commitments  from  EU  funds  under  several  EU  programmes  and  the  lack  of  disbursements 
following  a  payment  request  under  the  Recovery  and  Resilience  Plan  persist,  as  no  new 
measures have been adopted to remedy the outstanding rule of law and anti-corruption issues. 

to  assess  allegations  more 

The threats to media pluralism highlighted in previous Rule of Law Reports have remained 
unaddressed. No measures have been adopted or are planned to  regulate  the channelling  of 
state  advertising  to  media  outlets,  to  guarantee  the  functional  independence  of  the  media 
authority  and  to  ensure  the  editorial  and  financial  independence  of  public  service  media. 
Journalists  and  independent  media  outlets  continue  to  face  numerous  challenges  including 
seemingly  coordinated  smear  and  de-legitimisation  campaigns,  and  selective  access  to 
government  premises  and  events.  Further  legislative  changes  have  introduced  some 
restrictions to freedom of information. 

Increasing state interventions and arbitrary decisions of the authorities remain a problem for 
the  operation  of  businesses  in  the  single  market.  The  ‘state  of  danger’  has  been  further 
extended  until  November  2024.  The  quality  of  law-making  and  the  frequent  changes  in 
legislation remain a significant cause for concern. The Constitutional Court still reviews the 
merits  of  final  rulings  of  ordinary  courts  in  politically  sensitive  cases.  Obstacles  affecting 
civil  society  organisations  persist,  while  the  new  Protection  of  National  Sovereignty  Act 
further undermines civic space. Concerns related to the State’s role in financing civil society 
continue.  

1 

 
 
RECOMMENDATIONS 

Overall,  concerning  the  recommendations  in  the  2023  Rule  of  Law  Report,  Hungary  has 
made: 

•  No progress on improving the transparency of case allocation systems in lower-instance 

courts, taking into account European standards on case allocation. 

•  No  progress  on  adopting  comprehensive  reforms  on  lobbying  and  revolving  doors,  and 
further  improve  the  system  of  asset  declarations,  providing  for  effective  oversight  and 
enforcement. 

•  No progress yet on establishing a robust track record of investigations, prosecutions and 

final judgments for high-level corruption cases.  

•  No  progress  on  introducing  mechanisms  to  enhance  the  functional  independence  of  the 
media  regulator  taking  into  account  European  standards  on  the  independence  of  media 
regulators. 

•  No  progress  on  strengthening  the  rules  and  mechanisms  to  enhance  the  independent 
governance  and  editorial  independence  of  public  service  media  taking  into  account 
European standards on public service media. 

•  No  progress  on  adopting  legislation  to  ensure  fair  and  transparent  distribution  of 

advertising expenditure by the state and state-owned companies. 

•  No progress on fostering a safe and enabling civic space and remove obstacles affecting 
civil society organisations, including by repealing legislation that hampers their capacity 
of working, in particular the immigration tax. 

On this basis, and considering other developments that took place in the period of reference, 
in  addition  to  recalling  the  obligation  to  comply  with  the  rule  of  law-related  rulings  of  the 
ECJ  and  the  rule  of  law-related  infringement  procedures  referred  to  in  the  country  chapter, 
the  Commission’s  assessment  under  the  general  regime  of  conditionality,  the  relevant 
concerns raised in the Article 7(1) TEU procedure initiated by the European Parliament, the 
relevant  commitments  made  under  the  Recovery  and  Resilience  Plan,  and  the  relevant 
country-specific  recommendations  under  the  European  Semester,  it  is  recommended  to 
Hungary to: 

• 

Improve the transparency of case allocation systems in lower-instance courts, taking into 
account European standards on case allocation.  

•  Take structural measures to increase the remuneration of judges, prosecutors, and judicial 
and  prosecutorial  staff,  taking  into  account  European  standards  on  remuneration  for  the 
justice system. 

•  Adopt comprehensive reforms on lobbying and revolving doors, and further improve the 

system of asset declarations, providing for effective oversight and enforcement. 

•  Establish  a  robust  track  record  of  investigations,  prosecutions  and  final  judgments  for 

• 

high-level corruption cases. 
Introduce  mechanisms  to  enhance  the  functional  independence  of  the  media  regulatory 
authority  taking  into  account  European  standards  on  the  independence  of  media 
regulators. 

•  Adopt legislation to ensure fair and transparent distribution of advertising expenditure by 

the state and state-owned companies. 

2 

 
•  Strengthen  the  rules  and  mechanisms  to  enhance  the  independent  governance  and 
editorial independence of public service media taking into account European standards on 
public service media. 

•  Remove obstacles affecting civil society organisations and foster a safe and enabling civic 
space,  including  by  repealing  legislation  that  hampers  their  capacity  of  working,  in 
particular the immigration tax. 

3 

 
 
 
 
I. 

JUSTICE SYSTEM1  

Hungary  has  a  four-tier  ordinary  court  system.  114  district  courts  operate  at  first  instance, 
while 20 regional courts hear appeals from district courts and decide on certain cases at first 
instance.  Five  regional  appeal  courts  decide  on  appeals  against  decisions  of  the  regional 
courts.  Administrative  cases  are  dealt  with  by  the  ordinary  courts  (the  Budapest  Regional 
Appeal Court hears appeals against first-instance decisions of the eight regional courts with 
an administrative department). The main role of  the Supreme Court  (Kúria) is  to  guarantee 
the uniform application of the law. The Fundamental Law tasks the President of the National 
Office for the Judiciary (NOJ), elected by Parliament, with the central administration of the 
courts.  The  National  Judicial  Council  is  an  independent  body,  with  legal  capacity  and 
budgetary  autonomy  acquired  following  the  June  2023  reform,  which  supervises  the  NOJ 
President  and  participates  in  the  administration  of  the  courts.  Judges  are  appointed  by  the 
President  of  the  Republic  following  a  recommendation  of  the  NOJ  President  based  on  a 
ranking  of  candidates  established  by  the  local  judicial  councils.  The  NOJ  President  cannot 
deviate from this  ranking without the prior consent  of the National  Judicial Council.  In the 
case of Kúria judges, the recommendation is made by the Kúria President. The Constitutional 
Court is not part of the ordinary court system. The prosecution service is independent under 
the  Fundamental  Law  and  is  vested  with  powers  to  investigate  and  prosecute  crime.  The 
Hungarian Bar Association and the regional bar associations are autonomous self-governing 
public bodies. 

Independence  

The level of perceived judicial independence in Hungary is now average among both the 
general  public  and  companies.  Overall,  41%  of  the  general  population  and  40%  of 
companies perceive the level of independence of courts and judges to be ‘fairly or very good’ 
in  20242.  The  perceived  level  of  independence  among  the  general  public  has  increased  in 
comparison  with  2023  (35%),  but  it  is  lower  than  in  2020  (48%).  The  perceived  judicial 
independence  among  companies  has  increased  since  2020  (26%),  as  well  as  in  comparison 
with 2023 (32%)3. 

Following the legislative reform in 2023, the National Judicial Council exercises its new 
competences  to  effectively  counterbalance  the  powers  of  the  President  of  the  National 
Office  for  the  Judiciary.  As  noted  in  the  2023  Rule  of  Law  Report,  Hungary  adopted  a 

1   The assessments included in this country chapter do not prejudge any future assessment under Article 24 of 
Regulation (EU) 2021/241 of the European Parliament and of the Council of 12 February 2021 establishing 
the  Recovery  and  Resilience  Facility  or  under Article  15  of  Regulation  (EU)  2021/1060  of  the  European 
Parliament and of the Council of 24 June 2021 laying down common provisions on the European Regional 
Development  Fund,  the  European  Social  Fund  Plus,  the  Cohesion  Fund,  the  Just  Transition  Fund  and  the 
European  Maritime,  Fisheries  and  Aquaculture  Fund  and  financial  rules  for  those  and  for  the  Asylum, 
Migration  and  Integration  Fund,  the  Internal  Security  Fund  and  the  Instrument  for  Financial  Support  for 
Border Management and Visa Policy. 

2   Figures 51 and 53, 2024 EU Justice Scoreboard, and Figures 50 and 52, 2022 EU Justice Scoreboard. The 
level  of  perceived  judicial  independence  is  categorised  as  follows:  very  low  (below  30%  of  respondents 
perceive judicial independence as fairly good and very good); low (between 30-39%), average (between 40-
59%), high (between 60-75%), very high (above 75%).  

3   45% of the companies are either fairly or very confident that their investments are protected by the law and 
courts. Only 19% of the surveyed companies see the quality, efficiency or independence of justice as one of 
the main reasons for concern about investment protection (Figures 55 and 56, 2024 EU Justice Scoreboard). 

4 

 
 
legislative  reform  which  establishes  as  of  1  June  2023  stronger  powers  for  the  National 
Judicial Council. This reform was positively assessed by the Commission4. The Council has 
started  to  exercise  its  new  powers,  taking  a  series  of  actions  within  its  competence5.  For 
instance, the Council has given binding opinions on numerous proposals of the NOJ President 
to  change  the  number  of  judicial  posts  in  various  courts  or  to  second  judges6.  The  NOJ 
cooperated with the Council to support its institution building; after the end of the 9-month 
‘incubation period’7, since 1 March 2024, the National Judicial Council has been able to fully 
exercise  its  budgetary  autonomy8.  The  newly  elected  14  judges-members  –  including  one 
regional court president9 – took office on 30 January 2024. On 14 February 2024, the Council 
set up an ad hoc committee to analyse the last election process and make recommendations 
for possible changes to the legislative framework10. 

4   The  reform  aimed  at  addressing  the  justice-related  milestones  of  Hungary’s  RRP.  It  also  relates  to  the 
horizontal enabling condition on the EU Charter of Fundamental Rights, as regards to judicial independence. 
On  13  December  2023,  in  the  context  of  the  Common  Provisions  Regulation,  the  Commission  adopted  a 
decision considering that Hungary had taken the necessary measures for the Commission to consider that the 
horizontal enabling condition on the Charter as regards judicial independence is now fulfilled. The European 
Parliament has challenged this decision before the Court of Justice (case C-225/24, pending). 

5   On 7 June 2023, the Council elected its first (non-rotating) president and vice-president; made a legislative 
proposal – supported by the Kúria President, the NOJ President and the Hungarian Association of Judges – 
to  the  Minister  of  Justice  related  to  judicial  salaries;  adopted  its  own  budget;  and  requested  the  NOJ 
President  to  grant  access  to  a  classified  report  containing  the  results  of  an  enquiry  into  the  failure  of  the 
President  of  the  Budapest  Regional  Court  to  shield  a  senior  judge  from  undue  external  pressure.  On  6 
September 2023, the Council gave consent to the 2024 training schedule for judges. On 4 October 2023, the 
Council determined the structure of the NOJ President’s biannual report. On 8 November 2023, the Council 
gave consent to the decision of the NOJ President related to the rules on the end-of-the-year bonuses payable 
to judges. On 6 December 2023, the Council invited the Minister of Justice to review the Decree setting out 
the  point  system  applicable  to  the  evaluation  of  applications  for  judicial  posts.  On  27  March  2024,  the 
Council gave binding opinions as regards the suitability of candidates for the post of  Kúria Vice President. 
On 17 April 2024, the Council gave binding opinions as regards the suitability of candidates for the post of 
NOJ Vice President. 

6   The  Council  has  several  times  refused  to  give  consent  where  it  found  that  the  NOJ  President’s  proposal 
lacked sufficient explanations (contribution from Res Iudicata Association for the 2024 Rule of Law Report, 
p. 11). The Council did not agree (Decision 89/2023 of 4 October 2023) with the secondment (‘beosztás’) as 
of 1 October 2023 to the Ministry of Foreign Affairs of a former member of the Constitutional Court who 
had been appointed to the Budapest Regional Appeal Court as of 2 September 2023 following his request, 
after becoming a judge in 2020 outside the ordinary appointment procedure. 

7   For a period of nine months, the NOJ provided administrative support to the National Judicial Council which 
gained  legal  capacity  and  budgetary  autonomy  and  had  to  build  adequate  administrative  capacity.  The 
Council accepted its first elected president’s report also covering the Council’s institution-building efforts in 
the period 7 June 2023 to 30 January 2024 (Decision 34/2024 of 13 March 2024). The Council’s institution 
building continued following the ‘incubation period’ (verbatim minutes of the 27 March 2024 meeting of the 
National Judicial Council). 

8   Information received in the context of the country visit to Hungary from the National Judicial Council and 

the National Office for the Judiciary. 

9   Stakeholders  expressed  concerns  as  regards  the  possibility  for  court  presidents,  appointed  by  the  NOJ 
President, to become members of the National Judicial Council tasked with supervising the NOJ President 
(contribution  from  Res  Iudicata  Association  for  the  2024  Rule  of  Law  Report,  p.  13;  contribution  from 
Magistrats  Européens  pour  la  Démocratie  et  Libertés  (MEDEL)  for  the 2024  Rule  of  Law  Report,  p.  14). 
Pursuant to the 2023 reform, court presidents and vice-presidents are no longer allowed to participate in the 
deliberation and vote on matters relating to their administrative activities. 

10   Verbatim  minutes  of  the  14  February  2024  meeting  of  the National  Judicial  Council. The  President  of  the 
Council explained that the experiences of the last elections need to be analysed based on an overview of the 
way how the procedure was conducted in the different courts. The ad hoc committee was also tasked with 

5 

 
 
 
The  transparency  of  case  allocation  in  the  Kúria  has  improved  as  a  result  of  the  2023 
reform.  The  Kúria  President  amended11  the  case  allocation  scheme  as  of  16  July  2023  to 
bring it in line with the requirements of the legislative reform12 applicable as of 1 June 2023. 
In January and April 2024, the case allocation scheme was further amended. It now contains 
clearer rules on forming three- and five-judge panels where the number of judges assigned to 
the chamber  exceeds  five or when the number of presiding judges assigned to  the chamber 
exceeds two13. Special rules applied to  the composition  of three-judge panels  hearing cases 
related to the 2024 European parliamentary and municipal elections14. As of 6 February 2024, 
following the entry into force of a Ministerial Decree15, the Kúria extended the data content 
of the log files published weekly on its web site, which allow anyone  to verify more easily 
whether  the  rules  on  case  allocation  have  been  duly  applied.  While  also  reorganising  two 
Chambers  of  the  Civil  Department,  the  Kúria  President  dissolved,  as  of  1  January  2024, 
Chamber  II  of  the  Administrative  Department  and  its  judges  were  assigned  to  other 
chambers16.  The  Kúria  explained  this  decision  as  motivated  by  staffing  reasons17,  however 
stakeholders described it as arbitrary18.  

making  proposals  for  a  possible  change  to  the  applicable  law  and  internal  regulations,  where  necessary. 
Substitute members were elected on 15 January 2024. Former members of the Council decided not to run for 
office. The National Judicial Council is composed of the Kúria President ex officio and 14 judges-members 
(and 14 substitute members) elected by their peers for a period of six years. Judges-members (one court of 
appeal  judge,  six  regional  court  judges  and  seven  district  court  judges)  are  elected  by  a  conference  of 
delegates from among delegate judges. The full court of the  Kúria and the plenary sessions of each of the 
five regional appeal courts and the 20 regional courts elect 2 to 20 delegates.  

11   In  line  with  Sections  9(1),  151(2)  and  155(2)  of Act  CLXI  of  2011,  as  amended  by Act  X  of  2023,  the 
amendment to the case allocation scheme was issued by the Kúria President with the consent of the Kúria’s 
three departments (‘kollégium’) and judicial council (input from Hungary for the 2024 Rule of Law Report, 
p. 2; contribution from the Kúria for the 2024 Rule of Law Report, p. 1). 

12   Act X of 2023. See 2023 Rule of Law Report, Country Chapter on the rule of law situation in Hungary, pp. 

5-6. 

13   Contribution from the Kúria for the 2024 Rule of Law Report, p. 1. 
14   Currently,  the  Kúria’s Administrative  Department  has  seven  chambers  (one  of  them  only  dealing  with  the 
review  of  municipal  decrees)  composed  of  at  least  two  presiding  judges  and  at  least  three  other  judges. 
Election-related cases are heard by three-judge panels (Section 229(2) of Act XXXVI of 2023 on electoral 
procedure). Under the current rules, three-judge panels are composed of two presiding judges of the chamber 
and one other judge assigned to the chamber. 

15   Decree 18/2023 of 7 December 2023 of the Minister of Justice amended Decree 14/2002 of 1 August 2002 
of the Minister of Justice laying down the rules on judicial case  management.  On 13 December 2023, the 
Commission  positively  assessed  this  legislative  amendment  under  Article  15  of  the  Common  Provisions 
Regulation. The amendment clarifies that the Kúria shall enter into the register (‘lajstrom’) corresponding to 
the  case  category  (‘ügycsoport’)  all  ‘initial  documents’  (‘kezdőirat’)  received  by  electronic  means  in  the 
order of receipt, under the next registration number, with the proviso that as for the registration of the cases, 
each case shall be assigned a case number in an automated manner, without human intervention. Hungary 
has committed to take the necessary actions to ensure that an external forensic expert, independent from the 
Kúria, the NOJ and the Government, will conduct an  audit by 30 June 2024 with regard to the compliance 
with this new rule and that the European Commission will have access to the audit report. On 28 June 2024, 
a report by a forensic expert was delivered. Also, the amendment specifies the data content of the weekly log 
files that the Kúria publishes on its website, in accordance with Section 10(7) of Act CLXI of 2011. These 
logs now also show the date and time of arrival, registration and allocation of cases and the composition of 
the bench.  

16   The number of judges assigned to these chambers now exceeds five (five judges sit on a panel hearing an 

administrative case). The ongoing cases heard by Chamber II were reassigned to other chambers.  

17   According to the Kúria, the change in the organisation of the Administrative Department was entirely based 
on objective circumstances, with the retirement of one head of panel and one judge in January and March 
2024,  respectively  (written  contribution  from  the  Kúria  in  the  context  of  the  country  visit  to  Hungary). 

6 

 
 
 
Rules on preliminary references to the Court of Justice of the EU have been clarified, in 
line with the requirements of EU law. On 12 December 2023, Parliament adopted a law19 
amending the Criminal Procedure Code to remove any doubt as regards the right of judges to 
request in criminal proceedings a preliminary ruling from the Court of Justice in relation to 
any EU legal act or legislation20. At the same time, concerns have been raised as regards the 
national  preliminary  reference  procedure  before  the  Kúria  in  the  interest  of  uniformity  of 
law21. The Court of Justice confirmed in a preliminary reference from a Hungarian court that 
any  court  must  be  able  to  disregard  the  legal  assessment  of  a  higher  national  court  if  it 
considers, having regard to the interpretation of EU law provided by the Court of Justice, that 
such assessment does not comply with EU law22. 

There has been no progress to address concerns regarding the lack of transparency of 
case allocation in lower courts. The 2023 Rule of Law Report recommended to Hungary to 
‘[i]mprove the transparency of case  allocation systems  in  lower-instance courts, taking into 
account  European  standards  on  case  allocation’23.  In  accordance  with  the  applicable 
Hungarian legislation, these case allocation schemes continue to be established and regularly 

According to the Government, the measure can be explained by the introduction of five-judge panels (a 20% 
decrease in the number of cases and, as a result, the unreasonableness of filling vacant positions). 

18   Stakeholders  indicated  that  Chamber  II  had  handed  down  decisions  unfavourable  for  the  Government  in 
politically  sensitive  cases;  information  received  in  the  context  of  the  country  visit  to  Hungary  from  the 
National  Judicial  Council,  Hungarian Association  of  Judges  and  Eötvös  Károly  Policy  Institute.  See  also 
Kovács,  Ágnes  (2023):  Taking  Revenge  for  Dissent:  Hungary’s  Chief  Justice  to  Fully  Eliminate  Judicial 
Autonomy, VerfBlog.  

19   Section 35 of Act LXXXV of 2023 amending certain Acts required for strengthening the interconnectedness 
of universities, research institutes and the economy and certain Acts in the field of vocational training and 
culture entered into force on 13 February 2024. On 13 December 2023, the Commission positively assessed 
this legislative amendment under Article 15 of the Common Provisions Regulation. 

20   Section 490, paragraph (1), of the Criminal Procedure Code.  
21   The preliminary reference procedure in the interest of uniformity of law can be applied in two scenarios: (i) 
when a Kúria chamber wishes to deviate from the Kúria’s published case-law, it must stay the proceedings 
and request a uniformity decision; (ii)  the  Kúria (Vice) President,  the heads of  Kúria departments and the 
Prosecutor General may request a uniformity decision if it is necessary to ensure the uniform interpretation 
of  the  law,  or  to  alter  or  annul  a  previous  uniformity  decision,  also  if  this  question  does  not  arise  in  a 
concrete  pending  case.  The  Kúria’s  uniformity  decisions  are  binding  on  the  courts  until  the  uniformity 
complaint panel changes the decision.. By contrast, other published decisions of the  Kúria act as a limited 
precedent:  since  1 April  2020,  lower-level  courts  have  been  required  by  law  to  explain  why  they  do  not 
follow the interpretation of legal provisions given by the Kúria in its published decisions. Such deviation is a 
ground  for  an  extraordinary  remedy  before  the  Kúria.  Deviation  by  a  Kúria  chamber  from  the  Kúria’s 
published  case  law  requires  a  new  decision  of  the  Kúria’s  uniformity  complaint  panel.  Preliminary 
references in the interest of uniformity of law are heard by the uniformity complaint panels composed of the 
Kúria President and Vice President and 20 senior judges (the Secretary General, heads and deputy heads of 
department and presiding judges). 

22   In January 2024, the Court of Justice ruled that the principle of the primacy of EU law must be interpreted as 
requiring the national court, having exercised the power conferred on it by Article 267 TFEU, to disregard 
the  legal  assessments  of  a  higher  national  court  if  the  referring  court  considers,  having  regard  to  the 
interpretation  of  a  provision  of  EU  law  provided  by  the  Court  of  Justice,  that  those  assessments  do  not 
comply with EU law; that principle does not, however, preclude national legislation which merely requires 
lower  national  courts  to  give reasons  for  any  departure  from  those  assessments  (judgment  of  the  Court  of 
Justice of 11 January 2024, Global Ink Trade Kft., C-537/22, ECLI:EU:C:2024:6, para. 30). On 15 January 
2024, the Kúria issued a press statement clarifying that the cited judgment of the Court of Justice does not 
affect  the  obligation  of  Kúria  chambers  to  request  a  uniformity  decision  that  is  capable  of  removing  the 
binding effect of the Kúria’s published case-law which is no longer compatible with EU law. 

23   2023 Rule of Law Report, Country Chapter on the rule of law situation in Hungary, p. 2. 

7 

 
 
amended  by  court  presidents.  Judicial  councils  have  no  meaningful  role  in  the  process  and 
parties to court proceedings cannot verify the proper application of the schemes or whether 
there was  a derogation from them24. The applicable rules have not been amended and there 
are  no  plans  yet  to  do  so25.  Therefore,  there  has  been  no  progress  on  the  recommendation 
made in the 2023 Rule of Law Report. 

While the new legal framework aims at limiting the risk of arbitrary decisions about the 
career of judges, no further steps were taken to address concerns raised by the National 
Judicial  Council.  In July and September 2023, the National Judicial Council found that in 
2022  the  NOJ  President  and  the  Kúria  President  had  respected  applicable  rules  when 
appointing  judges  to  the  bench26.  There  are  however  no  legislative  plans  to  address  the 
concerns expressed by the National Judicial Council as regards the practice of the appointing 
authority  when  deciding  in  a  single  batch  on  multiple  applications  for  multiple  judicial 
posts27. In the National Anti-Corruption Strategy, the Government called on the Minister of 
Justice  to  review  the  current  point  system  applicable  to  the  evaluation  of  applications  for 
judicial  posts,  which  stakeholders  consider  to  favour  candidates  coming  from  public 
administration over  candidates from within the judiciary28. No follow-up  has been given to 
the draft legislative proposal prepared by the NOJ President to amend the rules related to the 
assessment of the suitability  for judicial tenure of judges appointed  for an initial  three-year 
period. This proposal would move forward their evaluation in view of a proposal for judicial 
tenure, thereby allowing for any judicial review of their evaluation to be completed before the 
end  of  their  fixed-term  appointment29.  When  recommending  the  appointment  of  the  Kúria 

24   2023  Rule  of  Law  Report,  Country  Chapter  on  the  rule  of  law  situation  in  Hungary,  p.  6.  According  to 
stakeholders there is still too much room for deviation from the general rules on case allocation (contribution 
from  Eötvös  Károly  Policy  Institute  for  the  2024  Rule  of  Law  Report,  p.  15;  information  received  in  the 
context of the country visit to Hungary from the National Judicial Council) and court presidents can freely 
reshuffle or dissolve chambers of judges (joint contribution from Amnesty International Hungary and eight 
other CSOs for the 2024 Rule of Law Report, p. 11). 

25   Input  from  Hungary  for  the  2024  Rule  of  Law  Report,  p.  3. According  to  the  Government,  a  pre-defined 
system  for  the  allocation  of  cases  ensures  that  the  allocation  of  cases  is  independent  from  the  court 
executives’ ad hoc or subjective decision. Based on such system, both the judges and the clients can establish 
why  a  case  was  assigned  to  a  specific  judge/panel.  According  to  stakeholders,  the  new  rules  on  case 
allocation  applicable  to  the  Kúria  could  be  applied  to  other  courts  as  well  (information  received  in  the 
context of the country visit to Hungary from the Hungarian Association of Judges). 
26   Decisions 64/2023 of 5 July 2023 and 81/2023 of 7 September 2023, respectively.  
27   According to stakeholders, in the absence of legislative amendments, this loophole allows the circumvention 
of the merit-based appointment system (contribution from European Association of Judges for the 2024 Rule 
of Law Report, p. 6; contribution from Eötvös Károly Policy Institute for the 2024 Rule of Law Report, p. 
11).  See  2023  Rule  of  Law  Report,  Country  Chapter  on  the  rule  of  law  situation  in  Hungary,  p.  4. 
Stakeholders  pointed  out  that  in  the  absence  of  legislative  amendments,  this  loophole  is  still  available  to 
circumvent  the  Council’s  right  to  veto  and  undermine  the  meritocratic  appointment  system  (information 
received  in  the  context  of  the  country  visit  to  Hungary  from  Hungarian  Helsinki  Committee).  The 
Government has no plans to propose legislative amendments in that respect (written contribution from the 
authorities in the context of the country visit to Hungary). 

28   Contribution from Amnesty International Hungary and eight other CSOs for the 2024 Rule of Law Report, p. 
4;  contribution  from  Eötvös  Károly  Policy  Institute  for  the  2024  Rule  of  Law  Report,  p.  11;  information 
received  in  the  context  of  the  country  visit  to  Hungary  from  the  Hungarian  Association  of  Judges.  The 
National Judicial Council adopted a detailed proposal to change the point system (Decision 125/2023 of 6 
December 2023). The Ministry of Justice has no plans to review the point system (written contribution from 
the authorities in the context of the country visit to Hungary). 

29   The  draft legislative proposal does not include provisions preventing the interruption of the judicial career 
during  the  review  of  the  evaluation,  raising  some  concerns  as  regards  effective  judicial  protection  of  the 

8 

 
 
 
Vice Presidents, the Kúria President is not bound by the ranking established by the full court, 
while  the  National  Judicial  Council  gives  a  binding  opinion  as  to  the  suitability  of  the 
candidates. On 13 June 2024, the Council of Europe’s Committee of Ministers reiterated its 
request  to  the  Hungarian  authorities  to  step  up  their  efforts  to  find  ways  to  introduce  the 
required measures to ensure that a decision to remove the President of the Kúria is subjected 
to effective oversight by an independent judicial body30.  

The freedom of expression of judges remains under pressure.  Smear  campaigns against 
judges  continue  in  the media31.  Also,  the  February  2024  decision  of  the  Kúria  President  to 
suspend the publication of the Kúria’s official court reports was criticized by stakeholders32. 
As regards the effect of the violations in the Baka case33 on the freedom of judges to express 
their  views  on  matters  of  public  interest  concerning  the  judiciary,  on  13  June  2024,  the 
Council  of  Europe’s  Committee  of  Ministers  reiterated  serious  concern  that  the  Hungarian 
authorities  had  not  produced  their  announced  evaluation  of  the  domestic  legislation  on  the 
status of judges and the administration of courts34. 

The  structure  of  the  prosecution  service  remains  unchanged  and  risks  of  undue 
interference  with  individual  cases  remain.  The  2023  and  previous  Rule  of  Law  Reports 
noted  that  the  strictly  hierarchical  architecture  of  the  prosecution  service  and  a  lack  of 
internal  checks  and  balances  enhance  the  persistent  risk  of  top  prosecutors  influencing  the 
work  of  subordinate  prosecutors,  including  in  individual  cases35.  Hungary  has  not 
implemented GRECO’s recommendation to review the possibility to maintain the Prosecutor 
General in office after the expiry of his/her mandate by a minority blocking of the election in 
Parliament  of  a  successor36.  A  new  law37  will  allow  the  Minister  of  Justice  to  access  the 

judges concerned. See 2023 Rule of Law Report, Country Chapter on the rule of law situation in Hungary, p. 
5. 

30   CM/Del/Dec(2024)1501/H46-15.  See  also  2023  Rule  of  Law  Report,  Country  Chapter  on  the  rule  of  law 

situation in Hungary, p. 7. 

31   On 7 July 2023, government-aligned media released an article claiming that the National Judicial Council 
should be abolished for being biased. On 5 October 2023, another smear article claimed that members of the 
Council are ‘service staff of the empire’ (hinting at the United States). On 20 February 2024, the National 
Judicial  Council,  the  NOJ  President,  the  Kúria  and  the  prosecution  service  issued  open  letters  rejecting 
statements  by  an  opposition  party  calling  for  the  ‘listing’  of  judges  and  prosecutors  involved  in  criminal 
proceedings  against  members  of  Parliament.  On  20  March  2024,  government-aligned  media  released  an 
article falsly ‘accusing’ the former president of the National Judicial Council of having terminated the pre-
trial arrest of a person charged with possessing child pornography. 

32   Statements of the Hungarian Association of Judges (23 February 2024) and of the National Judicial Council 
(27  February  2024). According  to  stakeholders,  this  measure  could  have  a  chilling  effect  on  judges  with 
consequences for the content of their decisions. According to the Government, following the completion of 
the internal investigation deemed necessary to clarify the editing principles, the Kúria President terminated 
the suspension still in February 2024. 

33   Judgment of the European Court of Human Rights of 23 June 2016,  Baka v Hungary, 20261/12. The Court 
found that the impugned measures had a ‘chilling effect’, discouraging not only the applicant, but also ‘other 
judges  and  court  presidents  […]  from  participating  in  public  debate  on  […]  issues  concerning  the 
independence of the judiciary’ (§ 173). 

34   CM/Del/Dec(2024)1501/H46-15. 
35   2023  Rule  of  Law  Report,  Country  Chapter  on  the  rule  of  law  situation  in  Hungary,  p.  8.  See  pillar  II  as 
regards the possibility of judicial review of prosecutorial decisions not to open or to close an investigation in 
corruption-related cases. 

36   GRECO Fourth Evaluation Round – Fourth Interim Compliance Report (9 June 2023), p. 9, paras. 54 et seq. 
37   Section 58 of Act XVII of 2024 adding Section 37/A to Act CLXIII of 2011 on the prosecution service. 

9 

 
 
pseudonymised version of all final decisions of the prosecution service and all other decisions 
(e.g. those of the investigating authorities) reviewed by the prosecution service.  

Quality  

Digitalisation of the justice system continues to be overall high while further investment 
remains  necessary.  Hungary  continues  to  rank  very  high  in  terms  of  digital  solutions 
allowing  participation  in  court  proceedings  and  online  access  to  published  judgments38. 
However,  the  installation  of  necessary  new  terminals  for  hearings  taking  place  via 
videoconference  has  not  continued,  even  though  judges  increasingly  schedule  such 
hearings39.  Stakeholders  report  that  no  new  tools  or  technologies  (e.g.  speech-to-text 
applications)  have  been  introduced  to  counterbalance  the  shortage  of  court  staff  and  that 
outdated devices (such as laptops) are rarely being replaced40. 

The  National  Judicial  Council  has  made  a  new  legislative  proposal  to  the  Ministry  of 
Justice  to  increase  judicial  salaries  and  ensure  automatic  indexation,  considering  that 
the level of remuneration of judges and court staff has further deteriorated due to high 
inflation.  As noted in  the 2023 Rule of Law Report41, the Government  has  not  yet  taken a 
decision to increase the real value of judicial salaries. The salaries for judges, prosecutors, as 
well  as  court  and  prosecutorial  staff  were  last  increased  in  January  202242;  since  then, 
inflation  has  exceeded  37%43.  Junior  judges  perceive  the  attractiveness  of  their  salaries  as 
low,  with  reports  of  related  resignations  shortly  after  hiring44.  This  negatively  impacts  the 
capacity of the judiciary to recruit and retain competent staff. Salaries for court staff barely 
reach  the  minimum  wage  and  do  not  substantially  increase  for  staff  with  significant  work 
experience45. The number of judges further decreased in 2023, and the number of applicants 

38   See Figures 46 to 48, 2024 EU Justice Scoreboard.  
39   Contribution from the Hungarian Association of Judges for the 2024 Rule of Law Report, p. 17.  
40   Contribution from Magistrats Européens pour la Démocratie et Libertés (MEDEL) for the 2024 Rule of Law 
Report, p. 16. The overall budget allocated to courts has decreased from 2023 to 2024 by 3%, from around 
HUF 160.38 billion (EUR 405 583 795) in 2023 to around HUF 155.66 billion (EUR 393 647 422) in 2024. 

41   2023 Rule of Law Report, Country Chapter on the rule of law situation in Hungary, p. 9. 
42   Between 2020 and 2022, judicial salaries were increased in three stages, with an overall increase of around 

60 %. 

43   Since  1  January  2022,  the  statutory  salary  base  of  judges  and  prosecutors  has  been  HUF  566 660  (EUR 
1 433). Judicial salaries are calculated by appying to the salary base various multiplying factors determined 
by law. Inflation stood at 15.3% in 2022, 17% in 2023 and is expected to stand at 4.5% in 2024, which poses 
a  general  challenge  for  public  administration.  The  European  Association  of  Judges  ‘[c]onsiders  that  the 
current  levels  and  conditions  of  remuneration  of  judges  in  Hungary  is  contrary  to  European  and  other 
international standards and is not compatible with the requirements established by decisions of the Court of 
Justice  of  the  European  Union’  (European  Association  of  Judges  (2024),  Resolution  on  Judicial 
Remuneration in Hungary). 

44   Information  received  in  the  context  of  the  country  visit  to  Hungary  from  Buda  Central  District  Court; 
contribution from Res Iudicata Association for the 2024 Rule of Law Report, p. 14. Junior judges (‘bírósági 
titkárok’) (‘legal secretaries’ in  RRP milestone 169) are  court staff having passed the bar examination  and 
tasked with certain judicial functions determined in the case allocation scheme. 

45   Several  courts  struggle  to  fill  vacancies  (contribution  from  Res  Iudicata Association  for  the  2024  Rule  of 
Law Report, p. 14). Many staff members are leaving the court, especially in the central region, because of 
the  extreme  low  salary,  the  increasing  workload  and  the  tense  atmosphere  (contribution  from  Magistrats 
Européens pour la Démocratie et Libertés (MEDEL) for the 2024 Rule of Law Report, p. 16). The salary of 
court  staff  consists  of  a  basic  salary  (calculated  on  basis  of  judicial  salary  base)  to  which  various 
supplements can be added. From 1 December 2023, the basic salary was at least gross HUF 266 800 (EUR 
675) or HUF 326 000 (EUR 824) if the post requires secondary education. For a staff member with 35 years 

10 

 
 
 
for initial positions does not always allow to fill all vacancies46. To address the situation, on 
26  February  2024,  the  National  Judicial  Council  made  a  new  legislative  proposal  on  the 
increase and automatic indexation of judicial salaries, which is currently being considered by 
the Ministry of Justice47. 

Concerns  remain as regards the effectiveness  of the legal  aid scheme in both civil and 
criminal cases. The eligibility threshold for legal aid in civil procedure is high48 leading, in 
general, to concerns as regards the inclusiveness of the legal aid scheme49. Fees for defence 
lawyers  under  the  legal  aid  scheme  are  regarded  as  critically  low50,  impacting  access  to 
justice  and  the  right  to  a  fair  trial.  Also,  as  reported  last  year,  access  to  justice  could  be 
improved  through  specific  arrangements  for  persons  at  risk  of  discrimination,  for  elderly 
persons and for women victims of violence51. 

Efficiency 

The efficiency of the judiciary in civil, commercial and administrative cases continues to 
remain  high52. As  in  previous  years,  Hungary  performs  very  well  as  regards  the  estimated 
time needed to resolve litigious civil and commercial cases at all court instances, as well as 
administrative  cases  at  all  court  instances53. According  to  the  Government,  the  backlog  of 
cases  has  been  reduced  further54.  Cases  with  lengthy  proceedings  cluster  in  courts  in  the 
central region around Budapest55, where the overall caseload tends to be higher. 

of experience, the net salary is around HUF 270 000 (EUR 683) (contribution from Amnesty International 
Hungary and eight other CSOs for the 2024 Rule of Law Report, p. 24).  

46   Contribution  from  the  Hungarian Association  of  Judges  for  the  2024  Rule  of  Law  Report,  p.  17.  For  35 
trainee positions nationwide in 2023, only 43 applicants applied, of which 35 passed the entrance exam and 
only 24 positions were filled.  

47   Information  received  in  the  context  of  the  country  visit  to  Hungary  from  the  Government.  The  National 
Judicial  Council  proposed  to  raise  the  salary  base  for  judges  by  35%  as  of  1  January  2024,  to  introduce 
automatic indexation of the salary base as of 1 March 2025 and to raise as of 1 January 2025 the special duty 
allowance  payable  to  judges  working  at  lower-level  courts.  In  the  budget  planning  period,  the  Kúria 
President  indicated  the  need  for  an  inflation-linked  salary  increase  for  judges  and  court  staff  (written 
contribution from the Kúria in the context of the country visit to Hungary). 
48   Contribution by Amnesty International for the 2024 Rule of Law Report, p. 23.  
49   Contribution by Amnesty International for the  2024 Rule of Law  Report,  p. 23, see also the 2023 Rule of 

Law Report, Country Chapter on the rule of law situation in Hungary, p. 9. 

50   Contribution  from  the  Hungarian Association  of  Judges  for  the  2024  Rule  of  Law  Report,  p. 17.  See  also 

Figure 24, 2024 EU Justice Scoreboard. 

51   See  2023  Rule  of  Law  Report,  Country  Chapter  on  the  rule  of  law  situation  in  Hungary,  p. 9.  In  its  2023 
concluding  observations  on  Hungary,  the  UN  Committee  on  the  Elimination  of  Discrimination  against 
Women  noted  with  concern  persistent  barriers  to  women’s  and  girls’  access  to  justice,  in  particular  for 
women  and  girls  facing  intersecting  forms  of  discrimination  who  have  limited  access  to  justice  owing  to 
social  stigma,  the  inaccessibility  of  the  judicial  system  and  gender  bias  among  law  enforcement  officers, 
including the police (contribution from UN Human Rights Regional Office for Europe for the 2024 Rule of 
Law Report, p. 45). 

52   Figures 5 to 11, 2024 EU Justice Scoreboard and 2023 Rule of Law Report, Country Chapter on the rule of 

law situation in Hungary, p. 9.  

53   Figures 7 and 8, 2024 EU Justice Scoreboard.  
54   Contribution by the Hungarian government for the 2024 Rule of Law Report, p. 7.  
55   For  example,  in  the  Criminal  Department  of  the  Budapest  Regional  Court,  the  rate  of  proceedings  with 
length of more than two years has increased from 10 % to 35 % in five years (contribution from Res Iudicata 
Association for the 2024 Rule of Law Report, p. 16). 

11 

 
 
There  were  no  further  developments  regarding  a  compensation  scheme  for  cases 
involving  protracted  administrative  and  criminal  proceedings.  The  2021  Act  on 
pecuniary  compensation  for  delay  in  civil  proceedings56  guarantees  in  principle  genuine 
redress for violations of Article 6 of the European Convention on Human Rights. However, 
the law does not cover non-contentious civil proceedings, such as enforcement proceedings57, 
administrative and criminal cases. On 13 June 2024, the Council of Europe’s Committee of 
Ministers ‘noted with grave concern the continued absence of a reaction to the Committee’s 
decisions  regarding  the  outstanding  criminal,  administrative,  and  non-contentious  civil 
compensatory remedies’58. According to stakeholders, the protraction of court proceedings in 
certain high-profile criminal cases is imputable to malfunctions of court administration59. 

II. 

ANTI-CORRUPTION FRAMEWORK  

The  Ministry  of  Interior  is  responsible  for  the  overall  coordination  of  the  anti-corruption 
policy  and  oversight  over  the  National  Protective  Service60.  As  a  law  enforcement  agency, 
the National Protective Service is still in charge of crime prevention and detection, lifestyle 
monitoring  and  integrity  testing  for  staff  subordinated  to  the  Ministry  of  Interior61.  The 
Constitution Protection Office, a national  security agency overseen by the Prime Minister’s 
Cabinet Office, is empowered to carry out integrity tests for all other public officials62. The 
Integrity  Authority  is  an  independent  authority  set  up  based  on  the  commitments  under  the 
conditionality  procedure  and  the  Recovery  and  Resilience  Plan  to  enhance  oversight  over 
public spending with a focus on EU funds63. Similarly, the Anti-Corruption Task Force was 
set  up  to  examine  existing  anti-corruption  policies  and  to  elaborate  new  proposals64.  The 

56   Act XCIV of 2021. 
57   Joint  contribution  from Amnesty  International  Hungary  and  eight  other  CSOs  for  the  2024  Rule  of  Law 
Report,  p.  28.  The  sanction  regime  for  non-execution  of  court  decisions  in  press  rectification,  personality 
rights  and  freedom  of  information  cases  lacks  dissuasive  effect,  leading  to  excessively  long  enforcement 
proceedings (contribution from Hungarian Helsinki Committee for the 2024 Rule of Law Report, p. 44). 
58   Interim Resolution CM/ResDH(2024)119. See also joint contribution from Amnesty International Hungary 

and eight other CSOs for the 2024 Rule of Law Report, p. 28.  

59   Contribution from Transparency International Hungary for the 2024 Rule of Law Report, p. 12. In particular, 
certain cases have been pending before the first-instance courts for years because they have been re-started 
more than once following changes in the composition of the bench. The protraction of criminal proceedings 
imputable to the authorities may lead to a more lenient criminal sanction. 

60   A  department  of  the  National  Protective  Service  is  entrusted  with  corruption  prevention  tasks,  including 
intra-governmental  cooperation  and  evaluation  of  the 2020-2022  anti-corruption  strategy and  action  plans. 
Since 1 January 2021, the Service has been in charge of corruption prevention in the health care and, since 1 
July 2020, the public education sectors. 

61   Following April 2022, the competence of the National Protective Service was reduced to a significant extent; 

for more information see further below in this text on integrity tests. 

62   Act IV of 2022 amending certain Acts related to Act II of 2022 on the list of Ministries of Hungary. Since 25 
May 2022, corruption prevention in the National Tax and Customs Administration is under the competence 
of the Constitution Protection Office (input from Hungary for the 2023 Rule of Law Report, p. 19).  

63   Setting  up  the  Integrity  Authority  is  a  commitment  under  the  conditionality  procedure  (corresponding  to 
RRP  milestone  160).  In  this  context,  a  new  internal  audit  directorate  has  also  been  set  up  within  the 
government body coordinating EU funds to strengthen internal controls to prevent the misuse of EU funds 
(RRP  milestone  224).  The  Directorate-General  for  Auditing  European  Funds  has  been  transformed  in  an 
autonomous body from the Ministry of Finance (RRP milestone 225). 

64   Setting  up  the  Task  Force  is  a  commitment  under  the  conditionality  procedure  (corresponding  to  RRP 
milestone 166). The Task Force is mandated to examine existing anti-corruption measures and to elaborate 
proposals  to  enhance  the  detection,  investigation,  prosecution  and  sanctioning  of  corrupt  practices.  It 
includes an even number of government and non-governmental members. Delegate members who participate 

12 

 
 
 
State Audit Office contributes to corruption prevention with its competences for the audit of 
the  financial  management  of  public  funds,  the  monitoring  of  state-owned  companies’ 
compliance with statutory public disclosure obligations, as well as political party finance and 
campaign finance audits. As to the repression of corruption, the police can investigate private 
sector corruption and corruption-related economic crimes. The investigation and prosecution 
of  corruption  in  the  public  sector  fall  under  the  exclusive  competence  of  the  Central  Chief 
Investigating  Prosecution  Office  and  its  six  regional  offices65.  The  prosecution  service 
oversees  investigations  and  is  supported  by  the  investigative  forces  of  the  police  and  the 
National Protective Service. 

The perception among experts and business executives is that the level of corruption in 
the public sector remains high. In the 2023 Corruption Perceptions Index by Transparency 
International,  Hungary  scores  42/100  and  ranks  27th  in  the  EU  and  76th  globally66.  This 
perception  has  been  relatively  stable  over  the  past  five  years67.  The  2024  Special 
Eurobarometer on Corruption shows that 88% of respondents consider corruption widespread 
in  their  country  (EU  average  68%)  and  24%  of  respondents  feel  personally  affected  by 
corruption in their daily lives (EU average 27%)68. As regards businesses, 78% of companies 
consider that corruption is widespread (EU average 65%) and 41% consider that corruption is 
a problem when doing business (EU average 36%)69. Furthermore, 40% of respondents find 
that  there  are  enough  successful  prosecutions  to  deter  people  from  corrupt  practices  (EU 
average  32%)70,  while  25%  of  companies  believe  that  people  and  businesses  caught  for 
bribing a senior official are appropriately punished (EU average 31%)71.  

While  the  implementation  of  some  remedial  measures  put  forward  in  response  to  the 
EU  conditionality  procedure  is  ongoing,  important  shortcomings  remain  and  no  new 
measures  were  adopted  to  remedy  the  outstanding  concerns.  To  protect  the  EU  budget 
against corruption and systemic rule of law issues, on 15 December 2022 the Council, on a 

in the Task Force meetings, but do not have a voting right, include the State Audit Office, the Competition 
Authority, the Public Procurement Authority, the Authority for the Supervision of Regulated Activities, the 
National Office for the Judiciary and the prosecution service. Other relevant actors, such as the Government 
Control Office, the National Data Protection and Freedom of Information Authority, the  Commissioner for 
Fundamental Rights and the Hungarian National Bank, are so far not participating in the work of the Task 
Force.  

65   As of 1 November 2023, the Budapest Investigating Prosecutor’s Office, previously under the control of the 
Budapest  Prosecutor’s  Office,  was  integrated  into  the  regional  investigative  bodies  of  the  Central  Chief 
Investigating Prosecution Office. The primary objective of the change was to address workload imbalances 
and the burden of the regional investigating prosecution offices. 

66   Transparency International (2024), Corruption Perceptions Index 2023. The level of perceived corruption is 
categorised  as  follows:  low  (the  perception  among  experts  and  business  executives  of  public  sector 
corruption scores above 79); relatively low (scores between 79-60), relatively high (scores between 59-50), 
high (scores below 50). 

67   In 2019, the score was 44, while, in 2023, the score is 42. The score significantly increases/decreases when it 
changes more than five points; improves/deteriorates (changes between 4-5 points) and is relatively stable 
(changes from 1-3 points) in the last five years. 

68   Special Eurobarometer 548 on Corruption (2024). The Eurobarometer data on citizens’ corruption perception 

and experience is updated every year. The previous data set is the Special Eurobarometer 534 (2023). 

69   Flash Eurobarometer 543 on Businesses’ attitudes towards corruption in the EU (2024). The Eurobarometer 
data  on  business  attitudes  towards  corruption  as  is  updated  every  year.  The  previous  data  set  is  the  Flash 
Eurobarometer 524 (2023). 

70  Special Eurobarometer 548 on Corruption (2024).  
71   Flash Eurobarometer 543 on Businesses’ attitudes towards corruption in the EU (2024).  

13 

 
 
proposal  from  the  Commission,  temporarily  suspended  EU  funds  under  several  EU 
programmes72  and  prohibited  entering  into  new  legal  commitments  with  public  interest 
trusts73,  until  further  reforms  are  introduced.  Pursuant  to  the  procedure  set  out  in  the 
Conditionality Regulation74, Hungary may any time notify remedial measures to demonstrate 
that the relevant breaches of the principles of the rule of law and/or their effects or risks for 
the Union budget and the Union’s financial interests have been removed. In the absence of a 
written  notification  from  Hungary,  the  Commission  reassessed  on  its  own  motion  the 
situation  in  Hungary  based  on  the  information  available.  On  13  December  2023,  the 
Commission considered that the situation that had led the Council to adopt measures had not 
been remedied and that the Union’s budget remained at the same level of risk as established 
by the Council on 15 December 2022. In its assessment, the Commission listed a number of 
issues that are still outstanding, concluding that the measures adopted by the Council should 
remain in place75. Furthermore, no disbursement of funds under the Recovery and Resilience 
Plan can be made to Hungary until all the ‘super milestones’, including those related to the 
key  implementation  steps  of  the  conditionality  procedure,  have  been  satisfactorily 
implemented. 

A  new  National  Anti-Corruption  Strategy  and  Action  Plan  is  now  in  place76.  On  14 
February  2024,  Hungary  adopted  the  medium-term  National  Anti-Corruption  Strategy  for 
2024-2025 and its related Action Plan, applicable as of 15 February 202477. On process, the 
draft had been consulted with some key international stakeholders, but national consultations 
appear to have remained limited78. On substance, the strategic documents envisage measures 
related to new ethical standards for public officials on conflicts of interest, asset declarations, 
and political party financing79. The goal is to put forward a whole-of-society approach in the 
fight against corruption. While this is beneficial, it remains to be seen in the implementation 
if  this  new  strategic  framework  can  effectively  address  systemic  weaknesses  in  public 
institutions and state organs as public service providers. As noted also by the OECD and the 
Council  of  Europe,  a  comprehensive  and  strategic  policy  approach  to  effectively  tackling 
corruption, including high-level corruption, remains missing from the strategy. Most integrity 
and  corruption  prevention  measures  target  low  and  mid-level  officials  and  the  integrity 

72   See, in particular, Article 2(1) of Council Implementing Decision (EU) 2022/2506. 
73   Public  interest  trusts  receive  significant  public  funding  and  have  been  found  to  be  managed  by  board 
members close to the Government (2023 Rule of Law Report, Country Chapter on the rule of law situation 
in  Hungary,  p.  22).  Hungary  has  not  adopted  any  new  remedial  measures  with  a  view  to  addressing  the 
weaknesses in relation to public interest trusts. 

74  Council  Implementing  Decision  (EU)  2022/2506  of  15  December  2022.  Article  7  of  the  Conditionality 
Regulation  provides  for  a  specific  procedure  to  adapt  or  lift  the  measures  adopted  by  the  Council  if  the 
Member State remedies the situation - in part or in full - that had led to the adoption of Council measures.  

75  Commission Decision C(2023) 8999 final of 13 December 2023. 
76   Apart  from  the  new  National  Anti-Corruption  Plan  for  2023-2025,  a  separate  Anti-Fraud  and  Anti-
Corruption  Strategy  specifically  for  the  protection  of  EU  funds  entered  into  force  in  2022,  which  the 
Government committed to coordinate. See also the commitments under RRP milestones 178, 179, 220, 221. 
77   Government Decision 1025/2024 of 14 February 2024 on the adoption of the medium-term National Anti-
Corruption Strategy for 2024-2025. The draft strategy was prepared by the National Protective Service.  
78   The  draft  was  consulted  with  the  European  Commission,  the  OECD,  the  Council  of  Europe,  the  national 
Anti-Corruption Task Force and a few selected national stakeholders. On 13 June 2023, the Anti-Corruption 
Task  Force  adopted  an  opinion  on  the  draft  strategy  (Anti-Corruption  Task  Force  (2023),  Complementary 
Report on the draft medium-term National Anti-Corruption Strategy for 2023-2025). On 16 October 2023, 
the  Minister  of  Interior  sent  a  letter  explaining  why  the  Government  did  not  to  take  up  certain  proposals 
(Minister of Interior (2023), Letter to the chairperson of the Anti-Corruption Task Force). 

79   For more details on lobbying, revolving doors and political party finance, see further below in this text. 

14 

 
 
framework applicable to persons with top executive functions remains weak80. As regards the 
governance  framework,  the  Anti-Corruption  Task  Force  is  tasked  to  help  evaluate  the 
progress as regards the implementation of the Action Plan81. A final government assessment 
report of the level of implementation to be prepared by the Ministry of Interior is planned for 
202682.  

The  Integrity  Authority  reports  certain  obstacles  to  fulfilling  its  oversight  tasks 
effectively,  and  the  impact  in  practice  of  the  proposals  made  by  the  Anti-Corruption 
Task Force remains to be seen. Largely, the Integrity Authority seems to have the adequate 
capacity and the necessary level of independence to carry out its work83. It referred two cases 
to  the  prosecution  service  in  2023,  one  following  a  whistle-blower  report  and  the  other 
identified  through  its  own  risk  assessment84.  On  29  June  2023,  the  Integrity  Authority 
published  its  first  annual  analytical  integrity  report  covering  202285,  and  on  14  December 
2023  its  position86  on  the  Government’s  reply  to  the  report87.  The  Government  responded 
positively  to  about  a  quarter  of  the  recommendations  issued  by  the  Integrity  Authority, 
committing to take further action88. In practice, some obstacles remain, particularly where the 
Authority needs to rely on cooperation with other public bodies89. In addition, the Authority 

80   OECD  (2023),  A  strategic  approach  to  public  integrity  in  Hungary:  The  2023-2025  National  Anti-
Corruption Strategy and Action Plan; Council of Europe (2023),  Hungary: anti-corruption group calls for 
measures to prevent corruption in central government and law enforcement. 

81   This requires measurable progress and impact indicators and a sufficiently high level of transparency. The 
strategy  does  not  contain  a  plan  for  communications  to  internal  and  external  stakeholders  about  its 
implementation, as also highlighted by the OECD (OECD (2023), A strategic approach to public integrity in 
Hungary:  The  2023-2025  National  Anti-Corruption  Strategy  and  Action  Plan,  p.  8).  Stakeholders  have 
criticized the implementation of the previous strategy for not being done transparently (information received 
in the context of the country visit to Hungary from K-Monitor and Transparency International Hungary). See 
also  2023  and  2021  Rule  of  Law  Report,  Country  Chapter  on  the  rule  of  law  situation  in  Hungary,  p.  10 
(2023), p. 11 (2021).  

82   This would be in the first quarter of the year 2026, see RRP milestone 179. 
83   Information received from the Integrity Authority in the context of the country visit to Hungary. 
84   Written  contribution  from  the  Integrity Authority  in  the  context  of  the  country  visit  to  Hungary. Also,  the 
Authority initiated proceedings in two cases and submitted one administrative appeal against a decision of 
the  Public  Procurement  Arbitration  Board;  it  notified  the  Hungarian  Competition  Authority  in  one  case, 
which  led  to  the  opening  of a  competition  procedure;  and  requested  the  designated  managing  authority  to 
initiate an irregularity procedure in two cases. 

85   Integrity Authority (2023), Annual Analytical Report, (29 June 2023). 
86   Integrity Authority  (2023),  The  position  of  the  Integrity Authority  regarding  the  Government’s  answer  (14 

December 2023).  

87   Hungarian  Government  (2023),  The  Government’s  positions  as  regards  the  findings  of  the  Integrity 

Authority’s 2022 annual analytical integrity report.  

88   Out  of  49  recommendations,  the  Government  fully  agreed  to  take  action  in  about  one  dozen  (13)  and 
disagreed with 21 recommendations, while no action will be taken with regard to 5 other recommendations, 
where the Government does not see a need to act or takes only note. Pursuant to Section 13 of Act XXVII of 
2022,  the  Government  is  not  required  to  agree  with  all  of  the  recommendations,  but  it  must  reply  to  the 
Integrity  Authority  and  explain  how  it  will  address  the  findings  made  in  the  annual  analytical  integrity 
report. 

89   Information  received  from  the  Integrity  Authority  in  the  context  of  the  country  visit  to  Hungary.  The 
Authority has established working relations with the relevant authorities and is empowered to act in case of 
detected irregularities affecting EU funds and to initiate proceedings to be conducted by other public bodies, 
such as the Committee of Immunities in the Parliament, the Tax and Customs Administration or the police, 
while  it  cannot  impose  sanctions  itself.  In  addition,  to  enhance  cooperation  with  other  public  bodies,  the 
Integrity  Authority  proposed  to  amend  and  mirror  the  powers  it  has  under  the  Act  XXVII  of  2022 
establishing the Integrity Authority also in sectoral laws. 

15 

 
 
reported that it does not have direct access to all the data registers containing information that 
may be needed for it to carry out its tasks90 and in certain cases no such data is available91. To 
enhance  cooperation  with  other  public  bodies  that  it  heavily  relies  upon,  the  Integrity 
Authority  has  proposed  to  the  Government  to  mirror  its  powers92  also  in  sectoral  laws93. 
Stakeholders  also  highlighted  the  need  for  a  strategy  for  the  Authority,  including  the 
definition of criteria for the selection of cases for investigation94. The Anti-Corruption Task 
Force,  created  to  support  the  Government’s  overall  anti-corruption  policy  coordination, 
adopted its second annual report95. Non-governmental members of the Task Force expressed 
concerns as regards its capacities96, scope and the Government’s limited uptake of proposals 
and questioned the Task Force’s meaningful impact in practice97.  

The possibility of judicial review has reportedly led the prosecution service to assess the 
follow-up  on  crime  reports  more  thoroughly,  even  though  court  decisions  overturning 
prosecutorial  decisions  remain  non-binding98.  A  year  after  its  introduction,  Hungary  has 
started  the  revision  of  the  possibility  for  a  judge  to  review  prosecutorial  and  investigative 
authorities’  decisions  not  to  investigate  reported  corruption  suspicions  or  to  terminate 
ongoing  corruption  investigations  without  indictment99,  which  has  been  in  force  since  1 

90   E.g.  the  central  register  on  beneficial  ownership  managed  by  the Tax  and  Customs Administration,  where 
data can only be provided upon targeted request. Overall, the Integrity Authority reports that, where there is 
no  direct  access,  the  requested  data  received  from  other  institutions  and  entities  is  at  times  fragmented, 
partially  incomplete,  and  often  unchecked.  Regarding  the  responses  to  data  requests,  the  speed,  ability, 
quality, and usability of the data poses obstacles to the effective operations and fulfilment of the Authority’s 
tasks (Integrity Authority (2023), 2022 Annual Analytical Report, p. 5). The Government reports that work is 
ongoing to allow for direct access, with closer cooperation between the Integrity Authority and the Tax and 
Customs Administration having started in January 2024 (information received in the context of the country 
visit to Hungary from the Ministry of Justice).  

91   The Integrity Authority has no access to beneficial ownership information on private equity funds because, 
in  line  with  national  law  adopted  in  2022,  information  about  the  investors/beneficial  owners  has  been 
removed from the register maintained by the Tax and Customs Administration; the Hungarian National Bank 
only verifies ownership at the moment of the authorisation and registration process but does not record such 
data (written contribution from the Integrity Authority in the context of the country visit to Hungary). 

92   As stipulated in Act XXVII of 2022 establishing the Integrity Authority. Other institutions and entities seem 
to apply only the sectoral legislation regulating their activity which does not refer to the Authority’s direct 
access  to  their  data  bases  or  the  obligation  to  cooperate  with  the  Authority.  This  could  be  solved  by 
‘mirroring’ the relevant provisions of Act XXVII of 2022 in the sectoral legislation concerned. 

93   Integrity Authority (2024), Annual Report to the Hungarian National Assembly 2023, p. 9, including a set of 

recommendations to enhance the protection of the EU budget, p. 11. 

94   Information  received  in  the  context  of  the  country  visit  to  Hungary  from  K-Monitor  and  Transparency 

International Hungary. See also Hadházy, Ákos (2024), Facebook post of 29 January 2024. 

95   The Task Force adopted its annual report covering the year 2023 at its meeting held on 12 March 2024. The 
Government replied on 10 June 2024. According to the Government,  it supported all consensual proposals 
which prescribed tasks for the Government. 

96  Three out of ten non-governmental members had resigned, with Hungary reporting that the remaining two 

vacancies were filled in February 2024. 

97   Three  non-governmental  members  of  the Task  Force  voted  against  the Task  Force’s  second  annual  report. 
See  Task  Force  (2024),  2023  Report  of  the Anti-Corruption  Task  Force;  and  Átlátszó  (2024),  Átlátszó,  K-
Monitor and Transparency have not accepted the annual report of the Anti-Corruption Working Group. The 
Government is not obliged to follow the proposals of the Task Force, but to provide a justification not to do 
so (K-Monitor (2023), Anti-Corruption Task Force: what is the situation eight months after its launch?). See 
also K-Monitor and Transparency International Hungary (2024), Special report on the 2023 Anti-Corruption 
Task Force Report: Current issues in the fight against corruption in Hungary. 

98   Information received in the context of the country visit to Hungary from the prosecution service.  
99   Input from Hungary for the 2024 Rule of Law Report, p. 15. 

16 

 
 
January 2023100. The Prosecutor General has published guidelines, including instructions how 
to  file  a  review  request,  which  stakeholders  have  found  to  be  user-friendly101.  However, 
shortcomings remain in particular as regards the  temporal  scope of the new measure102 and 
the  lack  of  the  binding  nature  of  court  decisions  quashing  the  prosecutor’s  decision  not  to 
prosecute103. Stakeholders  have also  raised concerns  as to  its results  in practice104. Until 29 
February  2024,  74  motions  for  judicial  review  had  been  filed  with  the  competent  Buda 
Central District Court105; most of them were allegations of abuse of office, unrelated to public 
funds106. 

Integrity  tests  and  lifestyle  monitoring  remain  the  main  tools  to  detect  and  deter 
corruption,  although  their  effectiveness  is  limited  in  detecting  high-level  corruption. 
Also in 2023, reliability testing through integrity surveillance and testing of public officials 
was  reported  to  be  the  primary  tool  used  to  detect  corruption  in  the  public  sector107.  In 
practice,  this  has  been  effective  primarily  for  petty  corruption  cases,  such  as  gratitude 
payments  in  healthcare108.  Other  tools  that  could  be  more  effective  in  detecting  a  wider 
variety  of  corruption  cases  (including  high-level  corruption),  such  asset  declarations, 

100  A government assessment report on the functioning of the judicial review planned for the fourth quarter of 
2023 is still pending. The possibility of judicial review was introduced in the Criminal Procedure Code by 
Act XLIV of 2022 to enhance the effective prosecution of corruption by addressing the concerns raised in 
the past as regards the accountability of the prosecution service (see 2022 and 2023 Rule of Law Reports, 
Country Chapter on the rule of law situation in Hungary, pp. 9, 15-16 (for 2022), and p. 13). Anyone can 
request a review and trigger the oversight procedure for any corruption-related cases dismissed or terminated 
after  1  January  2023.  If  the  prosecution  service  does  not  grant  the  request,  the  judge  can  decide  that  an 
investigation  should  take  place  or  should  be  continued  and  send  the  case  back  for  investigation  to  the 
prosecution service. If the prosecution service does not act, the judge informs the person who has requested 
the review that they can represent an indictment before the court. 

101  Information received in the context of the country visit to Hungary from K-Monitor.  
102  The  new  law  does  not  clarify  the  scope  of  application  in  time  of  the  new  rules  and,  in  particular,  fails  to 
clarify  that  the  new  procedure  will  also  apply  to  (non-time-barred)  criminal  offences  committed  before  1 
January 2023. See Council Implementing Decision (EU) 2022/2506 of 15 December 2022, recital 46. 

103  The prosecution service is only obliged to take the court decision into account. See Council Implementing 

Decision (EU) 2022/2506 of 15 December 2022, recital 46. 

104  See for example K-Monitor (2023), Anti-corruption criminal procedure reform: the rules are there, but the 

practice is unchanged (15 December 2023).  

105  Of the 74 motions, the court considered 43motions, rejected 37 and granted a motion for review in 6 cases 
until 29 February 2024. In addition, the court received one repeated motion for reconsideration, which was 
also  dismissed.  Until  1  November  2023,  no  motion  for  prosecution  was  filed,  see  K-Monitor  and 
Transparency International Hungary (2023), Special report on the 2023 Anti-Corruption Task Force: Current 
its  website 
issues 
(https://integritashatosag.hu/ugyek/felulbiralati-inditvanyok/felulbiralati-inditvanyok-2/), 
Integrity 
Authority  has  filed  five  motions  for  revision,  two  of  which  were  successful.  In  one  case,  the  prosecution 
decided to continue the investigation, and in another case, the court overturned the investigative authority’s 
decision to drop the procedure. One of the motions has been rejected by the Buda Central District Court. The 
Integrity Authority has filed one repeated motion for revision, which is still pending. 

in  Hungary.  According 

corruption 

against 

fight 

the 

the 

to 

in 

106  Information received in the context of the country visit to Hungary from the prosecution service. 
107  Information received in the context of the country visit to Hungary from the prosecution service.  
108  Gratuity payments in the health care sector are reported to be the most serious disturbance and challenges 
that the National Protective Service is in charge of, with a total of 218 cases of corruption and other criminal 
offences in the health sector having been reported or investigations been initiated against 1 354 persons in 
the  course  of  2023  (input  from  Hungary  for  the  2024  Rule  of  Law  Report,  p.  12).  In  its  RRP,  Hungary 
committed to implement an awareness-raising campaign against gratuity payments (RRP milestones 182-183 
and target 184). 

17 

 
 
whistleblower  disclosures  and  registers109,  continue  to  play  a  relatively  minor  role  in 
corruption  investigations110.  The  National  Protective  Service  continues  to  be  considered 
indispensable  to  gather  evidence  essential  for  initiating  corruption  investigations  and 
prosecutions111. It is tasked with carrying out integrity tests and lifestyle monitoring for staff 
subordinated  to  the  Ministry  of  Interior  and  other  public  administrative  bodies112.  For  the 
integrity testing of all other public officials conducted by the Constitution Protection Office, 
risks to the transparency of such proceedings, as previously reported, has materialised in the 
reporting  period113.  Information  or  data  about  reliability  testing,  including  numbers  of 
corruption suspicions reported to the prosecution service, is no longer publicly available for 
those  public  officials  who  are  covered  by  the  mandate  of  the  Constitution  Protection 
Office114.  

Whereas the number of convictions for corruption-related crimes has increased in low 
level corruption cases, there has been no progress yet to establish a robust track record 
against  high-level  corruption.  The  2022  and  2023  Rule  of  Law  Reports  recommended  to 
Hungary  to  ‘[e]stablish  a  robust  track  record  of  investigations,  prosecutions,  and  final 
judgments for high-level corruption cases’115. The prosecution service continues to view the 
level  of  cooperation  between  the  relevant  state  entities  combating  corruption,  as  well  as 
human and financial resources, and specialisation as adequate to carry out their tasks116. The 
new  IT  system  for  the  prosecution  service,  planned  to  address  the  persisting  challenge  in 
evidence-gathering and sharing, is still not in place and is now planned to be operational by 

109  The central register for beneficial ownership information managed by the Tax and Customs Administration is 
accessible only to those who have a legitimate interest to the central register. Access has been granted in this 
manner  since  1  July  2022.  Stakeholders  had  warned  in  previous  years  that  excessive  fees  and  too  strict 
accessibility criteria set by the Administration would deter ordinary citizens from using the central database. 
Information  received  in  the  context  of  the  country  visit  to  Hungary  from  K-Monitor  and  Transparency 
International  Hungary.  Transparency  International  recommend  increased  transparency  of  private  equity 
funds,  which  play  a  role  in  hiding  ill-gotten  gains  from  corruption  (Transparency  International  (2022), 
Exporting Corruption, p. 52). The EU legislation on anti-money laundering and counter terrorist financing 
imposes  obligations on  all  Member  States  to  identify  the  ultimate  beneficial  owner.  Beneficial  owners  are 
individuals who benefit from a company even though they are not formally named as owner of the business. 
110  Information received in the context of the country visit to Hungary from  the prosecution service. See also 
contribution from K-Monitor for the 2022 Rule of Law Report, p. 18. This is the case since 2021 (see 2021 
Rule of Law Report, Country Chapter on the rule of law situation in Hungary, p. 12). 

111  See 2023 Rule of Law Report, Country Chapter on the rule of law situation in Hungary, p. 14.  
112  These  include  employees  of  territorial  government  bodies  and  specialised  territorial  child  protection 

services, as well as the state employed health care staff. 

113  Since the Constitution Protection Office is a national security service, the potential detection of corruption 
by this Office can fall under national security rules and thus remain undisclosed. As a result, the decision not 
to further pursue a corruption investigation is de facto impossible to review, with corruption cases risking not 
to be pursued. See also 2023 Rule of Law Report, Country chapter on the rule of law situation in Hungary, p. 
14 with further stakeholder references. Other than for the National Protective  Service, no data on detected 
corruption cases was shared or is available from the Constitution Protection Office. 

114  The Constitution Protection Office, overseen by the Prime Minister’s Cabinet Office, performs the integrity 
tests  of  the  officials  and  employees  of  governmental  bodies  (e.g.  ministries),  with  the  exception  of  the 
military  and  the  officials  and  employees  of  governmental  bodies  (e.g.  the  Police,  the  penitentiary  system) 
and sectors (e.g. healthcare, public education) overseen by the Minister of Interior.  

115  2022 and 2023 Rule of Law Report, Country Chapter on the rule of law situation in Hungary, p. 2.  
116  Information received in the context of the  country visit to Hungary from the prosecution service. See also 

2023 Rule of Law Report, Country Chapter on the rule of law situation in Hungary, p. 15. 

18 

 
 
the end of 2025117. The reported indictment rate for corruption crimes continues to be high, 
according to the prosecution service118, with one new indictment in 2023 also in a complex 
corruption  and  money  laundering  case  against  a  large  number  of  defendants,  including  one 
former high-level official119. In 2023, the prosecution service reported that 364 persons had 
been convicted at a final instance for corruption-related crimes120. However, most cases target 
low  to  mid-tier  officials  while  leaving  out  the  top-level  officials  of  the  country’s  public 
administration,  and  convictions  in  high-level  corruption  cases  continue  to  be  rare121. 
Generally, in complex high-level corruption cases, court proceedings tend to be excessively 
long122.  The  risk  of  undue  interference  with  individual  cases  persists  in  the  prosecution 
service123, while also the police’s operational independence appears to be affected by political 
influence on the prosecution service124. Serious concerns remain therefore about the absence 
of  a  robust  track  record  of  investigations  of  corruption  allegations  concerning  high-level 
officials  and  their  immediate  circle.  Stakeholders  also  continued  to  raise  concerns  about 
clientelism, favouritism and nepotism in high-level public administration and about the risk 
of  impunity  caused  by  a  disparity  in  the  treatment  of  corruption  cases  for  political 

117  Financial  data  relevant  for  investigations  is  spread  over  numerous  separate  state  registers.  The  new  IT 
system for the handling of sensitive documents would facilitate administrative work and data exchange for 
data searches by prosecutors (information received in the context of the country visit to Hungary from the 
prosecution service). It was originally planned to be fully functional and operational by Q2 2024, see 2023 
Rule of Law Report, Country Chapter on the rule of law situation in Hungary, p. 16, and RRP milestone 180. 
Also, a new case management IT system facilitating administrative work and the exchange of non-sensitive 
information is planned to be fully functional and operational by the end of 2025, see RRP milestone 181.  
118  A total of 1 698 procedures registered in police proceedings for corruption crimes were completed, leading 
to indictment (compared to 1 224 in 2022) (input  from Hungary for the 2024 Rule of Law Report, pp. 14-
15). See also European Anti-Fraud Office (OLAF) (2024), Annual Report 2023 for the latest data on judicial 
follow-up by Member States, indicating an indictment rate in Hungary. 

119  Information received in the context of the country visit to Hungary from the prosecution service, referring to 
an  overall  number  of  22  defendants  in  this  case.  Allegations  of  evidence-tampering  by  the  prosecution 
service  upon  Government  instructions  and  the  obstruction  of  justice  by  the  Government  in  this  high-level 
corruption case involving a former state secretary of the Ministry of Justice and the chief bailiff prompted 
the  prosecution  service  to  initiate  investigations  for  failure  to  report  bribery,  see  Reuters  (2024),  Hungary 
prosecutors  probe  graft  case  tape  leaked  by  former  government  insider  and Telex  (2024),  Former  Justice 
Minister’s ex-husband releases recording he claims proof of high-level involvement in corruption case. For 
more details, see Intellinews (2023), Hungary’s highest-profile corruption case lifts the veil on how Orban’s 
regime  really  operates.  See  also  The  Budapest  Times  (2024),  KNYF:  ‘No  documents  disappeared  in  so-
called Volner-Schadl case’. 

120  Input from Hungary for the 2024 Rule of Law Report, pp. 14-15. In 2022, there were 326 final convictions, 

largely for petty corruption cases. 

121  Contribution  from  Democracy  Reporting  International  for  the  2024  Rule  of  Law  Report,  p.  4.  See  also 
Council of Europe (2023), Hungary: anti-corruption group calls for measures to prevent corruption in central 
government and law enforcement. 

122  Transparency International Hungary and K-Monitor (2023), Special report on the 2023 Anti-Corruption Task 
Force: Current issues in the fight against corruption in Hungary. See also 2023 Rule of Law Report, Country 
Chapter on the rule of law situation in Hungary, p. 16 and footnote 104 with further references. 

123  See  in  this  context  Section  I  above,  p.  11.  The  full  implementation  of  the  GRECO  recommendations  as 
regards the effective functioning of the prosecution would further strengthen the anti-corruption framework. 
See GRECO Fourth Evaluation Round – Third Interim Compliance Report (2022), p. 6, paras. 31-35. This 
concerns in particular the limitation of prosecutors’ immunity to functional immunity but also the procedures 
to  lift  parliamentarians’  immunity,  which  risk  hampering  the  timely  evidence-gathering  in  corruption 
investigations against parliamentarians. 

124  GRECO  Fifth  Evaluation  Round  –  Evaluation  Report  (2023),  p.  29,  para.  126,  pointing  at  hierarchical 

pressure on police officers to discontinue investigations in certain sensitive cases. 

19 

 
 
purposes125.  Overall,  considering  the  lack  of  significant  developments126,  no  progress  was 
made on establishing a robust track record to fight high-level corruption, as recommended in 
the previous years. 

Enforcement  against  foreign  bribery  is  still  lacking.  International  recommendations  to 
design a strategy to proactively detect and investigate foreign bribery cases and to provide for 
more time in the application of investigation measures in highly complex multi-jurisdictional 
cases  remain  among  other  recommendations  unfulfilled  since  2012127.  The  Government 
considers  Hungary’s  legislative  framework  appropriate  to  prevent  and  repress  foreign 
bribery, focusing its activity in this area on organising trainings and on creating a framework 
for improving cooperation128. While one conviction is reported129, no new investigations into 
foreign bribery have been initiated during the reporting period130. 

The  legislative  steps  taken  to  facilitate  on-the-spot  checks  conducted  by  the  EU Anti-
Fraud  Office  (OLAF)  for  investigations  involving  EU  funds  have  proven  effective.  In 
2023,  based  on  the  legislation  adopted  in  October  2022131,  OLAF  requested  in  several 
instances the  National Tax and Customs Administration to  secure the presence of  a  finance 
guard  during  OLAF’s  on-the-spot  checks  to  ensure  cooperation  of  the  economic  operator 
subject  to  the  control  and  it  received  the  necessary  support.  Following  allegations  of  a 
corruption ring in managing authorities, more than 50 suspects have been brought before the 
courts  on  bribery  charges  in  connection  with  EU  funds,  including  a  former  deputy  state 
secretary and 25 legal  entities132. Furthermore, the  Integrity Authority conducted successful 

125  Corruption  Research  Center  Budapest  (2023),  Fourteen  Graphs  and  Two  Tables  on  the  New  Trends  of 
Corruption  in  the  Hungarian  Public  Procurement  2005-2022;  information  received  in  the  context  of  the 
country visit to Hungary from Transparency International Hungary, K-Monitor, Corruption Research Center 
Budapest  and  Átlátszó.  There  is  a  prevalence  of  informal  power  networks,  and  centralised  political 
corruption  in  Hungary,  bolstered  by  economic  connections  within  networks  that  revolve  around  a  few 
oligarchs with close political ties, according to Bertelsmann Stiftung (2024), Transformation Index: Hungary 
Country Report.  

126  See above in this Section II on oversight and control mechanisms. 
127  OECD  (2023),  Implementing  the  OECD  Anti-Bribery  Convention,  Phase  4  Evaluation  of  Hungary: 
additional  written  follow-up  report.  See  also  OECD  (2023),  OECD  Working  Group  on  Bribery  public 
statement on Hungary. Transparency International (2022), Exporting Corruption, p. 51, reporting about little 
to  no  enforcement  referencing  that  in  the  period  of  2018-2021,  Hungary  opened  one  investigation, 
commenced no cases and concluded no cases. 

128  See Government Decision 1025/2024 of 14 February 2024. 
129  According  to  information  received  from  the  Government,  in  April  2024,  the  Budapest  Regional  Court 

convicted a defendant for having traded in honorary consular titles of different non-EU countries. 

130  Input from Hungary for the 2024 Rule of Law Report, p. 13. 
131  Act XXIX of 2022 on the control of the use of European Union budget funds, which entered into force on 11 
October  2022.  In  RRP  milestone  226,  Hungary  committed  to  reforms  to  strengthen  the  cooperation  with 
OLAF to reinforce the detection of fraud related to the implementation of Union support. 

132   Prosecution service (2024), Indictment in a case related to tender grants obtained through corruption – with 
video  –  press  release  of  the  Central  Chief  Investigating  Prosecution  Office.  The  case  concerns  108  EU-
funded calls for proposals and a total of HUF 25 bn grant amount sought. See also Magyar Hang (2024),  54 
people indicted in corruption case involving the Ministry of Finance and the Prime Minister’s Office; 24.hu 
(2024),  The  prosecution  service  would  send  to  prison  Mihály  Varga’s  former  deputy  state  secretary  and 
László Palkovics’ confidant; Forbes (2024), Here is another 25 billion forint government corruption scandal: 
dozens of Mihály Varga’s former subordinates are involved. 2023 Rule of Law Report, Country Chapter on 
the rule of law situation in Hungary, p. 18.  

20 

 
 
own-initiative  proceedings  in  at  least  one  case  concerning  budget  fraud,  including  EU 
subsidies, in a case involving a high-level official and his family, finding irregularities133.  

There has been no further progress on lobbying and post-employment regulation, with 
plans to legislate in this area only in 2025. The 2023 Rule of Law Report recommended to 
Hungary to ‘[a]dopt comprehensive reforms on lobbying and revolving doors [...] providing 
for  effective  oversight  and  enforcement’134.  The  new  National  Anti-Corruption  Strategy 
2024-2025  and  Action  Plan  contain  a  commitment  of  the  Government  for  a  legislative 
proposal on lobbying law, including rules on revolving doors, to be prepared by the Ministry 
of Justice by 30 November 2025135. Whether the proposal will provide for the creation of a 
transparency  register  and  a  legislative  footprint  to  disclose  contacts  with  interest 
representatives in  the decision-making process,  which are so  far missing in  Hungary, is  not 
yet  decided136.  In  this  context,  the  Minister  of  Justice  is  tasked  by  Government  decision  to 
evaluate  and  prepare  a  report  on  current  lobbying  practices137. The  Government  committed 
further  to  a  non-binding  Code  of  Conduct  for  persons  with  executive  functions,  including 
contacts  with  lobbyists  and  post-employment  restrictions138.  For  Parliament,  no  steps  have 
been reported  for the establishment of a  clear set of rules on contacts  between members of 
Parliament  and  lobbyists  to  address  concerns  regarding  the  level  of  transparency  in  the 
decision-making  process139.  Thus,  Hungary’s  lobbying  rules  remain  incomplete,  with  no 
systematic follow-up ensured in case of non-compliance140. Post-employment restrictions and 
cooling-off  periods  remain  largely  fragmented141  and  limited  in  personal  scope142.  At  the 
same time, no further steps have been taken to provide for more effective enforcement143. A 
code of ethics for members of Parliament, that would include post-employment guidelines, is 

133  Integrity  Authority  (2024),  Conclusion  of  inquiry  III_86_2023  –  modernisation  of  cattle  farm.  For  more 
details, Telex (2024), The Integrity Authority filed a complaint over the half-billion forint ‘dairy farm’ of the 
family  of  ex-minister  János  Süli.  The  case  was  already  publicly  reported  about  in  2020  (Átlátszó  (2020), 
Corruption  info:  hundreds  of  millions  of  euros  in  EU  funding  for  the  company  of  the  son  of  the  minister 
responsible  for  the  Paks  investment).  See  however  the  post  of  the  National  Assembly  member  Hadházy, 
Ákos (2024), Facebook post of 29 January 2024  on alleged inactivity of the Integrity Authority.  Regarding 
the allegations reported about over the last two years of a corruption ring in  managing authorities linked to 
national and EU funds that raised concerns as to the lack of systemic oversight, see above in this section on 
the track record. 

134  2022 and 2023 Rule of Law Report, Country Chapter on the rule of law situation in Hungary, p. 2.  
135  Government Decision 1025/2024 of 14 February 2024. See also written contribution from the authorities in 

the context of the country visit to Hungary. 

136  Information received in the context of the country visit to Hungary from the Hungarian authorities. 
137  Information received in the context of the country visit to Hungary from the National Assembly. 
138  Information received in the context of the country visit to Hungary from the Hungarian authorities. 
139  See GRECO (2022), Fourth Evaluation Round  – Third Interim Compliance Report, paras. 9-10. According 
to the National Assembly, parliamentary rules are clear and interest representatives have the opportunity to 
express their opinions (information received in the context of the country visit to Hungary from the National 
Assembly). 

140  See 2023 Rule of Law Report, Country Chapter on the rule of law situation in Hungary, pp. 18-19. 
141  2022  and  2023  Rule  of  Law  Report,  Country  Chapter  on  the  rule  of  law  situation  in  Hungary.  See  in  this 

context also GRECO (2023), Fifth Evaluation Round – Evaluation Report, p. 56 et seq.).  

142  They apply only to a small group of officials and a limited set of public institutions, such as the State Audit 
Office and the National Media and Infocommunications Authority, see 2022 and 2023 Rule of Law Report, 
Country Chapter on the rule of law situation in Hungary, pp. 17-18 (for 2022) and pp. 19-20 (for 2023). 
143  No  sanctions  are  enforced  in  practice.  The  Government  is  still  to  specify  the  sectors  and  public  officials’ 
positions to which cooling-off time restriction will apply with regard to business careers of public officials in 
the area, in which they were active beforehand. 

21 

 
 
planned144.  Without  more  steps  taken  for  a  comprehensive  reform  on  lobbying  and  post-
employment  rules,  there  has  been  no  further  progress  on  the  recommendation  made  in  the 
previous years. 

There has been no further progress to improve the asset declarations’ system, including 
effective  oversight.  The  2023  Rule  of  Law  Report  recommended  to  Hungary  to  ‘further 
improve 
the  system  of  asset  declarations,  providing  for  effective  oversight  and 
enforcement’145. On 7 December 2023, the Integrity Authority presented an ad-hoc report on 
Hungary’s  asset  declaration  system,  including  an  extensive  set  of  recommendations  to  the 
Government146. There is no official Government reply to this report yet. The National Anti-
Corruption  Strategy  for  2024-2025  includes  plans  for  the  Ministry  of  Justice  to  create  the 
possibility for electronic submission of asset declarations and to propose the introduction of 
an effective, proportionate, and dissuasive administrative and criminal sanctions’ regime for 
breaches of asset declaration obligations147. The power to verify asset declarations has not yet 
been effectively transferred and provided to the Integrity Authority148. In practice, according 
to  the  Integrity  Authority,  obstacles  for  its  oversight  role  remain  substantial,  including  the 
lack  of  direct  access  to  certain  registers  necessary  for  the  effective  fulfilment  of  its 
verification  tasks149.  Stakeholders  stressed  emerging  risks,  with  private  equity  funds  and 
fiduciary asset management arrangements providing for new opportunities to potentially hide 
assets, as they are removed from general oversight and access by the Integrity Authority150. 

144  Government  Decision  1025/2024  of  14  February  2024. According  to  Section  85  of Act  XXXVI  of  2012, 
restrictions apply for a period of two years after the termination of the mandate to members of Parliament to 
prevent economic conflicts of interest in that they are restricted to conclude a purchase agreement to acquire 
shareholdings  of  a  business  organisation  operating  with  influence  over  the  Hungarian  or  foreign  State,  a 
local  government,  the  association  of  local  governments,  a  foreign  municipality,  a  political  party,  or  a 
domestic  or  foreign  religious  community.  GRECO  has  repeatedly  called  for  the  introduction  of  a  code  of 
ethics/conduct  for  members  of  Parliament,  covering,  among  others,  post-employment  rules,  and 
complementary, practical measures for their implementation, see GRECO Fourth Evaluation Round – Third 
Interim Compliance Report, pp. 3-4, paras. 8-11, with reference to the Fourth Evaluation Report, p. 17. 

145  2022 and 2023 Rule of Law Report, Country Chapter on the rule of law situation in Hungary, p. 2. 
146  Integrity Authority (2023), Ad-hoc report on asset declarations. The report’s assessment was excluded from 

the Integrity Authority’s first annual analytical integrity report described above in this pillar I, p. 17. 

147  Government  Decision  1025/2024  of  14  February  2024,  Chapter  1.  See  also  written  contribution  from  the 

authorities in the context of the country visit to Hungary. 

148  Hungary committed under the RRP to provide the Integrity Authority with exclusive competence to verify 
the asset declarations of certain high-risk officials covered in Section 183 of Act CXXV of 2018 (including 
the Prime Minister, ministers, state secretaries, political director of the Prime Minister), as well as with the 
power to directly verify the public asset declarations of all high-risk officials. This is for example the case 
for  the  asset  declarations  of  members  of  Parliament,  where  the  Committee  of  Immunities  of  the  National 
Assembly is tasked to verify asset declarations. For non-public asset declarations of high-risk officials, the 
Integrity Authority shall have at least the power to request the competent bodies to carry out the verification 
of those declarations and obtain the result of that verification. 

149  Integrity Authority (2023), 2022 Annual Analytical Report, p. 152. See also above in this pillar I, pp. 17-18. 
150  Information received in the context of the country visit to Hungary from the Integrity Authority, K-Monitor 
and Transparency International Hungary. Even if a declarant as a beneficiary of private equity funds intends 
to transparently submit information on such assets in the declaration, the declaration form does not provide 
for sufficient clarity on how to report, as only shares in funds can be reported, with private equity not having 
shares but beneficiaries. Furthermore, since there is no publicly available database on such assets, there is no 
way  to  check  or  audit  the  income  or  the  beneficiary  status  of  equity  funds.  Reportedly,  ministers  were 
encouraged  by  a  non-public  Government  decision  (4100/2022)  to  transfer  their  holdings  in  public  limited 
companies and small and medium-sized enterprises into such trusts. See RTL (2024), The government covers 
up  certain  corporate  assets  of  ministers  with  an  undisclosed  decision;  24.hu  (2024),  Ministerial  fortunes 
may remain invisible as a result of a government decision.  

22 

 
 
With regard to asset declarations of members of Parliament, concerns persist regarding their 
effective  and  regular  monitoring  and  verification151.  In  the  reporting  period,  no  procedure 
against  a  member  of  Parliament  before  the  National  Assembly’s  Immunity  Committee  was 
initiated,  and  two  members  of  Parliament  decided  to  correct  and  rectify  their  asset 
declarations  retrospectively  following  reports  in  media152.  As  previously  reported,  there  is 
still no obligation for regular monitoring for the respective entities in Parliament or the Tax 
and  Customs  Administration  to  check  the  correctness  and  completeness  of  the  declarations 
made.  Asset  declarations  are  generally  verified  only  upon  notification  of  suspicions,  and 
potential  follow-up  is  left  to  the  discretion  of  the  public  official’s  employer  or,  in  case  of 
members  of  Parliament  and  other  high-ranking  officials,  to  the  Immunity  Committee. 
However,  neither  declarations  of  most  high-ranking  officials  nor  information  about  any 
follow-up  are  publicly  available153.  Other  previously  identified  shortcomings  remain 
unaddressed, including more effective monitoring, verification, oversight and enforcement154. 
Against  this  background,  no  progress  has  therefore  been  made  towards  implementing  the 
recommendation made in the 2023 Rule of Law Report155. 

Guides  and  awareness-raising  measures  on  conflicts  of  interests  are  envisaged,  while 
legislative fragmentation and systemic weaknesses remain. The Government included in 
the Action Plan of the National Anti-Corruption Strategy 2024-2025 the adoption of a Code 
of Conduct for persons with executive functions156, the aim of which is to provide new soft 
law rules for political and professional senior managers, their advisers, and Prime Minister’s 
delegates. To increase awareness of integrity also in the National Assembly, in particular, on 
conflicts  of  interests,  gifts  and  benefits,  the  Code  of  Conduct  is  planned  to  cover  also 
members of Parliament and employees of the Office of the National Assembly157. However, 
in  2023,  there  were  no  developments  to  address  the  systemic  weaknesses  reported  on  in 
2023158.  These  include,  among  others,  the  fragmentation  of  the  regulatory  framework  on 
conflict of interests, including the lack of a general definition of conflict of interests and the 

151  GRECO  also  found  that  the  verification  of  declarations  was  clearly  insufficient  (GRECO  (2023),  Fifth 
Evaluation  Round  –  Evaluation  Report,  p.  4, para.  3).  In  January 2024,  members  of  Parliament  continued 
largely  to  submit  their  asset  declarations  on  paper.  Of  these,  63  used  electronic  software  to  complete  and 
print the declaration, while 136 completed the declaration on paper (written contribution from the National 
Assembly  in  the  context  of  the  country  visit  to  Hungary).  No  failures  to  comply  within  the  deadline  are 
reported.  

152  Information received by the National Assembly in the context of the country visit to Hungary. 
153  While the declarations of members of Parliament are publicly available, they are often scanned documents 
filled  out  by  hand,  thus  not  being  machine-readable.  Furthermore,  in  2023,  while  previously  available, 
family  members’  names  in  asset  declarations  of member  of  Parliament  have  been  retrospectively  removed 
from all declarations published from 2010 onwards (information received in the context of the country visit 
to Hungary from National Data Protection and Freedom of Information Authority).  

154  See 2023 Rule of Law Report, Country Chapter on the rule of law situation in Hungary. See also K-Monitor 

(2023), Hungarian MP’s Assets: Less Declared and Still not Monitored. 

155  Important weaknesses, risks and shortcomings remained as regards elements of the asset declaration  system 
which  create  possible  loopholes  undermining  the  effectiveness  of  the  measure  were  also  identified  by  the 
Communication  on  the  application  of  Regulation  (EU,  Euratom)  2020/2092  (15  January  2024).  Council 
Implementing Decision (EU) 2022/2506 of 15 December 2022, recital 41. 

156  See above and RRP milestone 178. 
157  Written contribution from the National Assembly in the context of the country visit to Hungary. 
158  See 2023 Rule of Law Report, Country Chapter on the rule of law situation in Hungary, pp. 21-23. 

23 

 
 
absence  of  a  central  supervisory  body  remain  so  far,  as  also  pointed  out  by  the  Integrity 
Authority159.  

The  new  whistleblower  protection  law  for  EU  funds  entered  into  force.  The  new  law 
transposing  the  EU  Directive160  to  enhance  the  protection  of  whistleblowers  reporting  on 
potential wrongdoings relating to breaches of EU law has been in force since 24 July 2023161. 
Stakeholders flagged risks of legal uncertainty, with weaker protection levels for those cases 
that concern national funds compared to those that relate to EU funds162. An accompanying 
Government Decree sets out which Government bodies will be required to establish separate 
whistleblower  disclosure  systems163  apart  from  the  already  operated  online  disclosure 
channels164.  The  anonymous,  secure  whistleblower  hotline  of  the  Integrity  Authority  for 
corruption,  fraud  and  conflicts  of  interests  related  to  EU  funds  became  operational  in  June 
2023165. Overall, some disclosures reportedly reach the respective entities, but whistleblower 
reporting is not yet a widespread practice166. Also in 2023, no further steps have been taken 
yet  to  address  the  major  operational  deficiencies  in  the  whistleblower  regime  in  practice, 
including  the  limited  protection  against  retaliation  and  the  risks  of  disclosure  of  the 
whistleblowers’ identity167. 

Shortcomings with regard to political party and campaign rules and their narrow scope 
of application remain unaddressed. As reported last year, some measures had been taken to 
increase the transparency of political party financial registries168. The Government announced 
in  its  National  Anti-Corruption  Strategy  2024-2025  a  review  of  the  operations  of  political 
organisations and the enforcement of political party finance rules with a focus exclusively on 
preventing  foreign  funding  of  political  parties169.  In  February  2024,  the  State  Audit  Office 
imposed  fines  on  six  political  parties  for  alleged  illegal  foreign  funding  during  the  2022 
election campaign170. Challenges previously identified regarding political party and campaign 

159  Integrity Authority (2023), 2022 Annual Analytical Report, p. 119.  
160  Directive (EU) 2019/1937 on the protection of persons who report breaches of Union law. 
161  Act XXV of 2023 on complaints, public interest disclosures and rules related to whistleblowing. 
162  Information  received  in  the  context  of  the  country  visit  to  Hungary  from  K-Monitor  and  Transparency 
International Hungary; K-Monitor and Transparency International Hungary (2023),  Letter to the European 
Commission,  Possible  infringements  of  Directive  2019/1937  on  the  protection  of  persons  who  report 
breaches of Union law by the Hungarian Government, noting that disclosures to media remain unprotected. 

163  Government Decree 225/2023 of 8 June 2023. 
164  At the Commissioner for Fundamental Rights, the  National Protective Service, the Competition Authority, 

the Public Procurement Authority and the Prime Minister’s Office. 

165  See written contribution from the Integrity Authority in the context of the country visit in Hungary and the 

Integrity Authority’s website to report: https://integritashatosag.whispli.com. 

166  Anonymous  whistleblowing  on  EU  fraud  can  also  be  disclosed  on  the  anti-lop.hu  website.  In  2023, 
reportedly 25 whistleblowing reports were received  on the website, of which three are under investigation, 
and ten have been rejected as unfounded or after investigation.  See also the Special Eurobarometer 584 on 
Corruption (2024) on the level of corruption reporting. The reluctance to report is partially due to the lack of 
financial support for those who risk potential retaliation (information received in the context of the country 
visit to Hungary from K-Monitor and Transparency International Hungary). Also 2023 Rule of Law Report, 
Country Chapter on the rule of law situation in Hungary, p. 23. 

167  See OECD (2021), Implementing the OECD Anti-Bribery Convention, Phase 4 Two-Year Follow-Up Report: 
Hungary, p. 3. The general prohibition of retaliation of the new, enforced Act applies only to whistleblower 
disclosures related to subject-matters in EU legal acts. 

168  2023 Rule of Law Report, Country Chapter on the rule of law situation in Hungary, pp. 24-25. 
169  See Government Decision 1025/2024 of 14 February 2024. 
170  State  Audit  Office  (2024),  Partial  Audit  Report.  Bloomberg  (2024),  Hungary  Clamps  Down  on  Orban’s 
Opponents  with  Hefty  Fine.  Intellinews  (2024),  Hungarian  State  Audit  Office  fines  opposition  parties  for 

24 

 
 
 
financing  rules171  have  not  been  addressed  in  the  reporting  period  and  no  actions  in  this 
regard are planned under the Strategy and Action Plan. Overall concerns therefore remain as 
regards the transparency of party financing172. 

New  obstacles  to  the  transparency  of  public  procurement  appeared,  while  different 
levels  of  control  exist  for  national  and  EU-funds  related  procurements.  Businesses’ 
attitudes towards corruption in the EU show that 29% of companies in Hungary (EU average 
27%)  think  that  corruption  has  prevented  them  from  winning  a  public  tender  or  a  public 
procurement  contract  in  practice  in  the  last  three  years173.  Some  measures  to  enhance 
competition in public procurement are included in the National Anti-Corruption Action Plan 
for  2024-2025174.  The  members  of  the Anti-Corruption  Task  Force  report  that  most  of  the 
proposals  made  in  its  report  related  to  public  procurement  did  not  receive  support  by  the 
Government175. Stakeholders report that since autumn 2023, new obstacles have appeared for 
transparency  of  public  procurement176,  highlighting  practical  challenges.  For  instance,  they 
report that a new feature renders the bulk download of data on public procurement, and hence 
statistical  analysis  concerning risks of corruption and political  favouritism,  difficult177. This 
restricts possibilities for public monitoring. Corruption risk sectors remained largely the same 
compared to previous years, with high risks in public procurement, construction, health, IT, 

alleged foreign campaign finance. There are no legal possibilities to appeal the findings. Parties are subject 
to the prohibition of foreign funding. The Protection of National Sovereignty Act extended this prohibition to 
non-profit  organisations  which  are  now  prohibited  from  accepting  foreign  funding  and  from  using 
anonymous election donations or financial support from non-legal persons. The definition of foreign funding 
has  a  broad  scope,  encompassing  not  only  financial  contributions  from  other  state  and  foreign  natural  or 
legal persons, but also already the provision of trainings.  

171  Including  the  narrow  scope  of  application,  campaign  activities  that  are  conducted  outside  the  official 
campaign period, systemic overspending on outdoor billboard advertising during the 2022 elections, political 
advertising on the social media platform Facebook, financed by third parties and intermediaries, including 
the conservative social media incubator Megafon Centre training pro-government influencers and promoting 
their posts as one of the largest spenders on political ads on Facebook in the election  campaign,  see 2023 
Rule  of  Law  Report,  Country  Chapter  on  the  rule  of  law  situation  in  Hungary,  pp.  24-25;  on  the  level  of 
spending, see Lakmusz (2024), How does anyone who is not a friend of Fidesz become a ‘leftist’; and Telex 
(2024), SAO: CÖF and Megafon said that they had not cooperated with Fidesz.  

172  See  in  this  context  also  OSCE  ODIHR  and  Venice  Commission  (2020),  Guidelines  on  Political  Party 
Regulation,  Second  Edition,  para.  194;  OSCE  ODIHR  (2022),  Hungary  Parliamentary  Elections  and 
Referendum - 3 April 2022 - ODIHR Election Observation Mission Final Report, p. 22. State Audit Office 
audit  findings  cannot  be  challenged  before  an  administrative  court.  See  also  GRECO  (2019),  Third 
Evaluation Round – Second Addendum to the Second Compliance Report, para. 24. 

173  Flash  Eurobarometer  543  on  Businesses’  attitudes  towards  corruption  in  the  EU  (2024),  Report,  IV. 

Reporting of Corruption. 

174  Government Decision 1025/2024 of 14 February 2024, Chapter 5. See also European Commission (2024), 

2024 Country Report Hungary, pp. 9 and 62 for further measures to enhance competition. 

175  See K-Monitor and Transparency International Hungary (2024), Special report on the 2023 Anti-Corruption 

Task Force Report: Current issues in the fight against corruption in Hungary. 

176  The  new  website  of  the  Public  Procurement  Authority  uses  ‘captcha’  barriers,  introduced  to  address  IT 
security issues, which however limit machine-readability and comparability of vast amount of data by public 
monitors.  

177  Due to this new feature, public monitors, such as researchers and civil society, incurred extra costs, in order 
to still be able to obtain big data to continue their analysis of corruption risks and patterns in procurement 
over  time.  Information  received  in  the  context  of  the  country  visit  to  Hungary  from  Transparency 
International  Hungary,  K-Monitor  and  Corruption  Research  Center  Budapest,  indicating  that  the  bulk 
download is now more difficult, as it would now have to be done manually step-by-step, as users can only 
log-in for a limited period of time, with repeated requests to authenticate again with ‘captcha’.  

25 

 
 
and communication services178. National legislation does not allow public entities to conclude 
contracts  with  or  make  payments  to  non-transparent  entities.  However,  stakeholders  report 
about  emerging  risks  concerning  transactions  through  non-transparent  structures  with 
transactions often being concluded through private equity funds or trust funds, preventing the 
public  disclosure  of  their  beneficial  owners  and  change  in  ownership  in  practice179.  This 
uncertainty  creates  a  challenge  for  the  supervisory  authority  to  track  compliance  with  loan 
limits to companies owned by the owner of the bank. It also makes it difficult for the public 
to  monitor  the  use  public  money  if  the  state  sells  companies  or  concludes  tender  contracts 
with private equity funds180. Overall, corruption risks were found to have increased in 2023 
for public tenders related to national funds that are not controlled by the EU and thus where 
different levels of control and oversight applies181. In this context, high corruption risks were 
identified  in  particular  for  the  local  level  and  municipalities,  indicating  examples  of  how 
political networks can lead to abuse of tender processes, including favouritism due to close 
ties  between  business  and  politics182.  Stakeholders  continue  to  report  about  selective 
awarding to  political  affiliates183, which carry the potential to  increase  corruption risks in a 
procurement market that is already vulnerable to corruption184.  

III.  MEDIA PLURALISM AND MEDIA FREEDOM 

Hungary’s Fundamental Law185 and sectoral legislation provide the legal framework for the 
protection  of  media  freedom  and  pluralism.  The  Media  Act186  regulates,  in  detail,  both  the 
Hungarian media regulator, as well as the governance of public service media. The Freedom 
of  Information  Act  establishes  a  detailed  framework  which  regulates  the  right  to  access 

178  Input from Hungary for the 2024 Rule of Law report, pp. 11-13. See also Anti-Corruption Task Force (2023), 
2022  Report  of  the  Anti-Corruption  Task  Force,  and  Corruption  Research  Center  Budapest  (2024),  Two 
Communication Companies in the Hungarian Public Procurement Market 2012-2023.  

179  Information  received  in  the  context  of  the  country  visit  to  Hungary  from  Transparency  International 
Hungary,  K-Monitor  and  Corruption  Research  Center  Budapest.  According  to  the  Government,  national 
legislation  does  not  allow  public  entities  to  conclude  contracts  with  or  make  payments  to  non-transparent 
entities; information on the transparency of  such entities is available and beneficial owners are in all cases 
identified. 

180  Assets of private equity funds have increased from 0.2% in 2020 to 2.3% of GDP in 2023. 
181  Corruption  Research  Center  Budapest  (2023),  The  new  trends  of  corruption  risks  in  Hungarian  public 
procurement (2023). On government communications contracts, see Szabad Európa (2024),  Overpricing is 
only one of the tricks – this is how Gyula Balásy gets all state orders. Regarding EU-related procurement, 
see  Integrity Authority  (2024),  Conclusion  of  inquiry  III_86_2023  –  modernisation  of  cattle  farm  and  the 
Annual Analytical Report for 2022 with recommendations for managing authorities. Hungary has committed 
to reduce to 15% the high share of calls for tenders that result in a single bid, see RRP, while the share of 
single bids is reportedly significantly higher for high-value, non-EU fund-related public procurements. See 
also European Commission (2024), The Single Market and Competitiveness Scoreboard on access to public 
procurement in Hungary reporting 33% of single bids for 2022.  

182  SELDI  (2023),  Bridges  to  nowhere  –  State  Capture  and  Corruption  Risks  in  Fiscal  Transfers  and  Public 
Procurement at the Local Level in Southeast Europe, p. 57: when the mayor is from the same political party 
as  the  one  forming  the  ruling  coalition  on  the  national  level  the  value  of  public  procurement  contracts 
increases by approximately 56% in Hungary. 

183  Corruption  Research  Center  Budapest  (2023),  Fourteen  Graphs  and  Two  Tables  on  the  New  Trends  of 
Corruption  Risk  in  the  Hungarian  Public  Procurement  2005-2022;  Corruption  Research  Center  Budapest 
(2023),  White  Elephants  in  Hungary  –  Lessons  of  some  EU  funded  projects.  See  also  Átlátszó  (2023),  We 
identified the companies that have won hundreds of public contracts in a single city. 

184  See in this context also European Commission (2024), 2024 Country Report Hungary, p. 4. 
185  Article IX(2) of the Fundamental Law.  
186  Act CLXXXV of 2010. 

26 

 
 
information  held  by  public  authorities187.  The  Press  Act188  lays  down  general  and 
fundamental rules on freedom of the press and media content. 

There has been no progress to strengthen the functional independence of the Hungarian 
media  regulator.  The  2023  Rule  of  Law  Report  recommended  to  Hungary  to  ‘[i]ntroduce 
mechanisms to enhance the functional independence of the media regulatory authority taking 
into account European standards on the independence of media regulators’189. The decision-
making  body  of  the  Authority,  the  Media  Council,  remains  composed  of  members  all 
nominated by Parliament. The Commission’s action against Hungary in front of the Court of 
Justice  -  in  relation  to  the  Media  Council’s  refusal  to  renew  the  broadcasting  license  of 
independent  radio  station  Klubrádió,  which  resulted  in  the  radio  being  taken  off  air  -  is 
ongoing190. In light of the unresolved concerns with regard to the authority, the 2024 Media 
Pluralism  Monitor  (MPM)  once  more  assesses  the  independence  and  effectiveness  of  the 
Media Authority as an area presenting high risk, referring to the authority’s composition, lack 
of  transparency  of  its  decision-making  process  and  ‘clear  political  bias’191.  Given  that  no 
measures  have  been  adopted  or  are  planned  to  strengthen  the  regulator’s  functional 
independence,  there  has  been  no  progress  as  regards  the  recommendations  made  in  the 
previous years. 

There has been no progress to increase transparency and fairness in the distribution of 
state  advertising.  The  2023  Rule  of  Law  Report  recommended  to  Hungary  to  ‘adopt 
legislation to ensure fair and transparent distribution of advertising expenditure by the state 
and  state-owned  companies’192.  No  measures  have  been  announced  to  that  effect. 
Stakeholders  concur  that  the  State  is,  by  far,  the  most  important  player  in  the  media 
advertising  ecosystem  and  that  the  channelling  of  significant  state  resources  to  pro-
government  media  continues  to  prevent  a  level  playing  field  in  the  Hungarian  media 
landscape193.  MPM  2024  states  that  ‘for  years  now,  the  government  is  seen  as  the  largest 
advertiser  on  the  Hungarian  media  market’,  continues  to  consider  this  to  be  an  area  of 
medium risk194. Given that no legislative or other measures have been adopted or are planned 
by the Government, there has been no progress as regards the recommendations made in the 
previous years.  

There  are  no  specific  rules  on  transparency  in  the  ownership  structure  of  media 
companies.  Registers  maintained  by  the  media  authority  contain  limited  information  on 

187  Hungary ranks 67th in the 2024 Reporters without Borders World Press Freedom Index compared to 72nd the 

previous year. 
188  Act CIV of 2010. 
189  2022 Rule of Law Report, Country Chapter on the rule of law situation in Hungary, p. 2. In the 2023 Rule of 
Law Report, the Commission concluded that no progress had been made on the recommendation (2023 Rule 
of Law Report, Country Chapter on the rule of law situation in Hungary, p. 2).  

190  Action  brought  by  the  Commission  on  17  February  2023  in  case  Commission  v  Hungary  (Case  C-92/23). 

Klubrádió currently operates online. 

191  Media Pluralism Monitor 2024, country report on Hungary, pp. 15-16. 
192  2022 Rule of Law Report, Country Chapter on the rule of law situation in Hungary, p. 2. In the 2023 Rule of 
Law Report, the Commission concluded that no progress had been made on the recommendation (2023 Rule 
of Law Report, Country Chapter on the rule of law situation in Hungary, p. 2). 

193  Contribution  from  International  Press  Institute  for  the  2024  Rule  of  Law  Report,  p.  18;  contribution  from 
Mérték  Media  Monitor  for  the  2024  Rule  of  Law  Report,  p.  19;  contribution  from  Reporters  Without 
Borders for the 2024 Rule of Law Report, pp. 16-17.  

194  Media Pluralism Monitor 2024, country report on Hungary, p. 29. 

27 

 
 
media  service  providers,  but  direct  ownership  information  is  available  via  the  business 
register.  This  leads  the  2024  MPM  to  once  more  consider  this  a  high-risk  area  although  it 
points  out  that  ‘in  practice  […]  the  public  is  often  aware  of  the  ultimate  beneficial  owners 
behind a particular outlet’ due to the attention which journalists and researchers have given to 
this  matter195.  There  has  been  no  change  to  the  Hungarian  system  of  review  of  market 
concentration in the media market and, to date, no attempt by the Media Authority to examine 
the  impact  of  major  operations  on  the  plurality  and  diversity  of  the  Hungarian  media 
market196.  

There has been no progress  to enhance the independence of public service media. The 
2023  Rule  of  Law  Report  recommended  to  Hungary  to  ‘[s]trengthen  the  rules  and 
mechanisms  to  enhance  the  independent  governance  and  editorial  independence  of  public 
service  media  taking  into  account  European  standards  on  public  service  media’197.  No 
significant  legislative  or  policy  changes  have  been  adopted  or  are  planned  in  terms  of  the 
governance and funding of public service media, and concerns in relation to its financial and 
editorial independence persist198. As a consequence, the 2024 MPM has maintained its very 
high-risk score for this area based on its findings, among others, that public service media is 
financially  dependent  on  the  governing  majority  and  the  lack  of  effective  control 
mechanisms199.  There  has  thus  been  no  progress  on  the  recommendations  made  in  the 
previous years200. 

Further  legislative  changes  have  introduced  some  restrictions  to  the  freedom  of 
information  which  had  been  subject  to  a  recent  reform.  The  2023  Rule  of  Law  Report 
noted that a recent reform sought to facilitate access to public information and rendered the 
charging  of  fees  exceptional.  The  reform  aimed  to  accelerate  litigation  in  connection  with 
data  of  public  interest,  by  introducing  very  tight  procedural  deadlines.  Stakeholders  also 
noted  that  the  reform  had  established  the  over-arching  principle  that  public  information 
should  be  provided  free  of  charge,  rendering  associated  fees  exceptional201.  Stakeholders 
report that the reform has indeed resulted in speeding up litigation in freedom of information 
cases in front of the courts, although extraordinary remedies before the Kúria and ineffective 
enforcement  proceedings  significantly  delay  the  release  of  the  documents  and  data 

195  Media Pluralism Monitor 2024, country report on Hungary, pp. 19-20. 
196  See 2020, 2021 and 2022 Rule of Law Reports, Country Chapters on the rule of law situation in Hungary. An 
overview of the media market, including main players and trends, can be found in the 2023 Media Market 
Report prepared by the Media Authority. National Media and Infocommunications Authority (2023), Media 
Market Report 2023.  

197  2022 Rule of Law Report, Country Chapter on the rule of law situation in Hungary, p. 2. In the 2023 Rule of 
Law Report, the Commission concluded that no progress had been made on the recommendation (2023 Rule 
of Law Report, Country Chapter on the rule of law situation in Hungary, p. 2). 

198  For details with regard to the legislative framework regulating public service media see 2022 Rule of Law 

Report, Country Chapter on the rule of law situation in Hungary, pp. 22-23. 

199  Media Pluralism Monitor 2024, country report on Hungary, pp. 29-30. 
200  According  to  the  European  Parliament’s  Flash  Eurobarometer:  News  &  Media  Survey  2023,  25%  of 
respondents in Hungary stated that they trust public TV and radio stations, below the EU average of 48%.  
201  2023 Rule of Law Report, Country Chapter on the rule of law situation in Hungary, p. 28. Stakeholders point 
out that under the new rules, the defendant may present its  defence (the reasons for rejecting the access to 
documents application) orally at the first court hearing; in such a situation, the data requester cannot prepare 
effectively and has to develop its arguments right during the first hearing. Courts have adequate resources to 
process freedom of information cases within the statutory deadlines (information received in the context of 
the country visit to Hungary from the National Office for the Judiciary). 

28 

 
 
requested202.  In  2023  and  2024,  Parliament  adopted  further  legislative  amendments, 
introducing  new  grounds  for  rejecting  freedom  of  information  requests203.  Furthermore,  in 
direct  response  to  a  court  decision  which  had  ordered  access  to  certain  unclassified  but 
unpublished  government  documents,  as  of  1  March  2024  a  legislative  amendment204 
expressly  allowed  the  authorities  to  limit  public  access  to  this  category  of  documents. 
According  to  stakeholders,  these  amendments  make  access  to  public  information  more 
difficult205.  Parliament  has  so  far  not  implemented  a  Constitutional  Court  decision206 
requiring legislative amendments to establish effective judicial protection in case of freedom 
of  information  requests  related  to  public  funds,  addressed  to  the  recipients  of  such  funds. 
While  Hungary  committed207  to  ensure  that  all  public  bodies  publish  specified  data  on  the 
new  transparency  portal,  stakeholders  point  out  that  proactive  data  publication  on  the  new 
portal  is  not  mandatory  for  all  entities  performing  a  public  duty  and  certain  features  of  the 
portal  hamper  its  usefulness  in  accessing  data208.  The  MPM  2024  maintains  its  high-risk 
score for this area209. 

202  Joint  contribution  from Amnesty  International  Hungary  and  eight  other  CSOs  for  the  2024  Rule  of  Law 
Report, pp. 64-65; contribution from Hungarian Civil Liberties Union for the 2024 Rule of Law Report, p. 
20. The Kúria has 60 days to rule on a petition for review limited to points of law  (Section 31/C(5) of Act 
CXII of 2011); this procedural deadline cannot be extended.  

203  Act  CI  of  2023  amended Act  CXXII  of  2009  and Act  CXII  of  2011. As  of  30  December  2023,  the  new 
Section  3/A  of  Act  CXXII  of  2009  obliged  State-owned  companies  to  deny  for  a  period  of  10  years, 
following advice  from a Minister, the freedom of information requests related to their foreign investments 
and foreign relations. As of 1 January 2024, the new Section 30(2a) of Act CXII of 2011 provides that public 
service entities may deny a freedom of information request if granting it would require the collection of data 
from  another  public  service  entity  or  would  require  the  production  of  new  data  by  comparing  data  in 
possession of the two entities. According to the Government, this amendment was necessary in order to meet 
the  requirements  set  out  both  by  the  Kúria  and  the  Constitutional  Court  (written  contribution  from  the 
authorities in the context of the country visit to Hungary). 

204  The new Section 7/A of Act CXXV of 2018 on Government administration introduced by Act CIX of 2023. 
On  16  March  2023,  the  Budapest  Regional  Court  (15.P.22.010/2022/15),  confirmed  on  appeal  by  the 
Budapest Regional Appeal Court (Pf.20236/2023/5) on 13 June 2023, ordered the Government to grant news 
portal hvg.hu access to unclassified but unpublished Government decisions. The new  provision  allows the 
authorities  to  refuse  public  access  to  such  unclassified  documents  for  a  period  of  20  years  maximum  to 
‘safeguard the public interest’.  

205  Joint  contribution  from Amnesty  International  Hungary  and  eight  other  CSOs  for  the  2024  Rule  of  Law 
Report, p. 64; contribution from Transparency International Hungary for the 2024 Rule of Law Report, p. 13. 
206  Decision 7/2020. (V. 13.) AB concerned a freedom of information request addressed to a private company 
(not an entity performing a public duty) related to the construction of a motorway financed from EU funds. 
207  Hungary committed to ensure that all public bodies proactively publish a predefined set of information on 
the use of public funds in a central register in an open, interoperable and machine-readable format, which 
allows  bulk  download  and  data  to  be  sorted,  searched,  extracted,  compared  and reused; access  to  the  data 
shall be provided free of any charge and without the need to register (RRP milestones 175, 176). 

208  K-Monitor (2023), Report on the Access to Information, pp. 5-9. The new Central Public Data Information 
Register  is  an  online  repository  where  certain  public  entities  upload  metadata  on  their  contracts  (not  the 
contracts  themselves).  The  National  Data  Protection  and  Freedom  of  Information Authority  has  launched 
‘transparency procedures’ in case of non-compliance; these procedures focused on data that had already been 
made public in the Electronic Public Procurement System. The Register does not allow search by the name 
of companies that were awarded the contracts. While data are accessible and downloadable in CSV and PDF 
formats, bulk access to data is prevented by ‘captchas’. The Register has a limited personal scope compared 
to the already existing but not widely used public data site (kozadat.hu) because it exempts several entities 
performing  a  public  duty  (‘közfeladatot  ellátó  szerv’).  Only  public  entities  having  a  budgetary  status 
(‘költségvetési  szerv’)  under Act  CXCV  of  2011  fall  under  the  scope  of  the  new  disclosure  rules  (Section 
37/C  of  Act  CXII  of  2011).  Municipalities,  municipality-owned  companies,  public  interest  trusts  (e.g. 
Mathias  Corvinus  Collegium),  State-owned  companies  (e.g.  Hungarian  National  Asset  Management  Inc., 

29 

 
 
 
Journalists  and  other  media  professionals  continue  to  face  numerous  challenges. 
Following an amendment to the Criminal Code210, slanderous or defamatory statements made 
in the press or in the media as part of the public discourse are no longer punishable, unless 
they  ‘are  aimed  at  a  manifest  and  seriously  offensive  denial  of  the  human  dignity  of  the 
aggrieved  party’.  While  stakeholders  point  out  that  physical  attacks  against  journalists  are 
very rare in Hungary, they continue to draw attention to the selective access to government 
premises  and  events,  as  well  as  the  prevalence  of  seemingly  coordinated  smear  and  de-
legitimisation  campaigns  against  various  journalists  who  are  frequently  labelled  ‘foreign 
agents’,  ‘mercenaries’  and  ‘traitors’211.  The  2024  MPM  continues  to  consider  the  safety  of 
journalists to  be an area of medium  risk212. The 2023 Mapping  Media Freedom  monitoring 
report flags the targeting of numerous media outlets by Distributed Denial-of-Service (DDoS) 
cyberattacks as a new emerging threat213. The Council of Europe’s Platform to promote the 
protection  of  journalism  and  safety  of  journalists  registered  two  new  alerts  relating  to, 
respectively,  the  adoption  of  the  Protection  of  National  Sovereignty  Act214  and  DDoS 
attacks215.  

IV.  OTHER INSTITUTIONAL ISSUES RELATED TO CHECKS AND BALANCES 

Hungary  is  a  parliamentary  republic  with  a  unicameral  Parliament  (National  Assembly). 
Parliament,  among  other  functions,  adopts  and  amends  the  Fundamental  Law  of  Hungary, 
legislates, including cardinal laws216, elects the Prime Minister, and elects – by a two-thirds 
majority  –  the  top  rank  public  officials  of  the  country.  The  President  of  the  Republic  is 
elected by Parliament. There are a number of institutions tasked with counter-balancing the 
powers of the legislature and the executive, and are entrusted with guaranteeing the respect of 
the  constitutional  order,  including  the  Constitutional  Court,  the  State  Audit  Office  and  the 
Ombudsperson  (‘Commissioner  for  Fundamental  Rights’);  the  latter  is  also  tasked  with  the 
roles  of  the  equality  body  and  national  human  rights  institution.  The  Constitutional  Court 
reviews  the  constitutionality  of  laws  and  judicial  decisions.  In  addition  to  the  Government, 
the President of the Republic, every parliamentary committee and any member of Parliament 
may table a draft law. 

Increasing  state  interventions  and  arbitrary  decisions  of  the  authorities  weaken  legal 
certainty and remain a problem for the operation of businesses in the single market. The 

Hungarian Tourism Agency, Bethlen Gábor Fund Management Inc.) and the Hungarian National Bank are 
not required to provide data to the new Register. The entities falling outside the scope of the new rules are 
still obliged to publish data in accordance with the ‘general disclosure list’ (Annex 1 to Act CXII of 2011) 
but non-compliance is not sanctioned. 

209  Media Pluralism Monitor 2024, country report on Hungary, p. 14. 
210  Sections 226(3) and 227(3) of Act C of 2012, amended by Act XXX of 2023 as of 2 June 2023. 
211  Contribution  from  International  Press  Institute  for  the  2024  Rule  of  Law  Report,  p.  20;  contribution  from 
Reporters Without Borders for the 2024 Rule of Law Report, p. 18. See also Human Rights Watch (2024), ‘I 
Can’t Do My Job as a Journalist’ – The Systematic Undermining of Media Freedom in Hungary, p. 24-25.  

212  Media Pluralism Monitor 2024, country report on Hungary, pp. 14-15. 
213  Media Freedom Rapid Response (2023), Mapping Media Freedom - Monitoring Report 2023, p. 28. 
214  See pillar IV. 
215  Council of Europe, Platform to promote the protection of journalism and safety of journalists.  
216  The  Fundamental  Law  provides  for  the  adoption  of  36  cardinal  laws  containing  detailed  rules  on  the 
functioning of key institutions. They may be adopted or amended by a two-thirds majority of the members of 
Parliament  present.  The  Venice  Commission  has  been  critical  of  Hungary  for  using  cardinal  acts  beyond 
what is strictly necessarywhich has been considered questionable from a democratic perspective as it makes 
it difficult to introduce reforms in the future (CDL-AD(2012)009, para. 47). 

30 

 
 
2023 Rule of Law Report noted that the Government continued to use its emergency powers 
extensively, which undermines legal certainty and affects the operation of businesses in the 
single  market217.  The  Government  extended  until  November  2024  the  ‘state  of  danger’ 
declared by the Government on 25 May 2022 ‘in view of the armed conflict and humanitarian 
catastrophe in Ukraine and with a view to averting their impact on Hungary’218. In this way, 
the Government can override Acts of Parliament. Several emergency measures adopted in the 
reporting  period  might  have  an  impact  on  the  business  environment219,  while  others  do  not 
seem  to  be  related  to  the  ‘state  of  danger’220.  Parliamentary  oversight  of  individual 
emergency  measures  is  weak221.  Stakeholders  reported  that  the  Constitutional  Court  cannot 
ensure the effective and timely review of emergency measures222 and that the extensive and 
prolonged use of the Government’s emergency powers has undermined legal certainty223. The 
Government  has  continued  to  declare  certain  investment  projects  to  be  of  ‘strategic 
importance for the national economy’ or of ‘priority’. While the Government maintains that 
legal remedies before the ordinary courts exist, these types of projects are exempt from public 
oversight  and  control224  merely  through  decrees,  which  can  only  be  challenged  before  the 

217  2023 Rule of Law Report, Country Chapter on the rule of law situation in Hungary, p. 31. 
218  Government Decrees 167/2023 of 11 May 2023, 515/2023 of 22 November 2023 and 86/2024 of 17 April 
2024 amended Government Decree 424/2022 of 28 October 2022 by extending the ‘state of danger’ until 26 
November  2023,  24  May  and  19  November  2024,  respectively.  The  Government  needed  an  authorisation 
from  Parliament  to  extend  the  ‘state  of danger’. This  authorisation  was  given  through Section  2(1)  of Act 
XLII of 2022, as amended by Act XI of 2023, Act LXXII of 2023 and Act VIII of 2024. In parallel, Hungary 
has been under a ‘crisis situation caused by mass immigration’ since 10 March 2016. 

219  E.g.  in  the  second  half  of  2023,  the  rules  applicable  to  insolvency  and  winding  up  have  been  amended 
several times through Government Decrees: 265/2023 of 28 June 2023, 267/2023 of 29 June 2023, 335/2023 
of 20 July 2023, 436/2023 and 437/2023 of 21 September. Also, Government Decree 279/2023 of 29  June 
2023 increased from 10 to 15 % the discount retailers are forced to offer on certain food products. In 2023, 
the  Government  adopted  119  emergency  measures;  some  emergency  measures  were  subsequently 
incorporated in statute (information received in the context of the country visit to Hungary from the National 
Assembly).  The  Commission  has  brought  infringement  procedures  against  certain  emergency  measures 
considered  incompatible  with  EU  law  (e.g.  INFR(2021)2158,  INFR(2022)4009,  INFR(2022)4108). 
According to the Government, some emergency measures were adopted in the reporting period in order to 
protect vulnerable social groups and economic segments. 

220  For instance, Government Decree 523/2023 of 30 November 2023 removes the protection granted to  listed 
buildings  and  local  heritage  requirements  established  by  local  municipalities  in  the  case  of  certain 
investments  of  strategic  importance  for  the  national  economy.  The  apparent  objective  is  to  facilitate  the 
building  of  a  new  university  campus  in  the  8th  District  of  Budapest  without  the  consent  of  the  local 
authorities (contribution from Hungarian Helsinki Committee for the 2024 Rule of Law Report, p. 38). 

221  Contribution  from  Democracy  Reporting  International  for  the  2024  Rule  of  Law  Report,  p.  5.  The 
Government  needs  to  keep  Parliament  informed  about  the  decrees  adopted  during  the  ‘state  of  danger’; 
Parliament may repeal such Government decrees (Article 53 of the Fundamental Law); the Government has 
to take all measures necessary to guarantee the continuous functioning of Parliament and the Constitutional 
Court (see Article 52 of the Fundamental Law). Parliament has no ex ante control over individual emergency 
measures. 

222  Joint  contribution  from Amnesty  International  Hungary  and  eight  other  CSOs  for  the  2024  Rule  of  Law 
Report, p. 74; contribution from Eötvös Károly Policy Institute for the 2024 Rule of Law Report, p. 38. 
223  Contribution from Council of Bars and Law Societies of Europe for the 2024 Rule of Law Report, p. 68. 
224  The  Government has issued Decrees under Act LIII of 2006 (replaced, as of 1 January 2024, by Act C of 
2023 on Hungarian architecture). See 2023 Rule of Law Report, Country Chapter on the rule of law situation 
in Hungary, p. 32. Such measures include Government Decree 220/2023 of 1 June 2023 (two ports on Lake 
Balaton),  Government  Decree  263/2023  of  28  June  2023  (smart  logistics  park),  Government  Decree 
373/2023 of 7 August 2023 (primary school), Government Decree 390/2023 of 14 August 2023 (technology 
park),  Government  Decree  418/2023  of  31  August  2023  (building  material  factory),  Government  Decree 
423/2023 of 5 September 2023 (worker hostel next to an economic zone), Government Decree 429/2023 of 
14 September 2023 (bank building, hotel development), Government Decree 483/2023 of  31 October 2023 

31 

 
 
 
Constitutional Court. So far, the Court has not annulled any of these Decrees225. On 19 June 
2024,  in  the  context  of  the  European  Semester,  the  Commission  proposed  that  the  Council 
recommend  that  Hungary  ‘[i]mprove  the  regulatory  framework  and  enhance  competition  in 
product  markets  and  services  by  avoiding  arbitrary  administrative  interventions  and  the 
selective use of tailor-made legislation providing undue advantage or disadvantage to specific 
companies, by applying competition  scrutiny systematically to  business  transactions and by 
reducing  the  use  of  emergency  measures  to  what  is  strictly  necessary,  in  line  with  the 
principles of the single market and the rule of law’226. 

The quality of law-making and the frequent changes in legislation remain a significant 
cause for concern. Stakeholders reported that while draft pieces of legislation are published 
on the Government’s website, response times are limited to the statutory eight days and there 
is  no  meaningful  feedback227.  Stakeholders  also  note  that  important  legislative  changes  are 
not  subject  to  public  consultation  or  a  meaningful  debate  in  Parliament  because  of  the 
Government’s  practice  to  include  only  technical  amendments  in  draft  laws  and  then, 
following  a  purely  formal  process,  introduce  new  provisions  in  the  bill  through  the 
Committee on Legislation228 just before the  final  vote in  Parliament229. The quality  of law-

(new  production  hall  and  office),  Government  Decree  495/2023  of  2  November  2023  (industrial  park), 
Government  Decree  502/2023  of  13  November  2023  (industrial  and  logistics  park),  Government  Decree 
555/2023 of 12 December 2023 (apartment building), Government Decree 577/2023 of 18 December 2023 
(university  campus),  Government  Decree  671/2023  of  29  December  2023  (shooting  range),  Government 
Decree 10/2024 of 25 January 2024 (truck parking and logistics centre).  

225  The  Constitutional  Court  has  dismissed  the  constitutional  complaints  challenging  Government  Decrees 
384/2016 of 2 December 2016 and 141/2018 of 27 July 2018 (Decision 3441/2022. (X. 28.) AB and case 
II/02785/2023). The Constitutional Court has rejected the constitutional complaints challenging Government 
Decree  141/2018  of  27  July  2018  (Orders  3264/2021.  (VII.  7.)  AB,  3299/2021.  (VII.  22.)  AB  and 
3300/2021.  (VII.  22.) AB),  Government  Decree  523/2021 of  6  September  2021  (3454/2022.  (X.  28.) AB) 
and Government Decree 314/2022 of 11 August 2022 (Order 3087/2024. (III. 1.) AB). On 17 July 2024, the 
Constitutional Court found that a provision of Government Decree 6/2022 of 14 January 2022, repealed as of 
1 August 2023, had been unconstitutional; it dismissed the remainder of the complaint. 

226   COM(2024)  617  final.  The Commission  has  launched  several  investigations  and  infringement  procedures 
against  Hungary,  many  concerning  legislation  in  fields  defined  by  the  Hungarian  Government  as  having 
strategic interest. For instance, the Commission has recently referred Hungary to the Court of Justice of the 
EU in two cases concerning restrictive Hungarian measures in the construction sector (cases C-499/23 and 
C-144/24)  and  is  actively  pursuing  cases  in  other  sectors,  including  public  procurement  and  motorway 
concessions.  Commission  services  are  also  closely  monitoring  the  situation  in  the  retail  sector  and  are 
carrying out investigations with regard to potential violations of EU law in this area. A pattern of instances 
where companies from elsewhere in the EU are effectively hindered in their economic activities in another 
Member State would constitute a major threat to the Single Market. 

227  Joint  contribution  from  Amnesty  International  Hungary  and  eight  other  CSOs  for  the  2024  Rule  of  Law 
Report,  p.  91.  The  Hungarian  Chamber  of  Commerce  and  Industry  –  a  public  body  set  up  by  law  –  has 
entered into a strategic cooperation with the Government and several Ministries and it has the opportunity to 
comment on draft legislation (information received in the context of the country visit to Hungary from the 
Hungarian Chamber of Commerce and Industry). 

228  The  Committee  on  Legislation  is  a  special  committee  whose  activities  are  specifically  related  to  the 
legislative functions of the National Assembly; it is chaired by the Deputy Speaker. As a rule, the Committee 
intervenes following the end of the detailed debate in plenary (Section 46(2) of the Rules of Procedure). 
229  Joint  contribution  from Amnesty  International  Hungary  and  eight  other  CSOs  for  the  2024  Rule  of  Law 
Report, p. 70; contribution from Eötvös Károly Policy Institute for the 2024 Rule of Law Report, p. 36. 

32 

 
 
making and the frequent changes in legislation remain a significant cause for concern about 
the effectiveness of investment protection among companies in Hungary230.  

Concerns regarding the independence and effective functioning of the Commissioner for 
Fundamental  Rights  remain.  The  UN  Sub-Committee  on  Accreditation  (SCA)  of  the 
Global  Alliance  of  NHRIs  (GANHRI)  has  not  revised  its  earlier  recommendation  that  the 
Hungarian  national  human  rights  institution  be  downgraded  to  B-status231.  Stakeholders 
reported  that  the  deficiencies  pointed  out  by  the  SCA  persist232.  In  December  2023,  the 
Deputy Commissioner organised a conference on vulnerable groups in the courtroom, with a 
special  focus  on  children  and  refugees233.  The  mandate  of  the  Commissioner  was 
significantly extended in 2023 with regard to the protection of persons with disabilities234, as 
well  as  whistleblower  protection235.  According  to  stakeholders,  the  trend236  to  merge  all 
specialised  human  right  protection  institutions  into  the  Commissioner’s  Office  could  be 
highly problematic due to not only the lack of functional independence of the Office, but also 
due  to  the  decreased  institutional  focus  and  resources  in  an  organisation  with  multiple 
mandates237. In that context, the Government refers to the Paris Principles238 that require that 

230  23%  of  the  surveyed  companies  perceive  the  frequent  changes  in  legislation  or  concerns  about  quality  of 
law-making  process  as  a  reason  for  the  lack  of  confidence  in  investment  protection  (Figure  56,  2024  EU 
Justice Scoreboard). 

231  The  SCA  found  that  the  Commissioner  for  Fundamental  Rights  ‘has  not  effectively  engaged  on  […]  all 
human rights issues, including in relation to vulnerable groups such as ethnic minorities, LGBTI, refugees 
and migrants as well as constitutional court cases deemed political and institutional, media pluralism, civic 
space and judicial independence (2022 Rule of Law Report, Country Chapter on the rule of law situation in 
Hungary, p. 27). 

232  Contribution from Hungarian Helsinki Committee for the 2024 Rule of Law Report, p. 40, joint contribution 
from Amnesty  International  Hungary  and  eight  other  CSOs  for  the  2024  Rule  of  Law  Report,  pp.  78-79. 
According to stakeholders, the rules of the selection and appointment process have not been amended, and 
respective  concerns  have  not  been  addressed.  The  publicly  available  information  on  the  Commissioner’s 
work evidences that it still does not effectively promote and protect all human rights and vulnerable groups. 
The Commissioner did not issue any public reports that dealt with the rights of LGBTIQ people or refugees 
and  migrants,  despite  the  wide-ranging  rights  violations  suffered  by  these  groups  in  Hungary,  and did  not 
focus  in  any  of  its  public  reports  on  the  situation  of  human  rights  defenders,  media  pluralism  or  judicial 
independence either. According to the Government, the Commissioner is independent in his or her actions, 
subject only to the law, and cannot be instructed in connection with his or her activities. 

233  In addition, in June and October 2023 and February, April and June 2024, the Commissioner participated at 
conferences  about  children’s  rights,  equal  treatment,  sustainable  development,  national  minorities  and  the 
role of ombudspersons. 

234  As  of  1  January  2023,  the  Commissioner  has  assumed  the  responsibilities  of  the  independent  mechanism 
defined  in  the  UN  Convention  on  the  Rights  of  Persons  with  Disabilities  (see  2023  Rule  of  Law  Report, 
Country Chapter on the rule of law situation in Hungary, p. 33). The Commissioner has set up a Disability 
Advisory  Board  for  the  close  cooperation  with  CSOs  and  the  performance  of  his  tasks  related  to  the 
independent disability mechanism (input from Hungary for the 2024 Rule of Law Report, p. 21). 

235  Input from Hungary for the 2024 Rule of Law Report, p. 21. Act XXV of 2023 on complaints, disclosures in 
of public interest and related rules on reporting abuses entered into force on 24 July 2023. The system run by 
the  Commissioner’s  Office  is  meant  to  be  the  external  reporting  channel  as  defined  in  Directive  (EU) 
2019/1937 of the European Parliament and of the Council of 23 October 2019 on the protection of persons 
who report breaches of Union law (the ‘Whistleblowing Directive’). 

236  Since 2015, the Commissioner has been tasked with the role of National Preventive Mechanism under the 
Optional Protocol to the UN Convention against Torture and other Cruel, Inhuman or Degrading Treatment 
or  Punishment.  In  2020,  the  Commissioner  took  over  the  responsibilities  of  the  Independent  Police 
Complaints Board. In 2021, the Equal Treatment Authority was merged into the Commissioner’s Office. 

237  Contribution from Hungarian Helsinki Committee for the 2024 Rule of Law Report, pp. 40-41. 
238  Principles  relating  to  the  Status  of  National  Institutions,  adopted  by  the  UN  General  Assembly  on  20 

December 1993. 

33 

 
 
national  institutions  possess  the  widest  possible  mandate  to  promote  and  protect  human 
rights. 

New rules rendered the judicial review of administrative decisions more difficult. As of 
1  January  2024,  a  public  authority  may  amend  or  repeal  its  administrative  decision  after 
receiving  an  application  seeking  judicial  review  but  before  transmitting  the  file  to  the 
court239. If the citizen or a business fails to contest the amended decision within eight days, 
the application for review becomes ineffective, and the authority is not obliged to transmit the 
file  to  the  court.  According  to  stakeholders240,  these  new  rules,  and  in  particular  the  tight 
deadline,  is  a  disincentive  for  citizens  and  businesses  to  seek  judicial  review,  which  raises 
issues  under  European  standards241..Also,  the  Court  of  Justice  of  the  EU  has  found  that 
national law preventing third-country nationals who, on the basis of confidential information 
obtained by the Constitution Protection Office, have had their residence permit withdrawn, or 
have been refused such a permit, from being informed even of the substance of the grounds 
forming the basis of those decisions and from using such information for the purposes of an 
administrative procedure or judicial proceedings violates EU law242. 

Concerns  persist  due  to  the  absence  of  effective  judicial  or  other  oversight  as  regards 
the use of secret surveillance measures outside criminal  proceedings. The 2023 Rule of 
Law Report noted that ‘[f]urther concerns [had] been raised due to the absence of effective 
oversight as regards the use of secret surveillance measures outside criminal proceedings’243. 
No steps have been taken to  address  these  concerns. Stakeholders note that  the excessively 
broad range of potential victims of surveillance may give rise to mass-surveillance244. On 13 
June 2024, the Council of Europe’s Committee of Ministers ‘strongly exhorted the authorities 
to  adopt,  without  further  delay,  the  measures  required  to  bring  the  domestic  legislation  on 
secret  surveillance  for  national  security  purposes  fully  and  effectively  in  line  with  the 
Convention  requirements’245.  Previous  reports  highlighted  that  journalists  and  other  media 
professionals have been targeted by spyware246. In spite of subsequent investigations into the 

239  Section 115(5) and (6) of Act CL of 2016 on general rules of administrative procedure and Section 83(7) and 
(6) of Act I of 2017 on the code of administrative litigation. Before this legislative amendment, the citizen or 
business could amend the application before the court within a fair and reasonable time limit (30 days). After 
the legislative amendment, the citizen or business is bound by a strict 8-day time limit before the file reaches 
the court. If the public authority decides not to file a defence with the court, it can amend its administrative 
decision to the detriment of the citizen or business (e.g. by increasing the amount of the administrative fine) 
at any point of time until the file is transmitted to the court or even until the end of the court proceedings. 
240  Contribution from Magistrats Européens pour la Démocratie et Libertés (MEDEL) for the 2024 Rule of Law 
Report, pp. 23-24; contribution from Res Iudicata Association for the 2024 Rule of Law Report, pp. 22-23. 
The  Hungarian  Chamber  of  Commerce  and  Industry  has  not  registered  any  questions,  comments  or 
complaints from its members as regards the judicial review of administrative decision (information received 
in the context of the country visit to Hungary from the Hungarian Chamber of Commerce and Industry). 
241  Judgments of the European Court of Human Rights of 27 February 1980, Deweer v Belgium, 6903/75 and of 

9 November 2004, Marpa Zeeland B.V and Metal Welding B.V. v Netherlands, 46300/99. 

242  See for EU law requirements judgment of the Court of Justice of 25 April 2024, NW and PQ, C‑420/22 and 

C‑528/22, ECLI:EU:C:2024:344, para. 101. 

243  See 2023 Rule of Law Report, Country Chapter on the rule of law situation in Hungary, p. 33. The execution 
of  judgments  of  the  European  Court  of  Human  Rights  of  12  January  2016,  Szabó  and  Vissy  v  Hungary, 
37138/14 and of 29 September 2022, Hüttl v Hungary, 58032/16 is pending. 

244  Joint  contribution  from Amnesty  International  Hungary  and  eight  other  CSOs  for  the  2024  Rule  of  Law 

Report, p. 61.  

245  CM/Del/Dec(2024)1501/H46-17. 
246  For details, see 2023 Rule of Law Report, Country Chapter on the rule of law situation in Hungary, p. 29. 

34 

 
 
matter,  there  were  no  consequences  for  individuals  or  entities  concerned,  nor  were  any 
legislative changes initiated247. In February 2024, Hungary signed with China a memorandum 
of  understanding  on  performing  joint  patrolling  services  which  allows  Chinese  police  to 
operate on the territory of Hungary248. 

The Constitutional  Court still reviews the merits of final  rulings of ordinary courts in 
politically sensitive cases. The 2023 Rule of Law Report noted that legal certainty had been 
improved  as  public  authorities  could  no  longer  challenge  final  judicial  decisions  before  the 
Constitutional  Court249.  The  Constitutional  Court,  composed  of  members  elected  by 
Parliament  without  the  involvement  of  the  judiciary,  is  still  reviewing  judgments  of  the 
ordinary courts acting as ‘a court of fourth instance’250. In several such cases, some of them 
politically  sensitive,  final  judgments  of  the  ordinary  courts  were  annulled251.  Stakeholders 
noted  that  the  Constitutional  Court  does  not  have  a  case  allocation  scheme  and  cases  are 
assigned  to  judges-rapporteurs  under  non-transparent  rules252.  Moreover,  although  the  law 
requires that the Constitutional Court render a decision on a constitutional complaint within a 
reasonable time, stakeholders noted that the Constitutional Court is not bound by procedural 
deadlines when hearing such cases253. As a rule, this domestic remedy needs to be exhausted 
before filing an application with the European Court of Human Rights254. As of 14 December 

247  Friedrich Naumann Foundation and International Press Institute (2024), Watching the Watchdogs – Spyware 

surveillance of journalists in Europe and the ongoing fight for accountability, pp. 12-14.  

248  Reuters  (2024),  In  unusual  move,  China  offers  to  back  Hungary  in  security  matters.  The  text  of  the 

agreement is not public.  

249  On 13 December 2023, the Commission positively assessed this legislative amendment under Article 15 of 

the Common Provisions Regulation. 

250  2022 Rule of Law Report, Country Chapter on the rule of law situation in Hungary, pp. 27-28. Normally, the 
Constitutional Court reviews the constitutionality of judicial decisions and  annuls them only if they violate 
fundamental  rights.  However,  in  certain  cases  the  Constitutional  Court  qualifies  the  contra  legem 
interpretation of the law by ordinary courts as a breach of the right to a fair trial, allowing the Constitutional 
Court  to  assess  the  merits  of  the  case  (see  Decision  20/2017.  (VII.  18.) AB,  paragraphs  23-30;  Decision 
23/2018. (XII. 28.) AB, paragraphs 26-30). 

251  Joint  contribution  from Amnesty  International  Hungary  and  eight  other  CSOs  for  the  2024  Rule  of  Law 
Report, p. 23. On 9 May 2023, the Constitutional Court annulled a  Kúria judgment that had dismissed the 
application  of  a  mayor  from  the  governing  party  brought  against  his  political  opponent  because  of  libel 
(Decision  3234/2023.  (VI.  2.) AB);  on  11  July  2023,  the  Constitutional  Court  annulled  a  judgment  of  the 
Győr Regional Court that had allowed a local referendum concerning the expansion of the Győr industrial 
zone  (Decision  16/2023.  (VII.  25.)  AB);  on  19  July  2023,  the  Constitutional  Court  annulled  two  Kúria 
judgments  that  had  allowed  a  national  referendum  on  questions  concerning  public  education  (Decisions 
20/2023. (VIII. 7.) AB and 21/2023. (VIII. 7.) AB); on 19 December 2023, the Constitutional Court annulled 
a Kúria judgment that had dismissed the application of a public interest trust headed by the Prime Minister’s 
political director brought against an opposition party for libel (2/2024. (I. 9.) AB); on 9 January 2024, the 
Constitutional  Court  annulled  two  Kúria  judgments  that  had  allowed  a  national  referendum  on  questions 
concerning  public  education  (Decisions  3/2024.  (I.  25.) AB  and  4/2024.  (I.  25.) AB);  on  5  July  2024,  the 
Constitutional Court annulled a Kúria decision  confirming the election of the opposition candidate  for the 
post of mayor of Budapest (case IV/02641/2024). 

252  Joint  contribution  from Amnesty  International  Hungary  and  eight  other  CSOs  for  the  2024  Rule  of  Law 

Report, p. 12. 

253  Joint  contribution  from Amnesty  International  Hungary  and  eight  other  CSOs  for  the  2024  Rule  of  Law 
Report, p. 23. For instance, on 9 May 2023, the Constitutional Court dismissed a constitutional complaint, 
filed  on  26  June  2013,  challenging  an  individual  judgment  in  a  freedom  of  information  case  (Decision 
3233/2023. (VI. 2.) AB). 

254  Decision  of  the  European  Court  of  Human  Rights  of 19  June  2018,  Mendrei  v.  Hungary,  54927/15, of  12 

March 2019, Szalontay v Hungary, 71327/13, and of 4 June 2019, Karsai v Hungary, 22172/14. 

35 

 
 
2023, an omnibus law255 inserted a new provision in the Constitutional Court Act256 allowing 
the Constitutional Court to give an advisory opinion – upon request of the Court of Justice of 
the  EU257  –  on  the  interpretation  of  the  rules  related  to  Hungary’s  constitutional  order, 
constitutional 
identity,  sovereignty, 
population, and rights and freedoms enshrined in the Fundamental Law.  

requirements,  constitutional 

traditions,  national 

On  1  January  2024,  Hungary  had  45  leading  judgments  of  the  European  Court  of 
Human  Rights  pending  implementation,  an  increase  of  two  compared  to  the  previous 
year258. Hungary’s rate of leading judgments from the past 10 years that remain pending is at 
76% (compared to 71% in 2023), which remains the highest in the EU, and the average time 
that  the  judgments  have  been  pending  implementation  is  over  6  years  and  2  months 
(compared to over 6 years and 8 months in 2023)259. The oldest leading judgment, pending 
implementation  for  almost  15  years,  concerns  the  violation  of  the  right  to  freedom  of 
assembly260. As regards the respect of payment deadlines, on 31 December 2023 there were 
47 cases in total awaiting confirmation of payments (compared to 82 in 2022)261. On 1 July 
2024, the number of leading judgments pending implementation had had increased to 47262. 
The  execution  of  the  judgments  of  the  European  Court  of  Human  Rights  in  the  Kenedi  v 
Hungary263 and Magyar Helsinki Bizottság v Hungary264 cases is still pending. Hungary also 
faces challenges as regards the effective implementation of judgments of the Court of Justice 
of the EU265. 

255  Act LXXXV of 2023. 
256  Section 38/A of Act CLI of 2011 on the Constitutional Court. 
257  EU law does not provide for such a request by the Court of Justice of the EU. 
258  The adoption of necessary execution measures for a  judgment by the European Court of Human Rights is 
supervised by the Council of Europe’s Committee of Ministers. It is the Committee’s practice to group cases 
against  a  State  requiring  similar  execution  measures,  particularly  general  measures,  and  examine  them 
jointly. The first case in the group is designated as the leading case as regards the supervision of the general 
measures and repetitive cases within the group can be closed when it is assessed that all possible individual 
measures  needed  to  provide  redress  to  the  applicant  have  been  taken.  According  to  the  Government,  it 
always  cooperates with the Committee of Ministers,  however  often complex measures need to be taken to 
execute the judgments. 

259  All figures are calculated by the European Implementation Network and are based on the number of cases 
that  are  considered  pending  at  the  annual  cut-off  date  of  1  January  2024.  See  the  Contribution  from  the 
European Implementation Network for the 2024 Rule of Law Report, p. 5. 

260  Judgment of the European Court of Human Rights of 7 October 2008, Patyi and Others v Hungary, 5529/05, 

pending implementation since 2009. 

261  Council  of  Europe  (2024),  Supervision  of  the  execution  of  judgments  decisions  of  the  European  Court  of 

Human Rights – 17th Annual Report of the Committee of Ministers – 2023, p. 137.   

262  Data according to the online database of the Council of Europe (HUDOC). 
263  Judgment of the European Court of Human Rights of 26 May 2009, Kenedi v Hungary, 31475/05. The Court 
found the violation of the applicant’s right to freedom of expression on account of the continued resistance 
of the authorities to grant him access to documents concerning the Hungarian secret services for the purpose 
of historical research and the lack of an effective remedy in this respect. 

264  Judgment  of  the  European  Court  of  Human  Rights  of  8  November  2016,  Magyar  Helsinki  Bizottság  v 
Hungary,  18030/11.  The  Court  found  the  violation  of  the  applicant’s  freedom  to  receive  information  on 
account of the authorities’ refusal, in 2009, to provide it with the names of public defenders and the number 
of their appointments for a survey on the efficiency of the public defenders system. 

265  On 24 April 2024, the Commission called on Hungary to fully comply with the ruling of the Court of Justice 
in  case  C-66/18  and  decided  to  send  a  letter  of  formal  notice  to  that  end.  Also  on  24  April  2024,  the 
Commission decided to send a letter of formal notice to Hungary for failing to comply with the ruling of the 
Court of Justice in case C-823/21. In another case, on 13 June 2024, the Court of Justice found that Hungary 
had  failed  to  take  all  the  necessary  measures  to  comply  with  the  judgment  delivered  by  the  Court  on  17 

36 

 
 
 
There  has  been  no  progress  in  removing  existing  obstacles  affecting  civil  society 
organisations,  while  new  legislation  further  undermined  civic  space.  The  2023  Rule  of 
Law Report recommended to Hungary to ‘[f]oster a safe and enabling civic space and remove 
obstacles affecting civil society organisations, including by repealing legislation that hampers 
their  capacity  of  working,  in  particular  the  immigration  tax’266.  While  the  overall  legal 
framework  for  CSOs267  did  not  change  in  2023  and  is  generally  in  line  with  European 
standards268, the space for civil society continues to be rated as ‘obstructed’269. Stakeholders 
reported that government-coordinated smear campaigns and vilification of independent CSOs 
remain a current practice270. The implementation of the law271, adopted in 2021 to repeal the 
Transparency Act272 in  line with  the judgment  of  the Court of  Justice273, is  pending274. The 
so-called  ‘child-protection  law’275,  amending,  among  others,  the  law  on  national  public 
education276,  authorises  the  responsible  minister  to  regulate  by  decree  the  conditions  of 
registration  for  CSOs  that  are  allowed  to  give  sex  education  classes  in  public  education 
institutions.  No  such  decree  has  been  issued  ever  since,  thereby  limiting  the  activity  of  the 
CSOs  concerned277.  As  of  1  January  2023,  in  response  to  a  judgment  of  the  Court  of 

December  2020  in  Case  C-808/18;  according  to  the  Court  of  Justice,  that  failure,  which  consists  in 
deliberately avoiding the application of a common EU policy as a whole, constitutes an unprecedented and 
extremely serious infringement of EU law. 

266  2023  Rule  of  Law  Report,  Country  Chapter  on  the  rule  of  law  situation  in  Hungary,  p.  2.  In  2023,  the 
Commission registered ‘[n]o progress on removing obstacles affecting civil society organisations’. See also 
2022 Rule of Law Report, Country Chapter on the rule of law situation in Hungary, p. 2. 

267  Including Act V of 2013 on the Civil Code and Act CLXV of 2011 on the Freedom of Association, Public 

Benefit Status and the Operation and Financing of Civil Society Organisations. 

268  Joint  contribution  from Amnesty  International  Hungary  and  eight  other  CSOs  for  the  2024  Rule  of  Law 

Report, p. 86. 

269  Rating by CIVICUS; ratings are on a five-category scale defined as: open, narrowed, obstructed, repressed 

and closed. 

270  Joint  contribution  from Amnesty  International  Hungary  and  eight  other  CSOs  for  the  2024  Rule  of  Law 

Report, p. 69; contribution from Human Rights Watch for the 2024 Rule of Law Report, p. 20. 

271  Act XLIX of 2021; an application seeking the review of the law is pending before the Constitutional Court 

(Case IV/05049/2021). 

272  Act LXXVI of 2017 on the transparency of organisations which receive support from abroad. 
273  Judgment of the Court of Justice of 18 June 2020,  Commission v Hungary (Transparency of associations), 

C-78/18, ECLI:EU:C:2020:476. 

274  Under the new rules, in May 2022, the State Audit Office carried out legality checks on all accounts of CSOs 
with an annual balance sheet exceeding a certain amount and, therefore, considered capable of influencing 
public life. The Summary Report published by the State Audit Office on 2 December 2022 announced that 
the rules governing both the selection criteria and the methodology for the assessment would be reviewed. 
The audit of the financial management of CSOs is included in the 2024 audit plan of the State Audit Office 
(information received in the context of the country visit to Hungary from the State Audit Office).  

275  Act  LXXIX  of  2021  on  stricter  action  against  paedophile  offenders  and  amending  certain  acts  for  the 
protection  of  children  lays  down  a  number  of  restrictive  and  discriminatory  measures;  in  particular,  it 
prohibits or limits access to content that propagates or portrays the so-called ‘divergence from self-identity 
corresponding  to  sex  at  birth,  sex  change  or  homosexuality’  for  individuals  under  the  age  of  18.  The 
Commission considered that the law violates the internal market rules, the fundamental rights of individuals 
(in particular LGBTIQ people) as well as - with regard to those fundamental rights  - the EU values; on 15 
July 2022, the Commission decided to refer Hungary to the Court of Justice (case C-769/22, pending). 

276  Act CXC of 2011 on national public education. 
277  2023  Rule  of  Law  Report,  Country  Chapter  on  the  rule  of  law  situation  in  Hungary,  p.  36.  The  Media 
Authority,  relying  on  the  so-called  ‘child-protection  law’,  decided  that  the  official  campaign  video  of  the 
28th  Budapest  Pride  festival  may  be  aired  by  a  commercial TV  channel  between  10  p.m.  and  5  a.m  only 
(Decision 496/2023 of 4 July 2023). 

37 

 
 
Justice278, Hungary amended its legislation which criminalised the organisation of activities 
carried out with a view to assisting the initiation of applications for international protection 
that do not fulfil the national criteria for granting that protection. Another law279 introducing a 
special  25%  immigration  tax  applicable  to  financial  support  received  by  organisations 
carrying  out  ‘activities  facilitating  immigration’,  which  also  raised  concerns,  continues  to 
apply, although it is not enforced in practice280. On 12 December 2023, Parliament adopted 
the Protection of National Sovereignty Act281; it establishes a new office with broadly defined 
competences tasked with reporting on any person or organisation suspected of serving foreign 
interests  and/or  receiving  foreign  funding.  Independent  media  outlets  issued  a  statement 
warning that the new law is ‘capable of severely restricting the freedom of the press’282. In 
June 2024, the new office launched investigations into the activities and funding of an anti-
corruption CSO and an investigative media outlet283. The new law also amended the political 
party and campaign finance  rules without public consultation. Therefore, there has been no 
progress on the recommendation made in the 2023 Rule of Law Report.  

Concerns related to the State’s role in financing civil society persist. Overall, 40% of civil 
society’s  resources  come  from  public  funding284.  Stakeholders  report  that  this  income  is 
distributed unevenly285, and that the operation of state funding for CSOs is non-transparent286. 

278  The Court of Justice has held that Section 353/A of Act C of 2012, introduced by Section 11(1) of Act VI of 
2018 (part of the so-called ‘Stop Soros’ legislative package) breached Union law, see judgment of the Court 
of Justice of 16 November 2021, Commission v Hungary (Incrimination de l’aide aux demandeurs d’asile), 
C-821/19, ECLI:EU:C:2021:930. 
279  Section 253 of Act XLI of 2018. 
280  Joint  contribution  from Amnesty  International  Hungary  and  eight  other  CSOs  for  the  2024  Rule  of  Law 

Report, p. 69. 

281  Act  LXXXVIII  of  2023  on  the  protection  of  national  sovereignty.  On  7  February  2024,  the  Commission 
decided  to  launch  infringement  proceedings  against  Hungary;  on  23  May  2024,  the  Commission  sent  a 
reasoned opinion. On 18 March 2024, the Venice Commission concluded that the Act has established a new 
body with extremely broad competences which can interfere with the privacy of any legal or natural entity 
and engage in naming and shaming of this entity without being subject to any control or review mechanism; 
it risks having a chilling effect on the free and democratic discussion in the Hungarian society; the regulation 
related to the establishment of the Sovereignty Protection Office and its mandate and competencies is at odds 
with international standards and should be repealed (Venice Commission, CDL(2024)002, para. 65). 

282  Contribution  from  International  Press  Institute  for  the  2024  Rule  of  Law  Report,  p.  16;  contribution  from 
Mérték  Media  Monitor  for  the  2024  Rule  of  Law  Report,  p.  21;  contribution  from  Reporters  Without 
Borders for the 2024 Rule of Law Report, p. 17. See also Friedrich Naumann Foundation and International 
Press  Institute  (2024),  Watching  the  Watchdogs  –  Spyware  surveillance  of  journalists  in  Europe  and  the 
ongoing fight for accountability, p. 14. 

283  Telex (2024), Transparency International and Átlátszó became the first targets of the Sovereignty Protection 
Office;  Transparency  International  Hungary  (2024),  Press  statement:  Hungary’s  Sovereignty  Protection 
Office targets Transparency International Hungary with investigation. 

284  The  total income of associations and foundations in 2022 was HUF 1 270 billion (EUR 3.2 billion), more 
than the year before (HUF 1 070 billion; EUR 2.7 billion). Of this, some  40% came from public funding, 
25%  from  private  sources,  with  the  rest  originating  from  generated  own  income  and  a  variety  of  other 
sources (joint contribution from Amnesty International Hungary and eight other CSOs for the 2024 Rule of 
Law Report, p. 89). 

285  68.5% of the CSOs work with an annual budget of not more than HUF 5 million (EUR 12 644), and only 8% 
have  income  larger  than  HUF  50  million  (EUR  126 444),  with  the  average  per  organisation  being  around 
HUF  25  million  (EUR  63 222).  Independent  organisations  promoting  human  rights  and  similar  issues  and 
independent theatres rarely are able to secure public funding (joint contribution from Amnesty International 
Hungary and eight other CSOs for the 2024 Rule of Law Report, pp. 89-90). 

286  Joint  contribution  from Amnesty  International  Hungary  and  eight  other  CSOs  for  the  2024  Rule  of  Law 

Report, p. 90; contribution from Ökotárs for the 2024 Rule of Law Report, p. 22. 

38 

 
 
Funding  earmarked  for  civil  society  is  often  absorbed  by  organisations  affiliated  with  the 
governing parties287. Also in this respect, no progress has been made on the implementation 
of the recommendation made in the previous years to remove obstacles affecting CSOs. The 
increasing lack of state funding is to some extent offset by the growing amount of individual 
donations288.  Cutting  off  CSOs  from  public  funding  increases  their  dependence  on 
crowdsourcing tools and on philanthropies and donors from abroad289. 

There  is  little  room  for  CSOs  and  human  rights  defenders  to  engage  effectively  with 
public  institutions  on  issues  of  significant  societal  impact.  The  involvement  of  local 
communities  in  debates  related  to  investment  projects  (e.g.  vehicle  battery  factories),  has 
been  limited  through  legislation290.  The  Government  continued  the  practice  of  ‘national 
consultation’291. Independent CSOs can participate in the monitoring committees that oversee 
the spending of EU funds at national level and in the Anti-Corruption Task Force292. 

287  The  central  state  support  instrument  to  CSOs,  the  National  Cooperation  Fund  provides  grants  annually  to 
some 4 000 organisations with a total budget of HUF 13.9 billion (EUR 35 151 607) in 2024. According to 
the  Government,  the  evaluation  of  applications  and  the  monitoring  of  the  attainment  of  the  objectives 
supported are carried out by five committees, each consisting of nine members, some of whom are elected 
by  CSOs  themselves. Additionally,  the  Village  and  Town  Civil  Funds  (for  CSOs  operating  in  settlements 
under  and over  5 000  inhabitants,  respectively)  each  distributed  HUF 5 billion (EUR  12 644 000). A  large 
part of the Hungarian civil society sector is not eligible for funding by the National Cooperation Fund which 
actively  promotes  government  agendas  (European  Commission:  Civil  Society  Landscape  in  the  European 
Union  -  Research  in  support  of  the  Citizens,  Equality,  Rights  and  Values  (CERV)  Programme,  p.  19). A 
specific  provision  of  the  Public  Finances Act  (Section  111(9)  CXCV  of  2011,  in  fine)  allows  the  funding 
through  the Town  Civil  Fund  of  CSOs  that  stand  elections  (see  K-Monitor  (2024),  According  to  the State 
Audit Office, the Prime Minister’s Office lawfully awards public funds to organisations that stand elections). 
According to media reports, 251 (87%) of the organisations awarded at least HUF 15 million (EUR 37 933) 
from the Town Civil Fund in 2021, 2022 and 2024 were affiliated with the governing party (Válasz Online 
(2024),  Fidesz  has  built  a  gigantic  network  of  GONGOs  for  the  elections  –  several  little  ‘Szilárd  Németh’ 
can jump into action).  

288  In 2023, both the amount collected from the assignment of 1% of personal income tax (a scheme available 
since  1997)  and  the  number  of  taxpayers  using  this  option  grew  significantly,  by  approximately  26% 
compared  to  2022  (with  a  total  amount  HUF  15.3  billion  –  EUR  38 692 057  –  offered  by  1.8  million 
taxpayers). At the same time, tax incentives for donations remain meagre: there are no tax benefits at all for 
private persons after their donations, and companies may decrease their corporate tax base with 20% of the 
donation, but only in case of CSOs with public benefit status (21% of all organisations) (joint contribution 
from Amnesty International Hungary and eight other CSOs for the 2024 Rule of Law Report, p. 90). 

289  In  2023,  important  new  opportunities  opened  thanks  to  the  EU’s  Citizens,  Equality,  Rights  and  Values 
(CERV)  program  and  USAID’s  Central  Europe  program  (joint  contribution  from  Amnesty  International 
Hungary and eight other CSOs for the 2024 Rule of Law Report, p. 90; contribution from Ökotárs for the 
2024 Rule of Law Report, p. 22). 

290  Between April and December 2023, an emergency measure (Government Decree 146/2023 of 27 April 2023) 
allowed  that  townhall  meetings  discussing  local  matters  be  held  solely  via  electronic  means  of 
communication.  Also,  on  23  May  2024,  the  European  Commission  decided  to  open  an  infringement 
procedure by sending a letter of formal notice to Hungary (INFR(2024)2011) for failing to fully implement 
the  requirements  of  the  Convention  on  access  to  information,  public  participation  in  decision-making  and 
access to justice in environmental matters (Aarhus Convention). According to the European Commission, in 
its  national  legislation,  Hungary  does  not  ensure  the  right  to  challenge  before  a  court  all  decisions  or 
omissions  of  national  authorities  in  the  following  environmental  policy  areas:  nature  protection,  water 
management, air quality, waste management, industrial emissions, and noise protection. 

291  The  ‘national  consultation’  is  a  tool  consisting  of  letters  sent  directly  to  every  Hungarian  household  ‘on 
behalf  of  the  Government  of  Hungary’,  accompanied  by  questionnaires  allowing  the  citizens  to  submit 
answers to sets of questions formulated by the Government and supported by a countrywide billboard and 

39 

 
 
 
Annex I: List of sources in alphabetical order* 

* The list of contributions received in the context of the consultation for the 2024 Rule of Law report 
can 
https://commission.europa.eu/publications/2024-rule-law-report-targeted-
stakeholder-consultation_en 

found 

be 

at 

24.hu  (2024),  Ministerial  fortunes  may  remain  invisible  as  a  result  of  a  government  decision 
(Miniszteri  vagyonok  maradhatnak  láthatatlanok  egy  kormányhatározatnak  köszönhetően)  (15 
January 
https://24.hu/belfold/2024/01/15/miniszteri-vagyonok-kormanyhatarozat-bizalmi-
2024), 
vagyonkezelok/.  

24.hu  (2024),  The  prosecution  service  would  send  to  prison  Mihály  Varga’s  former  deputy  state 
secretary  and  László  Palkovics’  confidant  (Varga  Mihály  volt  helyettes  államtitkárát  és  Palkovics 
2024), 
László 
https://24.hu/kozelet/2024/04/09/varga-mihaly-penzugyminiszterium-volt-helyettes-allamtitkar-
karsai-tamas-palkovics-laszlo-barta-eke-gyula-korrupcio-eu-palyazat-kenopenz-vesztegetes-borton-
vadirat/. 

ügyészség) 

bizalmasát 

börtönbe 

zárná 

April 

az 

(9 

is 

Amnesty International Hungary, Eötvös Károly Institute, Hungarian Civil Liberties Union, Hungarian 
Helsinki  Committee,  K-Monitor,  Mérték  Media  Monitor,  Ökotárs,  Political  Capital,  Transparency 
International Hungary (2024), Joint contribution for the 2024 Rule of Law Report. 

the  Anti-Corruption  Task  Force 
Anti-Corruption  Task  Force 
https://kemcs.hu/wp-content/uploads/2023/06/Korrupcioellenes-Munkacsoport-2022-evre-vonatkozo-
jelentese.pdf.  

(2023),  2022  Report  of 

Anti-Corruption Task Force (2023), Complementary Report on the draft medium-term National Anti-
https://kemcs.hu/wp-
Strategy 
Corruption 
content/uploads/2023/06/Kiegeszito_jelentes_NKS.pdf.  

2023-2025 

for 

Átlátszó (2020), Corruption info: hundreds of millions of euros in EU funding for the company of the 
son  of  the  minister  responsible  for  the  Paks  investment  (Korrupcióinfó:  több  százmilliós  uniós 
támogatás 
(23  April  2020), 
felelős  miniszter 
https://atlatszo.hu/kozugy/2020/04/23/korrupcioinfo-tobb-szazmillios-unios-tamogatas-a-paksi-
beruhazasert-felelos-miniszter-fia-cegenek/.  

a  paksi  beruházásért 

cégének) 

fia 

Átlátszó (2023), We identified the companies that have won hundreds of public contracts in a single 
city  (16  February  2023),  https://english.atlatszo.hu/2023/02/16/we-identified-the-companies-that-
have-won-hundreds-of-public-contracts-in-a-single-city/. 

Átlátszó  (2024),  Átlátszó,  K-Monitor  and  Transparency  have  not  accepted  the  annual  report  of  the 
Anti-Corruption  Working  Group  (18  March  2024),  https://english.atlatszo.hu/2024/03/18/atlatszo-k-
monitor-and-transparency-have-not-accepted-the-annual-report-of-the-anti-corruption-working-
group/. 

Bertelsmann  Stiftung  (2024),  Transformation  Index:  Hungary  Country  Report  https://bti-
project.org/en/reports/country-report/HUN?cHash=16802a21c33eab84edaf76f4d2c323fe. 

media campaign. The ‘national consultation’ organised between November 2023 and January 2024, focused 
on the presumed impact of various EU policies on Hungary’s national sovereignty. 

292  Joint  contribution  from Amnesty  International  Hungary  and  eight  other  CSOs  for  the  2024  Rule  of  Law 
Report,  p.  92. According  to  stakeholders,  the  application  of  Háttér  Society  (an  LGBTIQ  organisation)  to 
participate in a monitoring committee was arbitrarily rejected (contribution from Háttér Society for the 2024 
Rule  of  Law  Report,  p.  12;  contribution  from  ILGA-Europe  for  the  2024  Rule  of  Law  Report,  p.  29). 
According to the Government, any CSOs can present their own views in the process of public consultation 
on draft laws. 

40 

 
 
Bloomberg  (2024),  Hungary  Clamps  Down  on  Orban’s  Opponents  with  Hefty  Fine  (20  February 
2024) 
https://www.bloomberg.com/news/articles/2024-02-20/opposition-deprived-of-funding-as-
orban-clamps-down-with-hefty-fine.  

Budapest Institute (2022), Open letter announcing withdrawal from participation in the activities of 
2022), 
the 
https://www.budapestinstitute.eu/uploads/IH_MCS_level_2023.pdf. 

Anti-Corruption 

(19  May 

Authority’s 

Integrity 

Force 

Task 

Centre for Media Pluralism and Media Freedom (2023),  Monitoring Media Pluralism in the Digital 
Era in the year 2022, Country report: Hungary. 

Civicus, Monitor tracking civic space – Hungary https://monitor.civicus.org/country/hungary/. 

Corruption  Research  Center  Budapest  (2023),  White  Elephants  in  Hungary  –  Lessons  of  some  EU 
https://www.crcb.eu/wp-
(29 
funded 
content/uploads/2023/01/2023_research_notes_01_230129_01.pdf. 

projects 

January 

2023), 

Corruption Research Center Budapest (2023), Fourteen Graphs and Two Tables on the New Trends of 
Corruption  Risk 
(7  February  2023), 
the  Hungarian  Public  Procurement  2005-2022 
https://www.crcb.eu/wp-
content/uploads/2023/02/2023_crcb_statistical_quick_report_230207_01.pdf. 

in 

Corruption Research Center Budapest (2023), The new trends of corruption risks in Hungarian public 
procurement (17 October 2023), https://www.crcb.eu/?p=3450.  

Corruption  Research  Center  Budapest  (2024),  Two  Communication  Companies  in  the  Hungarian 
Public  Procurement  Market 
http://www.crcb.eu/wp-
content/uploads/2024/02/2024_research_notes_01_190224_03.pdf. 

(19  February 

2012-2023 

2024), 

Council  of  Bars  and  Law  Societies  of  Europe  (2024),  Contribution  from  Council  of  Bars  and  Law 
Societies of Europe for the 2024 Rule of Law Report. 

Council of Europe: Commissioner for Human Rights (2023), Hungary: The proposal for a ‘defence of 
national 
2023) 
(27  November 
should 
https://www.coe.int/ca/web/commissioner/-/hungary-the-proposal-for-a-defence-of-national-
sovereignty-package-should-be-abandoned.  

sovereignty’ 

abandoned 

package 

be 

Council of Europe (2023), Hungary: anti-corruption group calls for measures to prevent corruption 
in  central  government  and  law  enforcement  (9  June  2023)  https://www.coe.int/en/web/portal/-
/hungary-anti-corruption-group-calls-for-measures-to-prevent-corruption-in-central-government-and-
law-enforcement.  

Council of Europe (2024), Supervision of the execution of judgments decisions of the European Court 
of  Human  Rights  –  17th  Annual  Report  of 
the  Committee  of  Ministers  –  2023 
https://edoc.coe.int/en/module/ec_addformat/download?cle=a73d18446f20a30be28c26ab513da8d8&
k=af860e1889bc86177636bda12d13da47. 

Council  of  Europe,  Platform  to  promote  the  protection  of  journalism  and  safety  of  journalists  – 
Hungary, https://fom.coe.int/en/pays/detail/11709524. 

Court of Justice of the European Union, judgment of 16 November 2021  WB and others, C-748/19 
and others, ECLI:EU:C:2021:931. 

Court  of  Justice  of  the  European  Union,  judgment  of  18  June  2020,  Commission  v  Hungary 
(Transparency of associations), C-78/18, ECLI:EU:C:2020:476. 

Court  of  Justice  of  the  European  Union,  judgment  of  16  November  2021,  Commission  v  Hungary 
(Incrimination de l’aide aux demandeurs d’asile), C-821/19), ECLI:EU:C:2021:930. 

Court  of  Justice  of  the  European  Union,  judgment  of  11  January  2024,  Global  Ink  Trade  Kft.,  C-
537/22, ECLI:EU:C:2024:6. 

41 

 
Democracy Reporting International (2024), Contribution from Democracy Reporting International for 
the 2024 Rule of Law Report. 

Eötvös Károly Policy Institute (2024), Contribution from Eötvös Károly Policy Institute for the 2024 
Rule of Law Report. 

European  Anti-Fraud  Office 
fraud.ec.europa.eu/about-us/reports/annual-olaf-reports_en.  

(OLAF) 

(2024),  Annual  Report 

2023 

https://anti-

European  Association  of  Judges  (2024),  Contribution  from  European  Association  of  Judges  for  the 
2024 Rule of Law Report. 

European  Association  of  Judges  (2024),  Resolution  on  Judicial  Remuneration  in  Hungary 
https://www.iaj-uim.org/iuw/wp-content/uploads/2024/04/EAJ-Resolution-Hungary.pdf. 

European Commission (2022), 2022 EU Justice Scoreboard. 

European Commission (2022), 2022 Rule of Law Report, Country Chapter on the rule of law situation 
in Hungary. 

European  Commission  (2023),  HICP  all-items  —  annual  average  inflation  rates,  2013-2022 
https://ec.europa.eu/eurostat/statistics-explained/index.php?title=File:HICP_all-
items_%E2%80%94_annual_average_inflation_rates,_2013-2022(%25).png. 

European Commission (2023), 2023 Rule of Law Report, Country Chapter on the rule of law situation 
in Hungary. 

the 

Citizens, 

European Commission (2023), Civil Society Landscape in the European Union - Research in support 
of 
Programme 
https://op.europa.eu/en/publicationdetail/-/publication/5eb1a213-c14f-11ed-8912-
01aa75ed71a1/language-en 
11ed-8912-01aa75ed71a1/language-en. 

https://op.europa.eu/en/publicationdetail/-/publication/5eb1a213-c14f-

Equality, 

(CERV) 

Values 

Rights 

and 

European Commission (2023), Commission Decision of 13 December 2023 on the reassessment, on 
the  Commission’s  initiative,  of  the  fulfilment  of  the  conditions  under  Article  4  of  Regulation  (EU, 
Euratom) 2020/2092 following Council Implementing Decision (EU) 2022/2506 of 15 December 2022 
regarding 
https://commission.europa.eu/document/83f08b3a-bf4a-4462-a361-
88d44692452b_en.  

Hungary 

European Commission (2024), 2024 EU Justice Scoreboard. 

European  Commission  (2024),  Economic  forecast  for  Hungary,  last  update  (15/02/2024),  Winter 
2024  Economic  Forecast:  A  delayed  rebound  in  growth  amid  faster  easing  of  inflation 
https://economy-finance.ec.europa.eu/economic-surveillance-eu-economies/hungary/economic-
forecast-hungary_enhttps://economy-finance.ec.europa.eu/economic-surveillance-eu-
economies/hungary/economic-forecast-hungary_en. 

European Commission (2024), The Single Market and Competitiveness Scoreboard, Country Report: 
Hungary, https://single-market-scoreboard.ec.europa.eu/countries/hungary_en. 

European Commission (2024), 2024 Country Report Hungary, SWD(2024) 617 final.  

European Court of Human Rights, judgment of 27 February 1980, Deweer v Belgium, 6903/75. 

European  Court  of  Human  Rights,  judgment  of  9  November  2004,  Marpa  Zeeland  B.V  and  Metal 
Welding B.V. v Netherlands, 46300/99. 

European  Court  of  Human  Rights,  judgment  of  7  October  2008,  Patyi  and  Others  v  Hungary, 
5529/05. 

European Court of Human Rights, judgment of 26 May 2009, Kenedi v Hungary, 31475/05. 

European Court of Human Rights, judgment of 16 July 2015, Gazsó v Hungary, 48322/12. 

42 

 
European  Court  of  Human  Rights,  judgment  of  12  January  2016,  Szabó  and  Vissy  v  Hungary, 
37138/14. 

European Court of Human Rights, judgment of 23 June 2016, Baka v Hungary, 20261/12. 

European  Court  of  Human  Rights,  judgment  of  8  November  2016,  Magyar  Helsinki  Bizottság  v 
Hungary, 18030/11. 

European Court of Human Rights, decision of 19 June 2018, Mendrei v. Hungary, 54927/15. 

European Court of Human Rights, decision of 12 March 2019, Szalontay v Hungary, 71327/13. 

European Court of Human Rights, decision of 4 June 2019, Karsai v Hungary, 22172/14. 

European Court of Human Rights, judgment of 29 September 2022, Hüttl v Hungary, 58032/16. 

European Implementation Network (2024), Contribution from the European Implementation Network 
for the 2024 Rule of Law Report. 

European Parliament: Flash Eurobarometer: News & Media Survey 2023. 

Forbes  (2024),  Here  is  another  25  billion  forint  government  corruption  scandal:  dozens  of  Mihály 
Varga’s  former  subordinates  are  involved  (Itt  az  újabb,  25  milliárdos  kormányzati  korrupciós 
botrány: Varga Mihály tucatnyi volt beosztottja érintett) (9 April 2024), https://forbes.hu/uzlet/varga-
mihaly-miniszterium-korrupcio-vad-ugyeszseg/.  

Friedrich  Naumann  Foundation  and  International  Press  Institute  (2024),  Watching  the  Watchdogs  – 
Spyware  surveillance  of 
for  accountability 
in  Europe  and 
https://shop.freiheit.org/download/P2@1698/832928/A4%20Brosch%C3%BCre%20Watching%20the
%20watchdogs_ENG_online.pdf. 

the  ongoing 

journalists 

fight 

GRECO (2019), Third Evaluation Round – Second Addendum to the Second Compliance Report on 
Hungary  on 
(1  August  2019) 
https://rm.coe.int/third-evaluation-round-second-addendum-to-the-second-compliance-
report/168096947e. 

transparency  of  party 

incriminations  and 

funding 

GRECO  (2023),  Fourth  Evaluation  Round  –  Fourth  Interim  Compliance  Report  on  Hungary  on 
corruption  prevention  in  respect  of  members  of  parliament,  judges  and  prosecutors  (9  June  2023) 
https://rm.coe.int/fourth-evaluation-round-corruption-prevention-in-respect-of-members-
of/1680ab87f1. 

GRECO (2023), Fifth Evaluation Round – Evaluation Report on Hungary on preventing corruption 
and  promoting  integrity  in  central  governments  (top  executive  functions)  and  law  enforcement 
agencies 
https://rm.coe.int/fifth-evaluation-round-preventing-corruption-and-
promoting-integrity-i/1680ab87f5. 

2023) 

June 

(9 

Hadházy, 
https://www.facebook.com/hadhazyakos/posts/946406733514288?ref=embed_post. 

Facebook 

(2024), 

Ákos 

post 

29 

of 

January 

2024 

Háttér Society (2024), Contribution from Háttér Society for the 2024 Rule of Law Report. 

Human  Rights  Watch  (2024),  Contribution  from  Human  Rights  Watch  for  the  2024  Rule  of  Law 
Report. 

Human Rights Watch (2024), ‘I Can’t Do My Job as a Journalist’ – The Systematic Undermining of 
Media  Freedom  in  Hungary  (13  February  2024)  https://www.hrw.org/report/2024/02/13/i-cant-do-
my-job-journalist/systematic-undermining-media-freedom-hungary. 

Hungarian Association of Judges (2024), Contribution from the Hungarian Association of Judges for 
the 2024 Rule of Law Report. 

Hungarian Civil Liberties Union (2024), Contribution from Hungarian Civil Liberties Union for the 
2024 Rule of Law Report. 

43 

 
Hungarian Government (2023),  The Government’s positions as regards the findings of the Integrity 
Authority’s 
2023) 
https://integritashatosag.hu/wp-content/uploads/2023/10/int-hat-2022jelentes-korm-valasz.pdf.  

September 

analytical 

integrity 

annual 

report 

2022 

(29 

Hungarian Government (2024), Input from Hungary for the 2024 Rule of Law Report. 

Hungarian  Helsinki  Committee  (2024),  Contribution  from  Hungarian  Helsinki  Committee  for  the 
2024 Rule of Law Report. 

ILGA-Europe (2024), Contribution from ILGA-Europe for the 2024 Rule of Law Report. 

(2023), 

Integrity  Authority 
https://integritashatosag.hu/wp-
content/uploads/2023/06/Integritas_Hatosag_Eves_Elemzo_Integritasjelentes_20220629.pdf 
https://integritashatosag.hu/wp-content/uploads/2023/10/Annual-Analytical-Integrity-Report-2022-
ENG.pdf.  

Analytical 

Annual 

Report 

2022 

June 

(29 

2023) 

Integrity  Authority 
https://integritashatosag.hu/wp-
content/uploads/2023/12/Integritas_Hatosag_Vagyonnyilatkozatok_Eseti_Jelentes_2023-1.pdf.  

(2023),  Ad-hoc  report  on  asset  declarations 

(7  December  2023) 

Integrity Authority (2023), The position of the Integrity Authority regarding the Government’s answer 
(14 
https://integritashatosag.hu/wp-
2023) 
content/uploads/2023/12/Integritas_Hatosag_osszegzes_Kormanyvalaszokra_20231206.pdf. 

December 

Integrity  Authority  (2024),  Conclusion  of  inquiry  III_86_2023  –  modernisation  of  cattle  farm  (21 
February 2024) https://integritashatosag.hu/case/iii_86_2023-sz-vizsgalat-lezarasa-szarvasmarhatelep-
korszerusitese/.  

Integrity Authority (2024),  Annual Report to the Hungarian National Assembly 2023 (March 2023) 
https://integritashatosag.hu/wp-content/uploads/2024/03/integrity-authority-annual-report-2023.pdf.  

Intellinews  (2023),  Hungary’s  highest-profile  corruption  case  lifts  the  veil  on  how  Orban’s  regime 
really  operates 
(20  February  2023)  https://www.intellinews.com/hungary-s-highest-profile-
corruption-case-lifts-the-veil-on-how-orban-s-regime-really-operates-270456/.  

Intellinews  (2024),  Hungarian  State  Audit  Office  fines  opposition  parties  for  alleged  foreign 
campaign finance (21 February 2024) https://www.intellinews.com/hungarian-state-audit-office-fines-
opposition-parties-for-alleged-foreign-campaign-financing-313363/. 

International Press Institute (2024), Contribution from International Press Institute for the 2024 Rule 
of Law Report. 

K-Monitor  (2023),  Hungarian  MP’s  Assets:  Less  Declared  and  Still  not  Monitored  (15  February 
2023) https://k.blog.hu/2023/02/15/hungarian_mp_s_assets_less_declared_and_still_not_monitored.  

K-Monitor (2023), Anti-Corruption Task Force: what is the situation eight months after its launch? 
(28 
https://k.blog.hu/2023/09/28/anti-
2023) 
corruption_task_force_what_is_the_situation_eight_months_after_its_launch?utm_medium=doboz&
utm_campaign=bloghu_cimlap&utm_source=nagyvilag. 

September 

the 
K-Monitor 
https://drive.google.com/drive/u/0/folders/1GwyaWR3pv2u-78gU2C8N9bfu_Qzs9yl_.  

Information 

(2023), 

Report 

Access 

on 

to 

(December 

2023) 

K-Monitor (2023), Anti-corruption criminal procedure reform: the rules are there, but the practice is 
unchanged (15 December 2023), https://k.blog.hu/2023/12/15/antikorrupcios_buntetoeljarasi_reform. 

K-Monitor (2024), According to the State Audit Office, the Prime Minister’s Office lawfully awards 
public 
2024), 
https://k.blog.hu/2024/03/25/asz_jogszeru_hogy_a_miniszterelnokseg_valasztason_indulo_szervezete
knek_oszt_kozpenzt.  

(24  March 

organisations 

elections 

stand 

funds 

that 

to 

44 

 
K-Monitor  and  Transparency  International  Hungary  (2023),  Letter  to  the  European  Commission, 
Possible infringements of Directive 2019/1937 on the protection of persons who report breaches of 
Union  law  by  the  Hungarian  Government  (21  December  2023),  https://transparency.hu/wp-
content/uploads/2024/01/K-Monitor_Transparency-Int-
HU_letter_to_COM_on_transposition_of_whistleblower_directive_21122023.pdf.  

K-Monitor  and  Transparency  International  Hungary  (2024),  Special  report  on  the  2023  Anti-
Corruption Task Force Report: Current issues in the fight against corruption in Hungary (14 March 
2024), 
https://transparency.hu/wp-
content/uploads/2024/03/KEMCS_2023_civil_kulonjelentes_final.pdf.  

Kovács,  Ágnes  (2023),  Taking  Revenge  for  Dissent:  Hungary’s  Chief  Justice  to  Fully  Eliminate 
Judicial  Autonomy,  VerfBlog  (13  December  2023),  https://verfassungsblog.de/taking-revenge-for-
dissent/. 

Kúria (2024), Contribution from the Kúria for the 2024 Rule of Law Report. 

Lakmusz (2024), How does anyone who is not a friend of Fidesz become a ‘leftist’? (5 April 2024), 
https://www.lakmusz.hu/hogy-lesz-barkibol-baloldali-aki-nem-a-fidesz-baratja-2/.  

Magistrats Européens pour la Démocratie et Libertés (MEDEL) (2024), Contribution from Magistrats 
Européens pour la Démocratie et Libertés (MEDEL) for the 2024 Rule of Law Report.  

Magyar Hang (2024), 54 people indicted in corruption case involving the Ministry of Finance and the 
Prime Minister’s Office (54 fő ellen emeltek vádat a Pénzügyminisztériumot és a Miniszterelnökséget 
érintő  korrupciós  ügyben)  (9  April  2024),  https://hang.hu/belfold/penzugyminiszterium-ugyeszseg-
miniszterelnokseg-vadirat-korrupcio-163101. 

Mérték Media Monitor (2024),  Contribution from Mérték Media Monitor for the 2024 Rule of Law 
Report. 

Minister of Interior (2023), Letter to the chairperson of the Anti-Corruption Task Force (16 October 
https://kemcs.hu/wp-content/uploads/2023/10/NKS-kiegeszito-jelentesre-adott-Kormanyzati-
2023) 
allaspont.pdf.  

National Judicial Council (2024), Verbatim minutes of the 14 February 2024 meeting of the National 
Judicial  Council  https://obt-jud.hu/sites/default/files/ulesek/Az-OBT-2024.-februar-14-i-ulesenek-
jegyzokonyve.pdf.  

National  Judicial  Council  (2024),  Verbatim  minutes  of  the  27  March  2024  meeting  of  the  National 
Judicial Council https://obt-jud.hu/sites/default/files/ulesek/Jegyzokonyv_2024.03.27.pdf.  

National  Media  and 
https://english.nmhh.hu/article/242928/Media_Market_Report_2023. 

Infocommunications  Authority 

(2023),  Media  Market  Report  2023 

OECD  (2021),  Implementing  the  OECD  Anti-Bribery  Convention,  Phase  4  Two-Year  Follow-Up 
Report: Hungary https://www.oecd.org/daf/anti-bribery/hungary-phase-4-follow-up-report.pdf.  

OECD  (2023),  OECD  Working  Group  on  Bribery  public  statement  on  Hungary  (31  January  2023) 
https://www.oecd.org/corruption/oecd-working-group-on-bribery-public-statement-on-hungary-31-
01-2023.htm.  

OECD  (2023),  Implementing  the  OECD  Anti-Bribery  Convention,  Phase  4  Evaluation  of  Hungary: 
additional 
2023) 
https://one.oecd.org/document/DAF/WGB(2023)35/FINAL/en/pdf?sessionId=1700663306729. 

follow-up 

October 

written 

report 

(25 

Strategy 

OECD  (2023),  A  strategic  approach  to  public  integrity  in  Hungary:  The  2023-2025  National  Anti-
Corruption 
https://www.oecd-
ilibrary.org/docserver/a5461405-
en.pdf?expires=1710511674&id=id&accname=oid031827&checksum=A968A42BA18AE860769123
CD88C99C24. 

(16  November 

Action 

2023) 

Plan 

and 

45 

 
OSCE  ODIHR  and  Venice  Commission  (2020),  Guidelines  on  Political  Party  Regulation,  Second 
Edition https://www.osce.org/files/f/documents/8/1/538473.pdf.  

OSCE  ODIHR  (2022),  Hungary  Parliamentary  Elections  and  Referendum  -  3 April  2022 -  ODIHR 
Election Observation Mission Final Report https://www.osce.org/files/f/documents/2/6/523568.pdf.  

Ökotárs (2024), Contribution from Ökotárs for the 2024 Rule of Law Report. 

Prosecution service (2024), Indictment in a case related to tender grants obtained through corruption 
–  with  video  –  press  release  of  the  Central  Chief  Investigating  Prosecution  Office,  (Vádemelés  a 
korrupció  útján  szerzett  pályázati  támogatások  ügyében  -  videóval  -  a  Központi  Nyomozó 
Főügyészség  sajtóközleménye)  (12  February  2024),  https://ugyeszseg.hu/vademeles-a-korrupcio-
utjan-szerzett-palyazati-tamogatasok-ugyeben-videoval-a-kozponti-nyomozo-fougyeszseg-
sajtokozlemenye/.  

Reporters Without Borders (2023), 2023 World Press Freedom Index. 

Reporters Without Borders (2024), Contribution from Reporters Without Borders for the 2024 Rule of 
Law Report. 

Res  Iudicata  Association  (2024),  Contribution  from  Res  Iudicata  Association  for  the  2024  Rule  of 
Law Report. 

Reuters  (2024),  In  unusual  move,  China  offers  to  back  Hungary  in  security  matters  (20  February 
https://www.reuters.com/world/unusual-move-china-offers-back-hungary-security-matters-
2024), 
2024-02-19/.  

Reuters (2024), Hungary prosecutors probe graft case tape leaked by former government insider (28 
https://www.reuters.com/world/europe/hungary-prosecutors-probe-graft-case-tape-
March 
leaked-by-former-government-insider-2024-03-28/.  

2024), 

RTL  (2024),  The  government  covers  up  certain  corporate  assets  of  ministers  with  an  undisclosed 
decision (Nem nyilvános határozattal fedi el a kormány a miniszterek bizonyos céges vagyonait) (15 
January 
https://rtl.hu/belfold/2024/01/15/nem-nyilvanos-hatarozat-bizalmi-vagyonkezelo-
kormany-miniszter-ceges-erdekeltseg-vagyon. 

2024), 

SELDI  (2023),  Bridges  to  nowhere  –  State  Capture  and  Corruption  Risks  in  Fiscal  Transfers  and 
in  Southeast  Europe  https://seldi.net/wp-
Public  Procurement  at 
content/uploads/2023/11/Bridges-to-Nowhere-2.pdf.  

the  Local  Level 

State  Audit  Office  (2024),  Partial  Audit  Report  on  the  accounting  of  funds  spent  on  the  2022 
parliamentary  election  campaign  in  case  of  Democratic  Coalition  (DK),  Jobbik  Movement  for  a 
Better  Hungary,  Momentum  Movement,  Hungarian  Socialist  Party  (MSZP),  LMP-Hungary’s  Green 
Party, Dialogue for Hungary (Részjelentés - Kampánypénzek ellenőrzése - A 2022. évi országgyűlési 
képviselő-választási  kampányra  fordított  pénzeszközök  elszámolásának  ellenőrzése  hat  jelölő.  
szervezetnél), https://www.asz.hu/dokumentumok/23025.pdf.  

Szabad Európa (2024), Overpricing is only one of the tricks – this is how Gyula Balásy gets all state 
orders  (A  túlárazás  csak  az  egyik  trükk  –  így  tarol  Balásy  Gyula  az  állami  megrendeléseken)  (7 
March 
https://www.szabadeuropa.hu/a/rogan-balasy-gyula-lounge-new-land-
tularazas/32843686.html. 

2024), 

Telex (2023), There are already 34 suspects in the bribery case involving the Ministry of Finance and 
the  Prime  Minister’s  Office  (Már  34  gyanúsítottja  van  a  Pénzügyminisztériumot  és  a 
2023), 
vesztegetési 
Miniszterelnökséget 
https://telex.hu/belfold/2023/03/03/vesztegetes-miniszterelnokseg-ugyeszseg-palyazat-
penzugyminiszterium-korrupcio-buncselekmeny-nyomozas. 

ügynek) 

March 

érintő 

(3 

is 

Telex (2024), SAO: CÖF and Megafon said that they had not cooperated with Fidesz (ÁSZ: A CÖF 
és  a  Megafon  azt  mondták,  hogy  ők  nem  működtek  együtt  a  Fidesszel)  (20  February  2024) 
https://telex.hu/belfold/2024/02/20/asz-kampanytamogatas-mmm-megafon-cof.  

46 

 
Telex (2024), The Integrity Authority filed a complaint over the half-billion forint ‘dairy farm’ of the 
family  of  ex-minister  János  Süli  (Az  Integritás  Hatóság  feljelentést  tett  Süli  János  exminiszter 
családjának 
2024) 
https://telex.hu/gazdasag/2024/02/21/hatosagi-feljelentes-suli-janos-exminiszter-csaladjanak-
felmilliardos-teheneszete-miatt.  

„tehenészete” 

félmilliárdos 

February 

miatt) 

(21 

Telex (2024), Former Justice Minister’s ex-husband releases recording he claims proof of high-level 
involvement  in  corruption  case  (26  March  2024),  https://telex.hu/english/2024/03/26/damning-
recording-about-orbans-right-hand-man-trying-to-cover-up-involvement-in-corruption-published-by-
former-justice-ministers-ex-husband.  

Telex (2024), The Sovereignty Protection Office has no problem with Chinese policemen coming to 
Hungary (A Szuverenitásvédelmi Hivatal szerint semmi baj nincs azzal, hogy kínai rendőrök jönnek 
Magyarországra)  (3  April  2024),  https://telex.hu/belfold/2024/04/03/szuveneritasvedelmi-hivatal-dk-
kinai-rendorok. 

Telex  (2024),  Transparency  International  and  Átlátszó  became  the  first  targets  of  the  Sovereignty 
Protection Office (A Transparency International és az Átlátszó lettek a Szuverenitásvédelmi Hivatal 
első  célpontjai)  (25  June  2024),  https://telex.hu/belfold/2024/06/25/szuverenitasvedelmi-hivatal-
transparency-international-vizsgalat-indul. 

The Budapest Times (2023), Prosecutors investigate a further 9 people in EU tenders bribery case (3 
March  2023),  https://www.budapesttimes.hu/hungary/prosecutors-investigate-a-further-9-people-in-
eu-tenders-bribery-case/. 

The Budapest Times (2024), KNYF: ‘No documents disappeared in so-called Volner-Schadl case’ (28 
March  2024),  https://www.budapesttimes.hu/hungary/knyf-no-documents-disappeared-in-so-called-
volner-schadl-case/. 

Transparency 
https://images.transparencycdn.org/images/2022_Report-Full_Exporting-Corruption_English.pdf. 

International 

Exporting 

(2022), 

Corruption 

Transparency International Hungary (2024), Contribution from Transparency International Hungary 
for the 2024 Rule of Law Report.  

Transparency  International  Hungary  (2024),  Press  statement:  Hungary’s  Sovereignty  Protection 
(25  June  2024) 
International  Hungary  with 
Office 
https://transparency.hu/en/news/spo-targets-ti-hungary/. 

targets  Transparency 

investigation 

UN Human Rights Regional Office for Europe (2024), Contribution from UN Human Rights Regional 
Office for Europe for the 2024 Rule of Law Report. 

UN Office of the High Commissioner for Human Rights (2023), Mandates of the Special Rapporteur 
on  the promotion and  protection  of  the  right  to freedom  of  opinion  and  expression  and  the Special 
Rapporteur 
2023), 
https://spcommreports.ohchr.org/TMResultsBase/DownLoadPublicCommunicationFile?gId=28661.  

(8  December 

defenders 

situation 

human 

rights 

the 

on 

of 

Válasz  Online  (2024),  Fidesz  has  built  a  gigantic  network  of  GONGOs  for  the  elections  –  several 
little  ‘Szilárd  Németh’  can  jump  into  action  (A  Fidesz  gigantikus  álcivil  hálózatot  épített  a 
2024), 
January 
választásokra 
https://www.valaszonline.hu/2024/01/22/fidesz-varosi-civil-alap-nemethszilard-valasztasok/.  

„Németh  Szilárd” 

akcióba) 

léphet 

sok 

(22 

kis 

– 

Venice  Commission  (2012),  Opinion  on  Act  CLI  of  2011  on  the  Constitutional  Court  of  Hungary 
(CDL-AD(2012)009). 

Venice  Commission  (2024),  Opinion  on  the  Act  LXXXVIII  of  2023  on  the  Protection  of  National 
Sovereignty (CDL(2024)002). 

Die  Welt  (2024),  When  the  Chinese  police  can  lawfully  patrol  in  the  EU  (Wenn  die  chinesische 
2024), 
Polizei 

patrouilliert) 

March 

legal 

EU 

(15 

der 

in 

47 

 
https://www.welt.de/politik/ausland/article250367428/Ungarn-Wenn-die-chinesische-Polizei-in-der-
EU-patrouilliert.html?cid=email.crm.redaktion.newsletter.politik.  

48 

 
Annex II: Country visit to Hungary 

The Commission services held virtual meetings in February 2024 with: 

Integrity Authority 

•  Amnesty International Hungary 
•  Átlátszó 
•  Bea Bodrogi lawyer, media expert 
•  Buda Central District Court 
•  Corruption Research Center Budapest 
•  ELTE Media Department 
•  Eötvös Károly Policy Institute 
•  Hungarian Association of Journalists (MÚOSZ) 
•  Hungarian Association of Judges (MABIE) 
•  Hungarian Bar Association (MÜK) 
•  Hungarian Civil Liberties Union (TASZ) 
•  Hungarian Chamber of Commerce and Industry (MKIK) 
•  Hungarian Helsinki Committee 
• 
•  K-Monitor 
•  Kúria (Supreme Court) 
•  Media Service Support and Asset Management Fund (MTVA) 
•  Mérték Media Monitor 
•  Ministry for European Affairs 
•  Ministry of Finance 
•  Ministry of Interior 
•  Ministry of Justice  
•  National Assembly (Országgyűlés) 
•  National Data Protection and Freedom of Information Authority (NAIH) 
•  National Judicial Council (OBT) 
•  National Media and Infocommunications Authority (NMHH) 
•  National Office for the Judiciary (OBH) 
•  Office of the Commissioner for Fundamental Rights 
•  Prosecution Service of Hungary 
•  State Audit Office (Állami Számvevőszék) 
•  Transparency International Hungary 

* The Commission also met the following organisations in a number of horizontal meetings:  

•  Amnesty International EU 
•  Centre for Democracy and Technology Europe  
•  Centre for European Volunteering 
•  Civil Liberties Union for Europe 
•  Civil Rights Defenders 

49 

 
 
•  Civil Society Europe 
•  Culture Action Europe 
•  Democracy Reporting International 
•  European Centre for Non-Profit Law 
•  European Civic Forum 
•  European Federation of Journalists  
•  European Partnership for Democracy 
•  European Youth Forum 
•  Free Press Unlimited 
• 
• 
• 
• 
•  JEF Europe 
•  Open Society Foundations 
•  Philanthropy Europe Association 
•  PICUM 
•  Reporters Without Borders 
•  SOLIDAR 
•  Transparency International EU 

International Federation for Human Rights 
International Planned Parenthood Federation 
International Press Institute  
Irish Council for Civil Liberties 

50