COMMISSION STAFF WORKING DOCUMENT Third River Basin Management Plans Second Flood Hazard and Risk Maps and Second Flood Risk Management Plans Member State: Hungary Accompanying the document REPORT FROM THE COMMISSION TO THE COUNCIL AND THE EUROPEAN PARLIAMENT on the implementation of the Water Framework Directive (2000/60/EC) and the Floods Directive (2007/60/EC) Third River Basin Management Plans Second Flood Risk Management Plans
Date: 2025-02-04
Institutions: Directorate-General for Environment, European Commission
Subjects: Hungary, adaptation to climate change, application of EU law, environmental risk prevention, flood, risk management, water, water management, water pollution, watercourse

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 4.2.2025  SWD(2025) 29 final  COMMISSION STAFF WORKING DOCUMENT Third River Basin Management Plans  Second Flood Hazard and Risk Maps and Second Flood Risk Management Plans   Member State: Hungary           Accompanying the document REPORT FROM THE COMMISSION TO THE COUNCIL AND THE EUROPEAN PARLIAMENT on the implementation of the Water Framework Directive (2000/60/EC) and the Floods Directive (2007/60/EC)    Third River Basin Management Plans  Second Flood Risk Management Plans {COM(2025) 2 final} - {SWD(2025) 13 final} - {SWD(2025) 14 final} - {SWD(2025) 15 final} - {SWD(2025) 16 final} - {SWD(2025) 17 final} - {SWD(2025) 18 final} - {SWD(2025) 19 final} - {SWD(2025) 20 final} - {SWD(2025) 21 final} - {SWD(2025) 22 final} - {SWD(2025) 23 final} - {SWD(2025) 24 final} - {SWD(2025) 25 final} - {SWD(2025) 26 final} - {SWD(2025) 27 final} - {SWD(2025) 28 final} - {SWD(2025) 30 final} - {SWD(2025) 31 final} - {SWD(2025) 32 final} - {SWD(2025) 33 final} - {SWD(2025) 34 final} - {SWD(2025) 35 final}  
 
 
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Country specific staff working document 

Hungary 

ENVIRONMENT 

 
 
 
 
 
 
 
 
Content 

Content ................................................................................................................................................................................................... 2 

SECTION A: WATER FRAMEWORK DIRECTIVE .......................................................................................................................... 3 

1. General info, member state characterisation ............................................................................................................. 4 

2. Horizontal aspects ...................................................................................................................................................................... 9 

2.1 Governance ............................................................................................................................................................................ 9 

2.2 Characterization of River Basin District ................................................................................................................. 9 

3. Policy elements contributing to biodiversity and climate change adaptation ...................................... 10 

3.1 Surface Water: what is their ecological status or potential .................................................................... 10 

3.2 Hydromorphological changes and artificialization (HMWBs and AWBs) .......................................... 11 

3.3 Groundwater bodies - have they sufficient water – quantitative status ......................................... 12 

3.4 Protected Areas (identification, monitoring, objectives and measures) ........................................... 13 

3.5 What is being done to prevent/reduce hydromorphological pressures ............................................ 14 

3.6 What Hungary is doing for abstractions and water scarcity .................................................................. 15 

3.7 Adaptation to climate change .................................................................................................................................. 16 

4. Policy elements contributing to zero pollution ........................................................................................................ 17 

4.1 Surface Water: what is their chemical status ................................................................................................. 17 

4.2 Groundwater Bodies: what is their chemical status .................................................................................... 18 

4.3 What Hungary is doing to combat pollution from agriculture ............................................................... 19 

4.4 What Hungary is doing to combat pollution from other sectors.......................................................... 20 

4.5  What  Hungary  is  doing  to  combat  significant  pressures  –  overall  assessment  of  the 
Programmes of Measures .................................................................................................................................................. 21 

5. Exemptions and economics ............................................................................................................................................... 22 

5.1 To what extent are exemptions applied in Hungary .................................................................................... 22 

5.2 Use of economic analysis and water pricing – cost recovery ................................................................ 23 

6. WFD recommendations ........................................................................................................................................................ 25 

SECTION B: FLOODS DIRECTIVE .................................................................................................................................................. 28 

7. Flood risk management under floods directive (FD) ............................................................................................ 29 

7.1 Flood hazard and risk maps ...................................................................................................................................... 29 

7.2 Flood risk management plans .................................................................................................................................. 30 

8. FD recommendations ............................................................................................................................................................ 32 

2 

 
 
 
SECTION A: 
WATER FRAMEWORK 
DIRECTIVE 

3 

 
 
 
1. General info, member state characterisation

Hungary  is  a  land-locked  country  which  shares  borders  with  Member  States  but  also  with  third 
countries: in the north Slovakia, Ukraine to the northeast, Romania to the east and southeast, Serbia 
to the south, Croatia and Slovenia to the southwest and Austria in the west. Hungary has a population 
of 9.6 million inhabitants1 and a surface area of 93 thousand km2.2 Lake Balaton, covering 598 km2, 
is one of the biggest tourist attractions of the country. Two-thirds of Hungary’s geographic area is 
less than 200 metres above sea level while the highest elevation reaches 1000 m.3

Hungary has one River Basin District (RBD) which is part of the Danube international RBD.  Hungary 
has 1072 surface water bodies (886 rivers and 186 lakes) as well as 185 groundwater bodies. As a 
land-locked country, it has no transitional or coastal waters.  

BD 
(Index) 

Danube 
(HU1000) 

Rivers 

Lakes 

Groundwater 
Bodies 

886 

186 

185 

1 Statistics | Eurostat (europa.eu) 
2 Hungary Facts | Britannica 
3 https://studyinhungary.hu/why-hungary/menu/basic-information-about-hungary.html 

4 

 
 
However, as it can be seen in the table below, the level of human intervention in the water system is 
quite considerable and more than half of the river water bodies and lake water bodies are heavily 
modified. This is due to the presence of weirs and dams, channelisation and straightening of rivers, 
and  bed  stabilisation  and  bank  reinforcement  as  well  as  inland  waterway  transport  facility 
installations, tourism and recreational activities (beaches, fishing). A smaller percent of water bodies 
is artificial (16%) i.e. water bodies created by human activity. 

Modifications   Rivers  

Lakes  

HEAVILY 
MODIFIED   

52% 

66% 

ARTIFICIAL   

16% 

16% 

Currently, 22.2% of Hungary terrestrial territory is designated as protected areas. Hungary has a total 
of 851 protected areas, comprising 326 sites designated under national laws and 525 recognized as 
Natura 2000 sites4. The share of species assessments with good conservation status is only 34.9% 
with more than half with bad conservation status.

Reporting 

The deadline for reporting the 3rd RBMPs was in March 2022. The Commission and the EEA together 
with Member States developed an electronic reporting system in WISE (Water Information System 
for  Europe).  Its  use  was  voluntary.  Some  Member  States  used  it  to  fulfil  their  obligations,  others 
reported the plans in pdf format. The cut-off date for the WISE e-reporting was September 2023 and 
the MS were assessed based on the datasets available by this date.  

By September 2023 Hungary have not submitted full electronic reporting. Therefore, the assessment 
is based on the data mining of the pdf RBMPs. 

Despite the cut off dates for the production of this report, reporting continued and, for the State of 
Water report, the EEA aggregated the results available by July 2024 in their products and dashboards 
available at WISE Freshwater web portal. 

4 https://biodiversity.europa.eu/countries/hungary 

5 

 
 
 
 
Changes in Status, Pressures, Exemptions & Measures 

Surface 
Water 
Bodies 
(1072) 

Trend (% good 
status/potential) 

Main Pressures & Changes & Exemptions 

ECOLOGICAL 
STATUS 

CHEMICAL 
STATUS 

All SWBs are under pressure from diffuse pollution of nutrients from 
agriculture (causing 84% of SWBs to fail good status) and 
hydromorphological pressures, and more than half of all SWBs are 
subjected to point source pollution and water abstraction. HU reports here 
that scarcity is due to increasing water demands (most abstraction by 
industry) and climate change impacts. A severe issue is illegal water 
abstraction for agriculture and domestic water supply. 

HU achieved a slight improvement in ecological status/potential since the 
2nd RBMPs, reporting an increase in SWBs in moderate status and less 
SWBs in poor and bad condition. Some efforts to improve monitoring have 
been made, e.g. no more SWBs are in unknown status. 

Article 4(4) exemptions have been applied on the grounds of natural 
conditions, justified with a delay between measure implementation and 
their positive effects. Exemptions under Article 4(5) have been applied to 
several SWBs for technical feasibility. 

The main reasons for failing to achieve good chemical status lies with a 
small number of uPBT substances, primarily polybrominated diphenyl 
ethers (PBDEs), mercury and to a lesser degree, perfluorooctane sulphonic 
acid (PFOS). Besides uPBT substances, primarily metals (cadmium, lead, 
arsenic, and nickel) which stem from heavy industry emissions and 
combustion processes, put pressure on SWBs. 

The percentage of SWBs in good status has not improved, However, the 
spatial and temporal scale of the monitoring network has improved 
significantly. SWBs in unknown status have been reduced and confidence 
of classification is high. 

Exemptions were applied to 43% of SWBs under Article 4(4) natural 
conditions, and to 12% under 4(5) for technical feasibility. 

6 

 
 
 
 
 
 
 
 
 
 
 
Ground 
Water 
Bodies 
(185) 

Trend (% good 
status/potential) 

Main Pressures & Changes & Exemptions 

QUANTITATIVE 
STATUS 

CHEMICAL 
STATUS 

Water abstractions affect 100% of all GWBs, and water demand is 
reportedly increasing. Households and services make up 75% of 
groundwater abstractions, although HU has a significant issue with illegal 
water abstraction for agriculture and domestic supply. An additional 
pressure is put on groundwater bodies by the impacts of climate change 
(increased evaporation, decreased recharge). 

The quantitative status of HU's groundwater bodies has not improved 
since the 2nd RBMPs.  

HU applies exemptions under Article 4(4) for natural conditions to most 
failing GWBs. Article 4(6) has been applied to 8 GWBs due to lowering 
water tables because of climate change, and 4(7) to 4 GWBs for new 
modifications. 

Main pressures and pollutants on GWBs are not explicitly reported, yet 
indication is given that point and diffuse pollution of urban, industrial, 
and agricultural origin affect groundwater bodies as they affect SWBs. 
Among this is untreated wastewater, nutrients from agriculture, urban 
run-off, and industrial wastewater, as well as sites of past 
contamination. 

While most GWBs are subject to chemical monitoring, there are gaps in 
monitoring methodology and implementation, e.g., some chemicals are 
not included. Thus, accuracy of the trend of slight chemical status 
improvement is uncertain. About 20% of GWBs fail to achieve good 
chemical status, and another 19% are at risk of falling to less-than-good 
status by 2027.  

Article 4(4) have been applied to 35 groundwater bodies (18.9 %) for 
natural conditions 

2. Horizontal aspects 

2.1 Governance 

Hungary has designated the Hungarian Danube RBD and has prepared one single national RBMP and 
four  sub-basin plans.  Hungary  registered  a  delay in  the publication  (19  May 2022)  of  the  official 
government  decision.  Hungary  has  a  multi-actor  type  of  governance  with  multiple  ministries 
responsible for water management, environment, nature conservation and climate. The Ministry of 

7 

 
 
 
 
 
 
 
Interior had the task amongst others of preparing the River Basin Management Plan as well as the 
interaction with the European Commission.  

Hungary has an overarching National Water Strategy, adopted in 2017. The RBMP was coordinated 
with  the  Floods  Risk  Management  Plan  (FRMP),  the  documents  undergoing  parallel  processes  of 
elaboration and revision. The RBMP addresses the links with the FRMP including also the analyses of 
the relationship of flood risk measures with the WFD. Coordination with the MSFD is mentioned only 
in connection with the implementation of the Urban Waste Water Treatment Directive to mitigate 
eutrophication5 and reduction of plastic litter6. 

The entire territory of Hungary is located in the international Danube RBD. The Danube Basin level 
coordination is performed by an international River Basin Commission (International Commission for 
the  Protection  of the Danube  River  –  ICPDR)  to  which  Hungary is  a  contracting  party.  In  addition, 
Hungary has bilateral agreements with all its neighbouring countries.  

One  initiative  of  Hungary  worth  mentioning  here  is  that  it  is  leading  the  recently  started  project 
“Development  of  a  harmonized  water balance modelling  system  for the Danube  River  Basin”  aka 
“Danube Water Balance”, financed by the Interreg Programme Danube Region (30 month). The aim 
of  the  project  is  to  establish  a  robust  water  balance  model  as  Danube  countries  proved  to  use 
different calculations  and models. This is a great initiative that will help the Danube countries by 
providing the knowledge about the available water resources in the river.  

It is also worth highlighting that the timetable, the work programme, the consultation plan for the 
RBMP, the overview of significant water management issues and the draft RBMP were submitted for 
consultation for six months, according to the WFD requirements. Moreover, the RBMP includes in an 
annex all comments received during public consultation and responses7 concerning the draft RBMP. 
Only 38 % of all comments were considered in the final version either fully or partially and 12% were 
deemed irrelevant. Based on 217 comments (46 %), no amendment was necessary, or the proposed 
suggestion was already included in the plan.  

2.2 Characterization of River Basin District 

Hungary has 1072 surface water bodies namely 886 rivers and 186 lakes. It is noted positively that 
reference  conditions  have  been  established  for  all  lake  and  river  types  for  all  biological, 
hydromorphological  and  physico-chemical  quality  elements.  Groundwater  bodies  are  delineated 
based on geological characteristics. Out of the 185 groundwater bodies, 115 (62 %) have a significant 
relationship with surface water bodies. 

Surface waters 

In  terms  of  pressure,  diffuse  pollution  and  hydromorphological  pressures  affect  all  surface  water 
bodies  while  point  source  pollution  and  water  abstractions  constitute  significant  pressures  for  a 
majority of surface water bodies. Priority substances that are present in a large number of water 

5 Source: Sub-section 2.4 of the 3rd RBMP (page 1662) 

6 Source: Table 3-1. Significant Water Management Issues (page 1674) and Table 8-17. Summary of Programme of 
Measures of the 3rd RBMP (page 1743) 
7Annex10-3,https://vizeink.hu/wp-
content/uploads/2022/10/VGT3/mellekletek/10_3_melleklet_VGT3_velemenyek_valaszok.xlsx 

8 

 
 
bodies are mercury, cadmium, brominated diphenyl ethers, heptachloride, fluoranthene, most of them 
being persistent, bioaccummulative and toxic.  

Figure 1 - Map of the monitoring points showing eutrophication assessment in Hungary, according to the 
reporting of the Nitrates Directive 

Source: Joint Research Centre of European Commission (n.d.). JRC NITRATES DIRECTIVE - Reporting Period 7 (2016-2019) 
Trophic Status. [online] water.jrc.ec.europa.eu.  
Available at: https://water.jrc.ec.europa.eu/portal/apps/dashboards/cb6034c2a75e4df282f8a62f90c16caa 
Note : 0% of the monitoring stations are above the threshold of 50mg/l 

Groundwaters  

Abstraction pressures affect 100 % of groundwater bodies.  

Hungary defines a significant pressure as one which exceeds the threshold value or emission limit 
specified in a water protection or environmental protection law, or has such a significant negative 
impact on the condition of water bodies and protected areas that it prevents good status or puts the 
achievement of good status at risk. If a water body is not at good status or potential, and the status 
is  worsening  or  not  improving  according  to  the  schedule,  then  the  pressure  causing  the  issue  is 
considered significant.  

9 

 
 
 
To  note,  the  invasive  alien  species  (IAS)  has  not  been  found  as  a  significant  pressure  on  waters. 
Nevertheless, the RBMP foresee measures to prevent and manage the introduction and spread of 
invasive alien species in accordance with the relevant EU legislation. In total, there are 30 aquatic 
species of EU concern in Hungary8.  

3. Policy elements contributing to biodiversity and 

climate change adaptation 

3.1 Surface Water: what is their ecological status or potential 

All surface water bodies have been classified for ecological status or potential. This classification is 
based  on  both  surveillance  and  operational  monitoring9.  Hungary  uses  grouping10  if  there  is  no 
monitoring present in a water body for measuring chemical quality elements (nitrogen, phosphorus, 
etc.). 96% of river water bodies and 76% of lake water bodies are classified using monitoring data. 
The rest of both categories are classified using expert judgement. The one-out-all-out principle is 
reported as having been used.  

A very important change is the very considerable improvement in the knowledge of the status of the 
water bodies. The number of unknowns has sharply decreased, most strikingly for lakes and there 
are also no longer any water bodies (river or lake) with an unknown status.  

Figure 1 depicts the evolution between the 2nd and 3rd RBMPs. For rivers, there are no water bodies 
in  high  ecological  status  or  maximum  ecological  potential;  There  are  only  12  %  of  rivers  having 
reached  good  ecological  status  /  potential,  and  almost  two  thirds  of  them  being  in  “moderate 
ecological status / potential”, however these shares have increased compared to the previous cycle. 
For lakes, the number of water bodies in good ecological status / potential has slightly increased, and 
also a significant increase of moderate ecological status / potential can be seen. The percentage of 
lakes with high ecological status or maximum ecological potential decreased slightly.  

8 EASIN - European Alien Species Information Network: https://easin.jrc.ec.europa.eu/easin/ 
9 The WFD distinguishes between surveillance and operational monitoring: i) operational monitoring to determine the 
status and which covers all water bodies at risk and ii) surveillance monitoring aimed at identifying impacts and long-
term changes 
10 Grouping of water bodies means using of monitoring data collected from another site, located on another body of water 
that presents the same typology, the same types, and the same magnitudes of anthropogenic pressures. 

10 

 
 
 
Figure 2 - Ecological status / potential of surface water bodies in the 1st RBMP, 2nd RBMP and 3rd RBMP  

Source: Data mining  

Since  no  data  is  provided  for  the  expected  status  of  the  surface  water  bodies  by  2027,  it  is  not 
possible to assess the gap in reaching good ecological status. 

3.2 Hydromorphological changes and artificialization (HMWBs and AWBs) 

The number of heavily modified river water bodies is very high and has even increased since the 2nd 
RBMP from 394 to 463 (41 % of all river water bodies). We see the reverse trend for lakes since that 
number has decreased from 124 to 123 (14.9 % of all lakes). According to the authorities, this is not 
due to a change in classification but rather an improvement of the data coverage. The methodology 
remained  almost  the  same  introducing  the  weighting  of  the  different  types  of  modifications 
depending on the biological sensitivity. Similar to the 2nd RBMP, the main uses are, for  

 - rivers: storage for fisheries, aquaculture, fish farms, and land drainage and irrigation for agriculture, 
although some uses are reported as unknown  

- lakes:  tourism, recreation, and flood protection. 

The main physical alterations of heavily modified water bodies are weirs and dams, channelisation 
and  straightening  of  rivers,  and  bed  stabilisation  and  bank  reinforcement.  It  also  includes  inland 
waterway transport facility installations, tourism and recreational activities (beaches, fishing). 

Good ecological potential is reported to be defined at water body level, based on the identification of 
mitigation measures. Good ecological potential was reported in the RBMP to be defined based on 
biological quality elements. Their Maximum Ecological Potential (MEP) and Good Ecological Potential 
(GEP) class boundary values were estimated by numerical modelling. According to information in the 
RBMP, the classification values for biological quality elements in Artificial and Heavily Modified Water 

11 

 
 
Bodies are estimated based on monitoring data with the same methodology as for natural water 
bodies. The methodology takes into account the  Biological Quality Elements (BQEs) most sensitive 
to  hydromorphological  alterations,  namely  benthic  invertebrates  and  fish  for  rivers,  and 
phytoplankton  and  phytobenthos  for  lakes.  Information  with  respect  to  physico-chemical  quality 
elements was not found in the RBMP. The comparison of GEP and GES has been included in the RBMP 
but only for macrophyte and macroinvertebrates. 

3.3 Groundwater bodies - have they sufficient water – quantitative status 

It is worth noting that all groundwater bodies are subject to quantitative monitoring in the 3rd RBMP, 
in some cases by grouping. As it was already the case in the previous cycle, 80% of groundwater 
bodies are in good quantitative and 20% of groundwater bodies are in poor quantitative status. This 
is indeed very high percentage of the groundwater bodies.  

Figure 3 - Quantitative status of groundwater bodies in the 1st RBMP, 2nd RBMP and 3rd RBMP 

Source: Data mining  

Equally worrying is that there are 32 (17.3 %) groundwater bodies in good quantitative status for 
the  moment  but  identified  as  being  at  risk  becoming  in  poor  status.  This  is  a  very  considerable 
increase in this risk compared to the 2nd RBMP where 20 groundwater bodies (10.8 %) were identified 
at  risk  of  being  in  poor  quantitative  status.  This  would  lead  to  conclude  that  the  pressures  on 
abstractions are increasing and may hinder the achievement of the environmental objectives. The 
absence of reported causes to fail good quantitative status, leads to absence of knowledge about 
the possible related impact on associated aquatic ecosystems or depending terrestrial ecosystems. 

In addition, it must be  noted  with some concern, that furthermore, illegal  water abstraction from 
groundwater was estimated in the 2nd RBMP to reach 16 % of total water abstraction in the country 
while illegal water abstraction from surface water was not estimated.  

Regrettably, no information could  be found in the Hungarian River Basin Management Plan about 
Hungary’s expectation in 2027. 

12 

 
 
3.4 Protected Areas (identification, monitoring, objectives and measures) 

Hungary has several protected areas including Natura 2000 sites, nutrient sensitive areas, Bathing 
Waters  and  Drinking  Water  Protection  Zones.  There  are  no  protected  areas  designated  for 
economically significant species. Compared to the previous cycle, it can be noticed that there is almost 
no change related to protected areas apart from bathing places i.e. an increase is seen from 236 to 
257 in the 3rd RBMP.  

Table 1 - Number of water bodies associated with protected areas in Hungary 

RBMP 

Length (km) 

Surface area (km²) 

Number 

Natura 2000 rivers 

Natura 2000 lakes 

Nitrate sensitive area 

Bathing water 

2nd  

6 900  

3rd  

6 900  

1 047 

1 047 

65 278 

65 048 

236 

257 

In the 3rd RBMP, the Hungarian authorities mention  the challenges encountered when  designating 
new protected areas e.g resistance from the owner of the aquifer or the local municipality where the 
water body is located as e.g. it can conflict with further plans for development of the local areas. 

The 3rd RBMP indicates that Hungary is succeeding in achieving and maintaining the good condition 
of water bodies by simultaneously fulfilling nature conservation goals. Protected areas are associated 
with about 90 % of the river water bodies and 70 % of lakes in Hungary. 

Monitoring of protected areas is carried out in an integrated manner, e.g. monitoring sites for Nitrate 
Vulnerable Zones and operational monitoring points for nutrients under WFD are the same. 

According to the RBMP, bathing waters had a total of 145 areas with excellent water quality with a 
further 45 having good or moderate status. There is no problem with lakes and smaller stagnant 
waters in terms of achieving the bathing water requirements.  

Hungary did not report electronically to WISE at the time of this analysis and for this reason specific 
data on the status of surface and groundwater bodies associated with protected areas could not be 
further described.11  

Additional objectives and additional measures have been established as follows:  

1)  for Drinking water protection areas, additional measures have been identified for drinking water 
abstraction points that serve 50 people or abstract more than 10m3/day, i.e. a total of 58 none 

11 Hungary subsequently highlighted the information presented in its RBMPs on status of water bodies, including 
information on protected areas. Hungary reported an overview summary of the protected areas, including their status and 
relevant maps (page 1702-1706 of the RBMP) 

13 

 
 
 
 
of which have any exemptions applied. A total of 863 areas have been identified as  requiring 
additional measure for the protection of drinking water supplies; 

2)  Natura 2000 sites out of which about half of them have had article 4(4) exemptions applied. 
Two packages of key measures for the improvement of Natura 2000 areas have been identified.  
These measures above have been applied within a total of 107 Natura 2000 areas. 

No additional measures have been identified within the RBMPs regarding Nitrate Vulnerable Zones 
and nutrient sensitive areas.  

3.5 What is being done to prevent/reduce hydromorphological pressures 

Significant  hydromorphological  pressures  (e.g.  dams)  are  reported  for  rivers  and  lakes  and  are 
assigned to specific sectors. Hydrological alterations are mainly related to aquaculture, agriculture 
and, to some extent, hydropower. Dams, barriers and locks are mainly related to flood protection, 
irrigation,  urban  use  and  recreation.  Physical  alterations  are  mainly  related  to  flood  protection, 
agriculture, urban development and to some extent navigation. To note, agriculture accounts for 55 
percent  of  the  country's  territory  in  terms  of  land  use,  which  is  remarkable  among  EU  member 
states12. The share of organic farming is around 6% of the total utilised agricultural area13. 

Information on systematic and periodical permit review of impoundment and abstraction was not 
found.  A  VIZIR  database  is  in  place  that  contains  the  register  of  physical  modifications  of  water 
bodies, including barriers, has been developed since 2015 e.g. by VIZEK project (https://vizek.gov.hu/) 
digitalised the authorisation process.  

Regrettably, the revision of e-flow values and the legislation in relation to water abstractions is in 
progress hence not yet in place. Also. the Integrated Water Resource Management Plan (IVOT) has 
not yet been published.  

Natural  water  retention  measures  were  reported  as  operational  measures  to  tackle  significant 
hydromorphological pressures, abstractions and diffuse pollution from urban run-off. These include 
soil erosion control measures and water retention in agricultural areas. Measures in relation to land 
drainage,  soil  erosion  and  sediment  loads  or  compacted  agricultural  soils  include  pollutant  and 
sediment deposition reduction using crop  production technologies, soil  erosion control  by planting 
vegetation and landscaping (gully bunds, sediment barriers), water retention in agricultural areas to 
increase infiltration and reduce run-off and urban stormwater management. 

3.6 What Hungary is doing for abstractions and water scarcity 

Water abstraction is identified as a significant pressure at the RBD level, thus nationally. In addition, 
water scarcity is acknowledged as the most significant issue facing Natura 2000 habitats particularly 
the groundwater-dependent habitats and rivers, floodplain woodlands, marsh meadows, hardwood 
forests, mudflats and natural riverbanks. However, no definition of water scarcity has been developed 
in the RBMP. As noted in the European Drought Observatory for Resilience and Adaptation (EDORA) 

12https://apps.fas.usda.gov/newgainapi/api/Report/DownloadReportByFileName?fileName=Agricultural%20Sector%20in%2
0Hungary%20Faces%20Structural%20Changes_Budapest_Hungary_HU2023-0010.pdf 
13 https://agridata.ec.europa.eu/extensions/IndicatorsSectorial/AreaUnderOrganicFarming.html  

14 

 
 
 
project,  12  general  water  scarcity  /  drought  management  plans  have  been  prepared  by  Hungary, 
covering the areas of the 12 regional Water Directorates (VIZIG).  

There have been no significant changes in the way the WFD is implemented in Hungary regarding 
water abstraction and water scarcity management since the 2nd RBMP despite the increasing risk 
identified for certain water bodies to turn to bad quantitative status. Indeed, as mentioned earlier, 
just as in the previous cycle there are 37 groundwater bodies in poor quantitative status (i.e., 20 % 
of total groundwater bodies) but there is a higher number of water bodies at risk of failing to achieve 
good status.  

There  are  authorisations/permitting/concession  regimes  in  place,  as  well  as  registers  for  both 
abstraction and impoundment. However, water abstractions from surface water or groundwater do 
not require registration, if they do not exceed 500 m3 per year. Permits are generally issued for a 
period of time established by the relevant authorities. Permits can be refused or revised under specific 
conditions, in order to maintain or achieve the environmental objectives in the RBMP.  

The 3rd RBMP states that water demand is increasing and refers to various users of water, providing 
the shares between consumptive uses, but not the relevant trends over time. It is noted that industry 
(including energy) takes up 82 % of total surface water abstraction, whereas households and services 
take up 75 % of groundwater abstraction and agriculture 2 % of total groundwater abstraction. The 
3rd RBMP mentions that the main estimation method is direct measurement / monitoring, including 
mandatory water metering for surface water and groundwater abstractions. However, a significant 
volume of abstraction might be unaccounted for since Hungary reports that there is a serious problem 
of illegal water abstraction for agriculture and domestic water supply.  This is also confirmed by a 
study done by Hungarian Centre for Ecological Research14 that states that a very high proportion of 
groundwater abstractions is illegal with only 10% of the wells being officially authorized. 

It is worth highlighting that the Plan explains that the legislation was amended in 2016 to prevent 
and minimise illegal groundwater abstraction and to introduce a more encouraging water price policy 
over exploited water bodies. The VIZEK Framework website (https://vizek.gov.hu/) was developed to 
support the electronic authorization process (“Manage your water law matters electronically!”), thus 
also  supports  the  development  of  electronic  data  management.  However,  the  underlying  legal 
framework  to  underpin  this  digitalisation  seems  to  be  under  development  based  on  a  national 
integrated water resource management plan.  

Regrettably, taking into account that 20 % of the groundwater bodies are in poor quantitative status 
without any progress since the 2nd RBMP, coupled with a large volumes of illegal water abstractions, 
it would appear that the existing framework and its enforcement is insufficient. In addition, most of 
the  measures  planned  in  the  2nd  RBMP  have  not  been  implemented  and,  thus,  have  been 
reintroduced in this cycle with few new measures included. 

3.7 Adaptation to climate change 

Hungary has recorded droughts in the following years: 2003, 2015, 2018, 2022, with impacts that 
have affected crop and livestock production, inland waterway navigation and public water supply. 15 

14https://mta.hu/data/dokumentumok/Viztudomanyi%20Program/Hungarian%20Water%20Research%20Programme%20
Challenges%20and%20Resesarch%20Tasks%202019.pdf 

15 Blauhut and Stahl (2023) Drought Impact Database, Deliverable 1.4, Confidential report.  

15 

 
 
 
The European Drought Atlas projects that as a result of 1 in 50-year drought events, a resultant 
reduction in the transport of goods of 10-20 % will occur.16 

It is worth highlighting that Hungary developed and adopted in 2019 a Drought Management Plan 
along with specific drought indicator including a range of drought mitigation measures. However, no 
details on the projected impacts of these measures have been provided, nor how these interlink with 
water scarcity management areas.  

Climate change adaptation measures are included in the RBMP. The measures are categorised based 
on their relevance to climate change mitigation and adaptation outlining if they have a direct / indirect 
effect, and prioritising measures identified as ‘significant importance’ e.g. land conversions (nature-
based solutions such as reinstatement of natural floodplain), modifications of water allocations to 
meet ecological needs, and water management practices to rehabilitate surface – and groundwater 
connectivity. All measures included  in the RBMP are assessed based on their relevance to climate 
change,  .  The  assessment17  is  based  the  EU  ‘Non-paper  Guidelines  for  Project  Managers:  Making 
vulnerable investments climate resilient’18. 

Hungary has stated publicly that it is envisaging irrigation development as an adaptation measure 
for maintaining competitiveness in agriculture. However, considering the issues with over and illegal 
abstractions of water for agricultural uses, it will be important for Hungary to develop comprehensive 
measures to develop a water resilient, and water efficient agriculture and not just rely on expanding 
irrigation.  Without  a  change  of  practices  this  may  lead  to  maladaptation,  creating  even  more 
dependency on increasingly unreliable rain and river flows. 

As regards floods, flooding is a common occurrence in Hungary, with climate change exacerbating the 
issue. The Floods Directive requires to consider the impacts of climate change on the occurrence of 
floods,  and  therefore  in  the  preparation  of  Flood  Hazard  and  Risk  Maps  (FHRMs)  and  Flood  Risk 
Management  Plans  (FRMPs).  More  information  on  these  can  be  found  in  Section  B.  However, 
considering the close relationship between overall water management and floods management and 
the importance of climate change on both, consideration climate change are jointly addressed in this 
section.  

Since the first FHRMs, Hungary carried out an extensive trend analysis of the long term measured 
hydrological data series and stated in its reporting that the impact of climate change was taken into 
account by extrapolating the measured hydrological data to future periods. 

The second FRMP has a chapter providing detail on the impacts of climate change, including how it 
was addressed in the new projects. The FRMP refers to Hungary’s second National Climate Change 
Strategy. Moreover, it provides an analysis of flash flood risks in the context of climate change. The 
FRMP  indicates  that  climate  studies  project  new  flood  extremes,  with  a  20 %  increase  in  flood 
damages in this century along larger and medium-sized rivers in Hungary, referring to a 2010 project 
that studied climate change impacts. The plan provides detailed information on flash flood risks. The 
FRMP provides further information in terms of the effects of climate change, and in particular flash 

16 Rossi et al., (2023) European Drought Risk Atlas.  
17 Conducted in the RBMP Background Material 8-3 document- Climate Risk Assessment regarding the PoM 

18 EC DG CLIMA (2011) Non-paper Guidelines for Project Managers: Making vulnerable investments climate resilient. 
Available at: https://climate-adapt.eea.europa.eu/en/metadata/guidances/non-paper-guidelines-for-project-managers-
making-vulnerable-investments-climate-resilient/guidelines-for-project-managers.pdf  

16 

 
 
floods, on small watercourses and mountainous and hilly areas where climate change is expected to 
increase the frequency and intensity of extreme weather phenomena. 

4. Policy elements contributing to zero pollution 

4.1 Surface Water: what is their chemical status 

Monitoring  

In the 3nd RBMP, it should be noted positively that monitoring in rivers has increased from 651 water 
bodies to 812 water bodies (representing 92 % of all river water bodies). Similarly, the monitoring in 
lakes has increased from 77 water bodies in the 2nd RBMP to 111 water bodies in the 3rd RBMP (60 
% of all lake water bodies). Grouping has been used to classify the remaining water bodies where 
monitoring was not undertaken. 

Hungary does not have any coastal or territorial waters being a land-locked country. It does however 
have  transboundary  waters.  As  mentioned  earlier,  Hungary  is  a  member  of  the  International 
Commission for the Protection of the Danube River (ICPDR). Monitoring to support the transboundary 
aspects of the Danube is reported at the ICPDR level. The 3rd RBMP states that monitoring has been 
completed at a frequency compliant with the WFD. This means that monitoring in surface water (both 
rivers and lakes) has been undertaken on a monthly basis for at least one full year in every six-year 
reporting period.  

46  substances19  are  included  within  the  routine  monthly  monitoring  as  an  expansion  of  previous 
monitoring rounds under the 2nd RBMP. 

It is noteworthy that in the 3rd RBMP, there is no more water body in “unknown” status. According to 
the 3rd RBMP, 46 % of the total number of water bodies are in good chemical status. If the Persistent, 
bioaccumulative and toxic (PBT) substances were to be excluded, 79 % of rivers (703 water bodies) 
and 80 % of lakes (150 water bodies) would be in good chemical status. This reflects that a small 
number of PBT substances (polybrominated  diphenyl  ethers, mercury, polyaromatic hydrocarbons, 
perfluorooctane sulfonic acid and its derivatives and heptachlor and heptachlor epoxide) and non-
PBT  substances  (arsenic,  but  also  cadmium,  lead,  and  nickel,  along  with  the  hydrocarbon 
fluoranthene)  cause significant number of water bodies to fail in achieving good chemical  status. 
Regrettably, no information could  be found in the Hungarian River Basin Management Plan about 
Hungary’s expectation in 2027. 

19 Note the RBMP does not indicate which substance is the additional one beyond the 45 substances included in the 
EQSD. 

17 

 
 
 
Figure 4 - Chemical status of surface water bodies (SWBs) in Hungary in the 1st, 2nd, and 3rd RBMPs 

Source: Data mining  

4.2 Groundwater Bodies: what is their chemical status 

Similarly  to  the  2nd  RBMP,  the  total  number  of  delineated  groundwater  bodies  in  Hungary  is  185 
clustered  in  66  groups  of  groundwater  bodies  (based  on  geochemical  indicators).  However,  2 
groundwater  bodies  have been  re-delineated  and  classified  as transboundary  in  the  3rd  RBMP.  All 
groundwater bodies are subject to chemical monitoring in the 3rd RBMP, in some cases by grouping.  

The  assessment  of  the  general  chemical  situation  of  a  groundwater  body  is  conducted  with  two 
different methods, depending on the type of the monitoring site. For drinking water monitoring sites, 
the  assessment  is  based  on  the  proportion  of  the  total  volume  of  groundwater  represented  by 
monitoring sites exceeding a groundwater quality standard or threshold value compared to the total 
volume of the whole groundwater body20. For other monitoring sites, the assessment is based on the 
number of monitoring sites exceeding a groundwater quality standard or threshold value21. 

In  the  3rd  RBMP,  81%  of  groundwater  bodies  are  in  good  chemical  status  revealing  a  very  slight 
improvement compared to the previous cycle.  Moreover, there are 20 (10.8 %) groundwater bodies 
which are now in good chemical status but identified as at risk of being in poor status. Regrettably, 
this is a slight deterioration trend since in the previous cycle the number of water bodies at risks was 
17 groundwater bodies (9.2 %). The top pollutants causing failure to achieve good chemical status 
of groundwater bodies are nitrates (25 groundwater bodies) and sulphates (9 groundwater bodies). 
Moreover, the top pollutants showing sustained upward trends in groundwater bodies are nitrates, 

20 If the volume of groundwater representing exceedances is over 3.5%, then the groundwater body is assessed in poor 
chemical status.  

21 If there are more than 3 monitoring sites with exceedances in a groundwater body, then the groundwater body is 
assessed in poor chemical status.   

18 

 
 
ammonium and sulphates. Regrettably, no information could be found in the Hungarian River Basin 
Management Plan about Hungary’s expectation in 2027. 

Figure 5 - Chemical status of groundwater bodies (GWBs) in Hungary in the 1st, 2nd, and 3rd RBMPs. 

Source: Data mining  

4.3 What Hungary is doing to combat pollution from agriculture 

Agricultural pressures have been identified as significant in the 3rd RBMP. The international RBMP for 
Danube includes assessments of nutrient loads including considerations of the agriculture shares as 
can be seen in the figure below. 

Figure  6  -  Share  of  sources  in  the  overall  Total  Nitrogen  emissions  in  the  Danube  countries  for  the 
reference period (2015-2018) 

Source: Danube River Basin Management Plan Update 2021 

19 

 
 
 
However,  while  the  Plan  mentions  nutrient  loads  and  references  to  model-based  assessment,  no 
details are given on the necessary quantified nutrient load reduction to achieve the environmental 
objectives, nor the part attributed to agriculture. These quantified gap analyses miss for pesticides 
too. 

While the planned measures correspond to identified pressures, without some knowledge about the 
gap to target, it is difficult to ascertain if the measures would be sufficient. The expectations about 
the effectivity of the agricultural measures are uncertain: A reduction of the load of phosphorus could 
be expected while the trends for nitrogen is uncertain. The expectations around pesticide pollution 
are not reported. 

The  Nitrate  Directive  is  a  basic  measure  under  the  Water  Framework  Directive.  Therefore 
implementation of basic measures22 for the control of diffuse pollution from agriculture at source is 
mandatory  in  Nitrate  Vulnerable  Zones  and  voluntary  under  the  Hungarian  Agro-environmental 
Programme. The majority of listed measures are mandatory measures under existing legislation. The 
implementation of basic measures covers microbiological, nitrate, organic, pesticide, phosphorus and 
sediment pollution. Only one measure is specifically mentioned to be voluntary (i.e. Pesticide use in 
accordance with voluntary environmental conditions). Many of the agricultural measures are ongoing 
measures that continue through several cycles. 2027 is the deadline for the implementation of all 
measures. 

Measures of the 3rd RBMP aim at reducing soil degradation and efficient nutrient management. The 
RBMP describes the relevant measures covering the mix of basic and supplementary measures. The 
details of the measures are elaborated (aim, methodology, financial backing, future indicators). There 
is only an indication of the number of water bodies that will be impacted by the measure and nothing 
about the size of the agricultural areas impacted, or the amount of water area or length impacted 
nor the estimated and quantified effectivity. Regrettably, the Hungarian RBMP does not include clear 
reference to the international Danube RBMP and how the measures will contribute to the achievement 
of the overall nutrient reduction targets.  

Hungary  refers  to  the  Rural  Development  Programme    2014  -  2022since  the  size  of  agricultural 
areas affected by water protection exceeded 1,600,000 hectares and concluded that there is synergy 
between goals in the CAP Strategic Plan 2023-2027 and the RBMP. All agricultural measures are 
financed and co-financed by the CAP23. Unfortunately, only a small improvement in the state of water 
can be seen until 2022 despite the fact that the measures of the 2nd RBMP should have had a much 
greater effect based on their surface of land on which they are applied. 

4.4 What Hungary is doing to combat pollution from other sectors 

The 3rd RBMP addresses chemical pollution in general terms. Hungary covers both point source and 
diffuse  pollutions  for  each  sector  with  basic  and  /  or  supplementary  measures.  These  include 
preventative measures and mitigating ones. While in principle all drivers are subject to measures, it 
is not possible to assess the expected level of progress. 

The  RBMP  includes  measures  on  point  sources  from  urban  wastewater  treatment  plants  and 
industrial wastewater treatment plants. The assessment of several indicators showed a delay in the 

22 See Article 11(3)(h) of the Water Framework Directive 
23 Mapping and analysis of CAP strategic Plans (2023 – 2027)  Mapping and Analysis of CAP Strategic Plans - European 
Commission (europa.eu) 

20 

 
 
application  of measures, with  only  6%  of  the  budget  allocated  to  finished projects  and  the  other 
projects still ongoing or having to start. Decontamination projects were postponed due to their large 
costs and volumes. For nutrients, there is information on the measures that will be taken per water 
bodies and point sources, however, nothing related to how much the planned measures are likely to 
achieve.  There is a strong focus on updating the discharge permits for both industrial and municipal 
wastewater treatment plans. This is very welcome since, as shown in the Figure 6, only 52% of the 
urban wastewater meet all the requirements of the Urban Waste Water Treatment Directive. Also, 
more monitoring is included as a measure to improve the knowledge base.  

Figure 7 - Proportion of urban wastewater that meets all requirements of the UWWTD 

Source: UWWTD country profile, WISE Freshwater portal 

Hungary provided more targeted information on basic measures required under Article 11(3) (c to k). 
Use of an authorisation and / or a permitting regime to control wastewater point source discharges 
(Article  11(3)(g))  was  reported  for  surface  and  groundwater.  A  register  of  wastewater  discharges 
(Article 11(3)(g)) is available for surface and groundwater. Small wastewater discharges (<15 m3 / 
business day) are exempted from controls and some direct discharges to groundwater are authorised 
in accordance with Article 11(3)(j). 

Unfortunately, the RBMP does not provide any information on the pollution reduction expected by 
implementing the above measures. 

4.5 What Hungary is doing to combat significant pressures – overall 

assessment of the Programmes of Measures 

Key  issues  identified  in  Hungary  are:  1)  Agriculture:  reducing  nutrient  pollution  and  irrigation 
abstraction demand; 2) Urbanisation: wastewater treatment and other diffuse pressures; 3) Flood 
Protection:  hydromorphologiocal  pressures  on  rivers;  4)  Sustainable  use  of  thermal  waters:  for 
recreation,  heating  and  agriculture;  5)  Reduction  of  hazardous  substances  emissions:  in  industry, 
agriculture and wastewater and also 6) impacts of climate change. 

Hungary performed a prioritisation of the measures prior to their selection. Hungary’s first priority is 
the implementation of the basic measures under the WFD, followed by the additional basic measures 
(i.e. regulatory measures to achieve the objectives of Art. 11(3) of the WFD). In Hungary, all basic and 
supplementary measures are mandatory. The rationale for the prioritisation was to favour measures 

21 

 
targeting the prevention of deterioration of status. As such when selecting measures, their relevance 
and effectiveness were assessed as most important and on a water body basis. 

In  total,  there  are  127  national  basic  measures  and  55  national  supplementary  measures.  The 
reported significant pressures are well covered with operational KTMs in Hungary, whereas all the 
KTMs have been assigned to measures, with the addition of six new measures.24 

Regrettably, Hungary did not provide quantitative gap indicators on the expected gap to good status 
for 2027, although all pressures have been clearly linked to their measures.  

5. Exemptions and economics 

5.1 To what extent are exemptions applied in Hungary 

Hungary makes a considerable use of exemptions.  

Article  4(4)  exemptions  (time  related  exemptions  which  can  be  applied  on  grounds  of 
technical feasibility, disproportionate costs or natural conditions) 

All Article 4(4) exemptions have been justified on the grounds of natural conditions. 

The exemptions for quantitative groundwater body status under Article 4(4) have been applied to 33 
groundwater  bodies  (17.8  %),  while  exemptions  for  chemical  status  have  been  applied  to  35 
groundwater bodies (18.9 %).  

The exemptions for chemical status under Article 4(4) have been applied to 461 surface water bodies.  

Hungary  invokes  exemptions  for  ecological  status  /  potential  under  Article  4(4)  WFD  for  surface 
waters, due to the following pressure: urban wastewater, industrial and other point sources; diffuse 
pollution, hydromorphological pressures and river basin specific pollutants. 

Article 4(5) exemptions (lowered objectives)  

These  exemptions  have  been  applied  on  grounds  of  infeasibility  with information  provided  at  the 
water body level. They have been applied to: 

13 surface water bodies for ecological status / potential and 66 water bodies for Specific Pollutants 
(chromium); and  

126 surface water bodies for chemical status (PAH and fluoranthene) 

Article 4(6) exemptions (temporary deterioration) 

They have been applied in the Tisza sub-basin for reason of prolonged drought to 15 surface water 
bodies (11 rivers and 4 lakes) and 8 groundwater bodies. A national study on the water resources of 
Hungary for the 1981-2020 period was conducted, determining (inter alia) the changes in hydrology 
and  hydromorphology  during  the monitoring period used  for  the  3rd  RBMP.  The  analysis  identified 

24 KTMs 26-31 (Managing heat loads; Modernisation and regulation of infiltration and recirculation; Protecting damaged 
protected aquatic, wetland and terrestrial habitats from impacts on water flow, in addition to other measures; Protection of 
damaged protected aquatic, wetland and terrestrial habitats from impacts on water quality, in addition to other measures; 
Specific measures to protect bathing sites; Prevention of accidental pollution) 

22 

 
 
surface  water  bodies  where  the  water  stock  decline  was  greater  than  20  %,  and  where  the 
hydrological  status  assessment  (within  the  WFD  hydromorphological  status  assessment)  did  not 
reach good status. Where this combination was met, an exemption under Article 4(6) of the WFD was 
applied. The study may be used for justifying the exemption subject to it being ascertained that the 
registered water stock declines were only attributable to exceptional and not reasonably foreseeable 
circumstances. However, it is expected that, for the future and taking into account the results of this 
study, the pressure on relevant water bodies and the risk of more frequent and severe drought and 
the long-term trends linked to climate change are taken into due account as they now pose a systemic 
challenge and require adapted measures to be taken.   

Article  4(7)  exemptions  (deterioration  or  prevention  of  achievement  of  good 
status/potential as a result of new modifications or new sustainable human development 
projects) 

They  have  been  applied  to  4  groundwater  bodies  in  the  Nyírség  eastern  edge  and  the  Nyírség  – 
Lónyay main canal catchment (quantitative status). It must be highlighted that no exemptions under 
Article 4(7) were applied in the 2nd RBMP. 

Figure 7 summarises the percentage of water bodies subject to each type of exemption (and reason). 

Figure 8 - Type of exemptions reported to be applied to surface water and groundwater bodies for the 
3rd RBMPs 

Source: Data mining  

5.2 Use of economic analysis and water pricing – cost recovery 

The RBMP provides a summary of the economic analysis and the implementation of WFD Article 9. 
The economic analysis covers most analysis elements as listed in WFD Annex III, but there is scope 
for improvement. As regards the long term forecasts of water demand and supply, the emphasis is 
on a “socio-economic forecast” until 2027, thus not long term, with the aim to identifying the driving 
forces underlying the changes in water status and water consumption.  

23 

 
 
The investments, their costs and financing are specified in an Annex to the RBMP, but there doesn’t 
seem to be a clear comprehensive overview of the investments, in particular for those after 2027. 
The economic analysis also lacks assessments of the most cost-effective combination of measures.  

Water services are clearly identified in the RBMP at the hand of Hungary’s legal definition in place 
since the 1st RBMP25  namely:  1. Public water supply; 2. Urban  wastewater services; 3. Agricultural 
water supply (irrigation, fish farming, fishing, other); 4. Discharge and storage for hydroelectric power 
generation; and 5. Water abstraction for own use. Financial cost recovery rates have been calculated 
for these water services at national level.  

Importantly, the RBMP does not seem to report on water uses aside from water services. This directly 
implies that Hungary does not provide an account on whether the contributions of the various water 
user sectors (agriculture, industry households) can be considered adequate. .  

Financial  cost  recovery  rates  have  been  provided  at  national  level  for  the  various  water  services 
(except  self-abstraction) together with the underlying costs and revenues, but only one for water 
supply  and  sanitation  services  together,  and  for  hydropower  without  a  clear  specification  of  the 
underlying costs. Capital costs are reported for the former, but the presence of subsidies aimed to 
provide debt relief to water sector entities and also substantial grants in the funding of water utility 
investments (both reported in some detail), may have complicated the definition of capital costs and 
hence the interpretation of the reported cost recovery rates.   

The RBMPs provide further qualitative information on subsidies, including directly on the provision of 
water services, allowing setting water tariffs below cost break-even level. The RBMP states that about 
two third of the revenues of water utilities come from end users. The support scheme to agricultural 
water users has been reformed in 2017. The blanket payment exemption (in force since 2014) was 
replaced by subsidies covering less than full costs, but still considerable, namely on average about 
three quarters of the “basic costs” and about half of the variable costs. A large part of these subsidies 
take the form of a price exemption granted to the smaller irrigation water permits. The RBMP does 
not  provide a clear  explicit  account of the rationale of the subsidies, i.e. linking it explicitly to the 
mitigation factors and explaining sufficiently clearly the extent of the ‘established practices” clause. 

25 Act LVII of 1995 

24 

 
 
Figure 9 - Water abstraction by economic sector in Hungary between 2009 and 2019,  

Source: EEA Wise (using Eurostat data, but also OECD and own data) as Eurostat data are not available for all  economic 
sectors in all MS [1]. 

An overview of water tariffs is provided for the three broad water users sectors, namely households, 
industry and agriculture (including irrigation, fishing lakes and rice production) There is a flat unit rate 
in  place  for  all  consumption  levels  set  by  the  various  water  service  provides  thus  allowing 
geographical  variation  related  to  costs  differences  (albeit  possibly  dampened  by  subsidies).  In 
contrast to this qualitative information, the RBMP provides quantitative information on the structure 
and rates of water abstraction (called water resource charge) as well as pollution charges. 

The  RBMP  only  provides  a  general  assurance  that  the  actual  pricing  policies  in  place  provides 
adequate  incentives to  use  water  efficiently.  However,  the  provided information  suggests  that  the 
current price policies provide some incentives for a more efficient water use, but unevenly so over the 
water user sectors and also dampened by substantial subsidies In particular, while pricing has been 
introduced  for  the  water  uptake  in  the  agricultural  sector,  overall  there  still  appears  room  for 
improvements. 

The  RBMP  indicates  that  Hungary  has  a  national  methodology  in  place  for  the  assessment  of 
environmental and resource costs (ERC) , and it reports quantitative estimates for environmental and 
resource costs separately. Specific data or capacity problems are not mentioned in RBMP, but neither 
the use of dedicated economic and environmental model(s) of water economy. It is not fully clear 
how the calculated ERC have informed the rates of the pollution charges. 

There is some quantitative information on the structure and rates of water abstraction (called water 
resource charge) and pollution charges, for two water user sectors (households and industry) and for 

[1] Conventional statistic abstraction data of Eurostat, EEA and OECD exclude water disappearing after abstraction via 
leakages or evaporation from the surfaces of reservoirs and canals. Leakage and evapotranspiration losses can however 
be significant in Member States with many reservoirs and/or older distribution systems, as is illustrated by French data. 
Page 14, French analytical note on total water consumption (incl. evapotranspiration and losses) adding up to 54.000 
million m3 abstracted, instead of 30.000 million m3 used: 
https://www.strategie.gouv.fr/sites/strategie.gouv.fr/files/atoms/files/fs-2024-na_136_enjeux_et_usages_de_leau_avril.pdf 
. 

25 

 
 
 
water utilities (water supply and sanitation services), but it is not fully clear how the calculated ERC 
have informed the rates. 

However,  the  RBMP  presents  a  detailed  account  on  the  application  of  the  Polluter  Pays  Principle, 
namely that i.e. a water load fee is paid by all polluters discharging into water, including water utilities 
that pass the water load fee to final/end consumers. The amount of the water load feed is determined 
by the weight expressed in natural units of the total amount of the pollutant emitted each year, the 
unit fee for water pollutants, the area sensitivity factor, and the sludge disposal factor. 

In terms of subsidies, the RBMPs reported subsidies aimed at water users and subsidies provided as 
debt relief to actors in water sector. It has to be highlighted that for the agriculture sector, from 2017, 
there has been a significant alteration in the support scheme. In accordance with the established 
practices, the approach of providing agricultural water for free (payment exemption), which had been 
in effect since 2014, has been abolished. Regrettably, even though agricultural water uses were in 
principle subject to the obligation to pay a water resource charge, exemptions were introduced at the 
same time e.g. no water resource charge will be payable "for irrigation water use, for the amount of 
water per hectare per water right permit not exceeding 400,000 m3 per year”. This has substantially 
reduced the payment of the water resource charge for water used for agricultural irrigation. 

6. WFD recommendations 

Recommendations - Hungary should: 

1. 

Increase the level of ambition and accelerate actions to reduce the compliance gap as much as possible 
until the next reporting cycle i.e. by 2027. This implies: 

a.  Tackling obstacles identified in the implementation of measures such as administrative capacities 

and resources; 

b.  Design and implement robust and proportionate measures to address water abstraction including 
illegal  abstraction  and  water  scarcity  issues.    For  example,  consider  revision  of  the  existing 
concession,  authorisation,  and  /  or  permitting  regime  to  control  surface  and  groundwater 
abstractions, as well as its enforcement. Unauthorised water abstraction from both surface water 
and groundwater bodies should be tracked and addressed effectively.  

2. 

Increase investments and ensure adequate funding including implementation of cohesion funding to 
effectively  implement  the  Programmes  of  Measures  to  reach  the  objective  of  the  WFD  by  e.g. 
developing  long  –  term  investment  plans  and  clearly  identifying  the  source  of  financing  for 
implementation of all measures in particular related to wastewater treatment and decontamination 
of sites.  

3. 

Identify and put in place additional measures to reduce existing persistent environmental challenges 
(pressures) preventing the achievement of good status. This implies for example: 

a. 

b. 

the measures show concretely the expected results to achieve the objectives set for each water 
bodies; 
reduction of nutrients and other chemical pollution including setting of nutrient loads to achieve 
the objectives of WFD and Nitrates Directive.; 

c.  Stepping up efforts for the implementation of all necessary restoration and mitigation measures 

by especially prioritising nature-based solutions; 

26 

 
d.  For  Heavily  Modified  Water  Bodies,  Hungary  should  provide  an  economic  or  other  analysis  to 
assess  the  beneficial  objectives  served  by  other  means  which  are  a  significantly  better 
environmental option;  

e.  The  mitigation  measures  shows  exactly  how  their  implementation  improve  the  status  of  the 

various BQEs; 

f.  Hungary should continue its efforts to implement and report hydro morphological measures for 
all  water  bodies  affected  by  hydro  morphological  pressures  also  to  meet  international 
commitments  to  remove  obstacles  to  river  continuity.  Given  the  importance  of  the  hydro 
morphological  pressures  to  cause  failure  in  ecological  status  in  Hungary  mitigating  measures 
should receive priority attention wherever possible. 

4. 

In the light of the water scarcity challenge experienced by across the EU, Hungary should: 

a.  Proactively  establishes  an  explicit  link  between  the  implementation  of  e-flows  and  the 
authorisation process and / or review of permits to control water abstractions and impoundments, 
also considering further impacts from climate change;  

b.  Enhance the international cooperation on water abstraction and water scarcity considering the 

climate and socio-economic changes in the Danube; 

c.  Give information on how the projected impacts of drought including an analysis of climate change 

impacts on existing pressures at water body-level are assessed; 

d.  Take effective measures to promote water reuse; 
e. 

If/when planning new dams or reservoirs, carefully assess their environmental impacts, including 
as regards the objectives of the WFD and ensure that such interventions are part of coherent 
water resilience strategies, which, amongst others, duly considers long-term climate scenarios. 

5.  To more effectively achieve the objectives of the WFD, Hungary should further enhance transboundary 

cooperation in particular:  

a.  Delineation and characterization of the water bodies as well as status assessment methodologies 

(e.g. commonly agreed reference conditions for biological quality elements); 

b.  Clear explanation should be provided on how the Hungarian RBMP contributes to addressing the 
MSFD’s objectives and the overall coherence in the implementation of the WFD and MSFD (under 
the cooperation carried in the international RBMP) and also to the achievement of the Danube 
nutrient reduction targets; 

c.  Harmonisation efforts  

i.  towards a better comparable assessment of significant morphological alterations; 
ii.  between data on significant hydromorphological pressures on national and international 

level and data reported on implementation of hydromorphological measures. 

6.  On the use of economic tools, Hungary should: 

a. 

b. 

c. 

consider re-evaluating its pricing policies so that to provide incentives for a more efficient water 
use;  
continue  to  present  transparently  how  financial,  environmental  and  resource  costs  have  been 
calculated and how the adequate contribution of the different users is ensured;  
to continue to transparently present the water-pricing policy and provide an overview of estimated 
investments and investment needs. 

7.  As regards monitoring, assessment, data management and reporting Hungary should: 

a.  Further strengthen the application of the national methodology to define significant pressures, 

across RBDs, and limit reliance on expert judgement; 

27 

 
b.  provide detail information on the inventory of emissions, discharges and losses and particularly 

links to the pressure assessment; 

c.  provide details of the substances are discharged into water and are included in the monitoring 

d. 
e. 

program; 
include the trend analysis as a result of long-term surveillance undertaken in biota and sediments 
improve  the  groundwater  chemical  status  assessment  methodology,  including  coordination  of 
threshold values with neighbouring countries; details on how the baseline levels for substances, 
which  occur  both  naturally  and  from  anthropogenic  sources  are  considered  as  part  of  trends 
assessment;  details  on  how  upward  trends  are  distinguished  from  natural  variation  with  an 
adequate level of confidence and precision; 

f.  maximise the efforts to ensure electronic reporting of WFD data to facilitate comparison between 
implementation cycles and allow for easier monitoring of progress in reaching the objectives of 
the WFD; 
continue the efforts to transparently justify every exemption; 

g. 
h.  ensure that all measures necessary for achieving good status or potential by end of 2027 are 
identified  and  initiated  (implemented)  during  this  cycle,  to  avoid  unjustified  time  exemptions 
beyond 2027 (i.e. other than exemptions based on natural conditions) or an unjustified conversion 
to  Article  4(5)  exemptions  in  2027  (i.e.  other  than  based  on  objectively  established 
disproportionate costs/unfeasibility after identification of all measures necessary to achieve good 
status); 
Ensure a proper implementation of Article 4.7 in relation to all projects potentially deteriorating 
status of water bodies (also if this would only be temporary).  

i. 

28 

 
 
SECTION B: 
FLOODS DIRECTIVE 

29 

 
 
 
7. Flood risk management under floods directive (FD) 

The Directive requires each Member State (MS) to scan its territory for flood risks, assess the potential 
adverse  consequences  of  future  floods  for  human  health,  the  environment,  cultural  heritage  and 
economic  activity,  identify  the  significant  risks,  map  the  flood  extent  and  the  potential  adverse 
consequences, and take measures to reduce the flood risk. These activities are reflected in (a) the 
preliminary  flood  risk  assessments,  or  PFRAs  (including  the  identification  of  areas  of  potential 
significant flood risk, or APSFRs), (b) the preparation of flood hazard and risk maps, or FHRMs, and (c) 
the establishment of flood risk management plans, or FRMPs. The preliminary assessments, mapping 
and planning for flood risk are repeated in six-year cycles. 

There is one Unit of Management (UoMs) in Hungary, which is the same as the Water Framework 
Directive’s  River  Basin  Districts  (RBD).  Fluvial,  pluvial,  and  groundwater  floods  are  considered  as 
potentially  significant  sources  of  flooding  in Hungary.  Hungary  designated  419  Areas  of  Potential 
Significant Flood Risk (APSFRs). The impacts of climate change on flood risk have been considered in 
Hungary at the time of the second preliminary flood risk assessment. There is an extended summary 
on  how  climate  change  issues  were  taken  into  consideration  including  the  update  of  the  climate 
scenarios,  what  internationally  recognized  climate  models  were  adopted  and  used  to  model 
temperature, precipitation, etc. climate parameters and how these will impact the hydrological and 
drought processes in the 2021-2050 and 2071-2100 periods. 

7.1 Flood hazard and risk maps 

At the time of the first PFRAs Hungary identified two APSFRs. For the second FHRMs information for 
23 APSFR was reported in EIONET, which is far less than the 419 APSFRs Hungary reported at the 
time of the second PFRAs. In the first FHRMs Hungary included fluvial and groundwater floods, not 
directly related to APSFRs. In the second FHRMs fluvial and groundwater floods are mapped on the 
basis of eight planning unit areas (which it is not clear how they compare to the APSFRs). 

Hungary is using a website which includes PDF format FHRMs26, as a result it is difficult to get an 
overview.  FHRMs  were  prepared  at  the  national  level  and  show  the  whole  country.  Hungary  has 
identified  23  APSFRs,  for  which  it  is  unclear  if  all  have  been  mapped27.  Maps  for  floods  with  low 
probability (fluvial/river floods (1/1 000 years) and for pluvial/streams and groundwater floods (1/100 
years)),  with  medium  probability  (fluvial/river  floods  (1/100  years)  and  for  pluvial/streams  and 
groundwater  floods  (1/33,3  years))  and  with  high  probability  (fluvial/river  (1/30  years)  and  for 
pluvial/streams and groundwater floods (1/10 years)) are provided. Flood extent is shown on all maps. 
Water depth is shown on all maps. Number of inhabitants is shown on all maps. Likewise, type of 
economic activity and IED installations are shown. Potentially affected protected areas identified in 
Annex IV(1)(i), (iii) and (v) to Directive 2000/60/EC are not shown consistently in the FHRMs for bathing 
sites and abstraction for drinking water, however there are some pdf maps for specific locations. 

In terms of changes of contextual information (i.e. the way in which information about the maps is 
conveyed to the public) since the first FHRMs, albeit still in pdf format, more detailed FHRMs have 

26 https://vizeink.hu/akk-elso-felulvizsgalata/#up01, dedicated to flood risk management, provides access to FHRMs. 

27 Hungary subsequently clarified that APSFR areas were merged from 419 to 23 (without though the total surface having 
been reduced), where eight plus eight planning units are affected by fluvial and ground water flooding and seven planning 
units are affected by pluvial flooding. 

30 

 
 
been published for the eight planning units (as opposed to a less detailed FHRM covering the entire 
country). Also there is a detailed methodological description on the updating of the maps; and the 
preparation of medium and high probability maps for groundwater flooding. 

In  terms  of  changes  in  methodologies  used  to  prepare  flood  hazard  maps  since  the  first  FHRMs, 
Hungary used an improved methodology to prepare updated versions of the flood hazard maps and 
more  detailed  databases  to  prepare  the basic modelling  information.  In  the  case  of  groundwater 
floods,  medium  and  high  probability  maps  were  produced  in  addition  to  the  low  probability  map 
already prepared at the time of the first FHRMs. 

In terms of changes in methodologies used to prepare flood risk maps since the first FHRMs, risks to 
inhabitants, to economic activity, to IED installations and (partially) to WFD protected areas are shown 
on the pdf maps. 

Climate change in the second FHRMs 

As regards the consideration of climate change effects in the preparation of flood hazard and risk 
maps, reference is made to section 3.7 on ‘adaptation to climate change’.    

7.2 Flood risk management plans 

Objectives and measures 

The  FRMP  is  publicly  accessible  and  can  be  downloaded  from  a  webpage28  which  is  part  of  the 
government website on water management. The Hungarian FRMP sets a main objective and identifies 
additional principles and objectives for flood risk management, also citing objectives from a separate 
water management plan, the 2017 Kvassay Jenő Plan (KJT). The objectives refer to the protection of 
human health. The FRMP also identifies “long-term” objectives, which refer to land use and spatial 
planning, though it is not clear how these long-term objectives are related to the other objectives. 
The FRMP does not specifically set out objectives that refer to the protection of economic activity, 
though  it  does  cite  the  FD’s  provision  (in  Article  7(2))  that  this  should  be  addressed.  The  FRMP’s 
objectives state that, during the implementation of measures to reduce the flood risk, undesirable 
environmental effects should be minimised. The FRMP also cites the KJT’s objectives, which refer to 
coordinated management and preservation of activities related to, among others, natural resources 
and  natural  values.  The  FRMP  moreover  cites  the  FD’s  provision  (in  Article  7(2))  stating  that 
environment should be addressed. The objectives do not refer to the protection of cultural heritage, 
though it does cite the FD’s provision (in Article 7(2)) that this should be addressed. The second FRMP 
identifies 49 new, potential flood risk management projects. In addition, 45 measures were reported 
to EIONET: these appear to be projects set out in the first FRMP. The 49 new, potential projects have 
been chosen based on prioritisation using cost-benefit analysis. The FRMP does not explain how the 
new projects will be monitored. Project reports have been prepared for the 45 measures reported to 
EIONET, many of which have been completed. Hungary has reported priority for the measures. Almost 
all measures (43 out of 45 measures, or 96 % of the total) are moderate priority. One measure is 
high priority, and another one is very high priority: these are both protection measures. 

28 https://vizeink.hu/akk-elso-felulvizsgalata/#up01  

31 

 
 
 
The costs and benefits of 28 of the 45 projects reported to EIONET are provided. The FRMP provides 
the costs of the 49 proposed new projects, which were prioritised based on cost-benefit analysis. The 
FRMP provides little further information on funding sources, though its discussion of public awareness 
actions includes a reference to the national  budget. The FRMP identifies water retention as a key 
element of flood risk management. While it refers in particular to structural water retention projects, 
the FRMP also mentions the role of natural water retention. The FRMP calls for the harmonisation of 
flood risk management measures with WFD objectives. The FRMP provides an overview of the impact 
of floods on Natura 2000 sites in floodplains but provides few details on nature conservation in its 
measures. The FRMP refers to long-term flood prevention by addressing land use in floodplains. The 
new  projects  listed  in  the  FRMP  have  a  strong  focus  on  flood  protection.  Three-quarters  of  the 
measures reported to EIONET are for flood protection. The FRMP refers briefly to emergency planning. 
One  preparedness  measure  was  reported  to  EIONET.  As  noted  above,  the  FRMP  refers  to  the 
importance of spatial planning and land use in flood plains. 

The second FRMP does not specify indicators that could be used to assess progress towards its own 
objectives. The FRMP and a separate document state however that risks in flood plains protected by 
embankments and other structural measures have decreased by 10 % with the implementation of 
structural  projects  under  the  first  FRMP.  The  FRMP  notes  that  this  is  based  on  a  simplified  risk 
assessment that focuses on property risks over a 30-year period; the risk-reduction effect of each 
project is assessed separately. Moreover, the second FRMP presents estimates of the risk reduction 
obtained under each of the 28 projects (for which costs and benefits were calculated) under the first 
FRMP, using this approach.  

In Hungary’s reporting to EIONET, half of the measures (23 measures) are indicated as completed. 
Thirteen measures are reported as on-going construction; four measures as on-going recurrent (e.g. 
maintenance  works).  The  sole  preparedness  measure  is  reported  as  completed,  along  with  18 
protection  measures  and  three  prevention  measures.  The  only  recovery  and  review  measure  is 
reported  as  on-going  recurrent,  along  with  one  protection  and  two  prevention  measures.  Ten 
protection and three prevention measures are on-going construction. Three protection measures are 
reported as abandoned or interrupted. Two protection measures (4 %) are reported as not started. 
These are for the first and second phase of the ‘Differentiated embankment development strategy’, 
which has not yet been implemented29. It appears that this strategy refers to the preparation of the 
strategy for the future projects identified in the FRMP. 

Hungary’s  second  FRMP  provides  an  estimate  of  the  costs  for  many  but  not  all  of  its  measures 
reported  to  EIONET.  The  FRMP  provides  cost  estimates  for  its  proposed  new  projects.  The  FRMP 
describes the method used to select and prioritise its new measures on the basis of flood risks and 
costs and benefits. (For measures reported to EIONET, however, all but two are indicated as having 
‘moderate’ priority, so only a minor change compared to reporting for the first FRMP.) The number of 
measures remains unclear, in particular in terms of the relationship between the measures reported 
to EIOENT, those listed in the FRMP, and those listed in other documents uploaded to EIONET. 

Governance 

29 FRMP, chapter 6.1.2. 

32 

 
 
The FRMP does not discuss transboundary coordination, either within the International Commission 
for the Protection of the Danube River (ICPDR), which has prepared an international FRMP for the 
whole Danube basin, or bilaterally with neighbouring Member States. 

The FRMP30 provides only limited information on public consultation mechanisms, though it indicates 
that  documents  and  information  on  stakeholder  meetings  were  available  online31  and  that 
consultation lasted for six months. 

Consideration of climate change 

As regards the consideration of climate change effects in the preparation of flood risk management 
plans, reference is made to section 3.7 on ‘adaptation to climate change’.    

Progress identified in the second FRMPs 

Hungary’s second FRMP provides an estimate of the costs for many of its measures. It also provides 
cost estimates for its proposed new projects. Moreover, the FRMP describes the method used to select 
and prioritise its new measures on the basis of flood risks and costs and benefits. Hungary reported 
half of its measures completed, a major increase from the first to the second FRMP. In addition, the 
second FRMP briefly refers to the role of insurance. The FRMP refers to the use of CBA for packages 
or ‘variants’ of flood risk protection projects. The second FRMP makes clearer references to climate 
change impacts and to adaptation, which can be considered progress. The FRMP also cites Hungary’s 
Second National Climate Change Strategy and its actions. Further, the FRMP provides an analysis of 
flash-flood risks related to climate change, identifying local areas that are facing these risks. 

8. FD recommendations 

Based  on  the  reported  information  and  the  FHRMs  and  FRMPs  assessed  and  uin  addition  to  the  progress 
achieved, Hungary should: 

• 

• 

• 

• 

• 

produce a national GIS based portal for FHRM, with easy access for the public; 

reflect clearly also in the FHRM the potential future impacts of climate change (also based on future 
scenarios), or discuss such in a background document; 

provide detail on how the FHRM was used in the choice of objectives and measures of the FRMPs; 

include summary maps of APSFRs in the FRMP; 

include information on the international coordination undertaken with other Member States via the 
international river basin commission during the development of the PFRA the FHRM and the FRMP; 

30 FRMP, chapter 6.1. 
31 https://vizeink.hu/ 

33 

 
 
• 

• 

• 

• 

• 

• 

• 

include in the FRMP specific objectives  and where possible linked to quantitative indicators and be 
timebound. An assessment of the progress made towards the achievement of the objectives should 
be included in the FRMP; 

clarify the links and priorities between different objectives, principles and sub-objectives in the FRMP; 

set out the methods used to monitor measures in the FRMP; 

 discuss provisions on the protection of cultural heritage at risk from flooding in the FRMP; 

set out the nature and number of measures that are being and will be implemented in the FRMP; 

there  seems  to  be  a  single  preparedness  measure  in  the  FRMP,  for  one  specific  area,  and  it  is 
completed. Consider a review for a need of additional preparedness measures. 

provide  detail  on  the  public  consultation  and  active  stakeholder  involvement,  in  particular,  the 
comments received, and how they were taken into account in the final plan; 

•  where  appropriate,  consider  in  the  FHRM  flow  velocity  or  relevant  water  flow  and  the  FRMP  flood 

conveyance routes, as these are relevant to emergency response. 

34