COMMISSION STAFF WORKING DOCUMENT 2026 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 2026 Rule of Law Report The rule of law situation in the European Union
Date: 2026-07-17
Institutions: European Commission, Secretariat-General
Subjects: Hungary, administrative transparency, corruption, democracy, freedom of the press, human rights, independence of the judiciary, pluralism in the media, rule of law, whistleblowing

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 17.7.2026  SWD(2026) 917 final  COMMISSION STAFF WORKING DOCUMENT 2026 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 2026 Rule of Law Report                           The rule of law situation in the European Union {COM(2026) 900 final} - {SWD(2026) 901 final} - {SWD(2026) 902 final} - {SWD(2026) 903 final} - {SWD(2026) 904 final} - {SWD(2026) 905 final} - {SWD(2026) 906 final} - {SWD(2026) 907 final} - {SWD(2026) 908 final} - {SWD(2026) 909 final} - {SWD(2026) 910 final} - {SWD(2026) 911 final} - {SWD(2026) 912 final} - {SWD(2026) 913 final} - {SWD(2026) 914 final} - {SWD(2026) 915 final} - {SWD(2026) 916 final} - {SWD(2026) 918 final} - {SWD(2026) 919 final} - {SWD(2026) 920 final} - {SWD(2026) 921 final} - {SWD(2026) 922 final} - {SWD(2026) 923 final} - {SWD(2026) 924 final} - {SWD(2026) 925 final} - {SWD(2026) 926 final} - {SWD(2026) 927 final} - {SWD(2026) 928 final} - {SWD(2026) 929 final} - {SWD(2026) 930 final} - {SWD(2026) 931 final}  
 
 
ABSTRACT 

The  new  Government  has  engaged  in  intense  reform  efforts  to  restore  the  rule  of  law. 
Following continued dialogue with the Commission under the Recovery and Resilience Plan 
and the general regime of conditionality, several legislative reforms  were advanced. Further 
constitutional  amendments  are  being  considered  regarding  the  justice  system,  the  anti-
corruption framework and institutional issues related to checks and balances. 

The National Judicial Council continued to exercise the powers it acquired through the 2023 
judicial  reform.  In  January  2026,  the  Council  issued  statements  in  defence  of  judges  who 
faced  undue  pressure.  The  Kúria  continued  to  enforce  uniformity  of  case  law  through  its 
uniformity  panel. The transparency of case allocation in  lower-instance courts has  not  been 
improved. The election procedure for the Prosecutor General, combined with the hierarchical 
structure  of  the  prosecution  service,  gives  rise  to  a  risk  of  undue  political  interference  in 
individual  cases.  Salaries  in  the  justice  system  have  been  increased  further,  while  no 
measures have been taken to ensure that such increases are carried out in  a structured way. 
The justice system performs efficiently overall. 

New legislation adopted in June 2026 aims to tackle obstacles to the effective functioning of 
the Integrity Authority and the Anti-Corruption Task Force. The number of indictments  for 
corruption-related  crimes  has  generally  increased  but  there  has  so  far  been  no  progress  to 
establish  a  robust  track  record  in  cases  of  high-level  corruption.  Following  Hungary’s 
request, the Commission has confirmed Hungary’s participation in the EPPO. Newly adopted 
legislation strengthens the Integrity Authority and improves the system of asset declarations, 
providing  for  effective  oversight  and  enforcement.  No  steps  have  been  taken  yet  to  adopt 
comprehensive legislation on lobbying and revolving doors, and shortcomings related to the 
transparency of the financing of political parties remain. New legislation addresses corruption 
risks  in  public  procurement  procedures  and  increases  the  transparency  of  private  equity 
funds.  

Legislation  adopted  in  June  2026  amending  the  Media  Act  introduces  reforms  to  both  the 
rules governing the national media regulator, as well rules on the governance and funding of 
public service broadcasting. Transparency and fairness in the distribution of state advertising 
has  not  been  addressed  yet.  Although  the  processing  of  court  cases  relating  to  access  to 
information  has  been  accelerated,  the  scope  of  access  remains  limited,  particularly  with 
regard  to  the  use  of  public  funding.  Several  journalists  and  other  media  professionals 
encountered serious challenges to their work during a large part of the reporting period.   

The former Government used its emergency powers extensively, undermining legal certainty 
and affecting businesses’ ability to operate in the single market. Upon expiry of the ‘state of 
danger’ on 13 May 2026, the new government did not extend it further. Foreign companies 
operating  in  strategic  sectors  continue  to  face  intensified  regulatory  pressure  from  state 
action. The legal framework that allows the selective application of competition rules further 
weakens  legal  certainty  for  businesses.  The  absence  of  procedural  safeguards  and  effective 
oversight  in  the  event  of  secret  surveillance  measures  remains  a  concern.  The  Sovereignty 
Protection  Office  has  been  abolished,  whilst  obstacles  hindering  the  work  of  independent 
civil  society organisations  are  yet  to  be removed.  Under the new legislation, public interest 
trusts will be phased out. 

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RECOMMENDATIONS 

Overall, based on the recommendations in  the 2025 Rule of Law Report, considering other 
developments  that  took  place  in  the  period  of  reference,  and  in  addition  to  recalling  the 
obligation  to  comply  with  the  rule  of  law-related  rulings  of  the  CJEU  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  country-specific  recommendations 
under  the  European  Semester  on  reinforcing  the  anti-corruption  framework  and  the  quality 
and transparency of the decision-making process, the Commission concludes the following:  

•  No  progress  has  been  made  on  the  transparency  of  case  allocation  systems  in  lower-
instance courts, as the previous government limited itself to addressing deficiencies in the 
rules  on  case  allocation  at  the  level  of  the  Kúria.  Therefore,  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.  

•  No  further  progress  has  been  made  yet  to  ensure  that  the  ongoing  increase  in  the 
remuneration of judges, prosecutors and judicial and prosecutorial staff is carried out in a 
structured manner. Therefore, it is recommended to Hungary to take measures to ensure 
that  the  ongoing  increase  in  the  remuneration  of  judges,  prosecutors  and  judicial  and 
prosecutorial  staff  is  carried  out  in  a  structured manner,  taking  into  account  European 
standards on remuneration for the justice system. 

•  As new legislation was adopted that further develops the system of asset declarations, the 
recommendation  to  further  improve  the  system  of  asset  declarations  and  provide  for 
effective  oversight  and  enforcement  has  been  fully  implemented.  No  progress  has  been 
made  yet  on  putting  forward  comprehensive  legislative  reforms  on  lobbying  and 
revolving doors. As these gaps in integrity rules remain unaddressed, it is recommended 
to Hungary to strengthen the integrity framework by adopting comprehensive legislative 
reforms on lobbying and revolving doors.  

•  No  progress  has  been  made  on  establishing  a  robust  track  record  of  investigations, 
prosecutions and final judgments for high-level  corruption cases, given that the positive 
changes recently initiated in the anti-corruption framework have not yet come into effect. 
Therefore,  it  is  recommended  to  Hungary  to  take  further  measures  to  ensure  a  track 
record  of  investigations,  prosecutions  and  final  judgments  for  high-level  corruption 
cases. 

•  Some progress has been made to ensure that there are no obstacles hindering the work of 
civil society organisations and foster a safe and enabling civic space, given measures such 
as  the  abolition  of  the  Sovereignty  Protection  Office  were  taken,  while  legislation 
hampering their capacity of working has not been repealed. Therefore, it is recommended 
to  Hungary  to  further  ensure  that  there  are  no  obstacles  hindering  the  work  of  civil 
society  organisations,  including  by  repealing  legislation  that  hampers  their  capacity  of 
working, and to further foster a safe and enabling civic space. 

2 

 
 
 
 
As regards the other 2025 recommendations, the Commission concludes that: 

•  Some  progress  has  been  made  on  introducing  mechanisms  to  enhance  the  functional 
independence  of  the  media  regulatory  authority  taking  into  account  European  standards 
on  the  independence  of  media  regulators,  in  the  light  of  recent  legislation  which  has 
introduced reforms in this area.  

•  No progress has been made yet to ensure fair and transparent distribution of advertising 
expenditure by the state and state-owned companies, as no legislative or other measures 
have been proposed.   

•  Some progress has been made 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,  in  the  light  of  recent  legislation 
which has introduced reforms in this area.  

Given that the topics  of  the three recommendations above are covered by provisions of the 
European  Media  Freedom  Act  (EMFA),  while  the  Rule  of  Law  Report  will  continue  to 
monitor  significant  developments  and  report  on  their  impact,  further  follow-up  will  be 
ensured  as  part  of  the  Commission’s  support  to  Member  States  and  enforcement  of  the 
EMFA. 

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I. 

JUSTICE SYSTEM1  

Independence  

The  level  of  perceived  judicial  independence  in  Hungary  continues  to  be  low  among 
both the general public and companies. Overall, 31% of the general population and 33% of 
companies perceive the level of independence of courts and judges to be ‘fairly or very good’ 
in  20262.  The  perceived  level  of  independence  among  the  general  public  has  significantly 
decreased in  comparison with 2025 (38%), as well as in comparison  with  2022 (43%). The 
perceived level of judicial independence among companies has decreased since 2025 (38%) 
and has slightly decreased in comparison with 2022 (34%). 

The National Judicial Council has continued to exercise the powers it acquired through 
the  2023  judicial  reform3.  In  particular,  the  National  Judicial  Council  (NJC)  rejected  the 
decisions  of  the  President  of  the  National  Office  for  the  Judiciary  (NOJ)  to  annul  the 
application  procedures  for  two  judicial  posts,  and  did  not  agree  with  the  secondment  of  a 
judge  to  the  National  Directorate-General  for  Hospitals  and  with  the  temporary  transfer  of 
two judges4. In 2025, the NJC requested the NOJ President on three occasions to grant access 
to documents in order to get acquainted with the proposals and comments received from the 
courts  in  connection  with  certain  bills  and  regulations5.  The  NJC  seized  the  Constitutional 
Court  twice  to  defend  its  prerogative  to  be  consulted  on  legislative  proposals  affecting  the 
justice system6. On 18 May 2026, the NJC proposed that the procedural rules introduced in 
2025 obliging the court to pay the parties a daily lump sum as compensation for any breach 
of  a  procedural  deadline  by  the  judge  hearing  the  case  be  repealed7.  On  the  same  day,  the 
Council gave a positive opinion on the suitability of a candidate for the post of Kúria Vice-
President8. 

The National Judicial Council has approved the findings of a report exploring measures 
to make the Council more effective. The report prepared by an ad hoc committee9 proposes 

1   An overview of the institutional framework for all four pillars can be found here.  
2   Figures 48 and 50, 2026 EU Justice Scoreboard and Figures 51 and  53, 2024 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   See 2023 Rule of Law Report, Hungary, pp. 3-5. Hungary adopted a legislative reform which established 
stronger powers for the NJC and ensures that the  NJC gives a binding opinion on a number of important 
matters related to the administration of the justice system as regards both individual decisions and general 
regulations issued by the NOJ President. The NJC now has access to all documents, information and data 
related to the administration of courts. It also needs to be consulted on legislative proposals  affecting the 
justice system and is able to propose to the Government to initiate new legislation on the same matters. 
4   Decisions 76/2025 of 11 June 2025, 99/2025 of 15 July 2025, 115/2025 of 3 September 2025, and 147/2025 

of 5 November 2025. 

5   Country visit Hungary, Hungarian Government, 
6   See  Section  108/A(9)  of  the  Organisation  and  Administration  of  Courts  Act  and  Section  36/A(1)  of  the 
Constitutional Court Act. On 9 September 2025, the Constitutional Court dismissed the NJC’s application 
related to  the adoption of the 2025 judicial reform (see 2025 Rule of Law  Report,  Hungary, p. 5). On  19 
February  2026,  the  NJC  challenged  Government  Decree  15/2026  of  3  February  2026,  an  emergency 
measure  obliging courts to discontinue ongoing cases related to the  ‘solidarity levy’; on 6 May 2026, the 
Constitutional  Court  annulled  the  justice-related  provisions  of  the  emergency  measure  with  retroactive 
effect (case IX/00673/2026) (see pillar IV). 

7   Decision 73/2026 (V.18.) OBT. See 2025 Rule of Law Report, Hungary, p. 10. 
8   Decision 72/2026 (V.18.) OBT. 
9   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 framework (2024 Rule of Law Report, Hungary, p. 

4 

 
 
several  amendments  to  the  Organisation  and  Administration  of  Courts  Act.  These  include 
extending  the  NJC’s  supervisory  powers  over  the  administrative  activity  of  the  Kúria 
President10. Furthermore, the report suggests extending the NJC’s supervisory powers to also 
cover the publication of calls for applications to judicial posts by the NOJ President and the 
Kúria President. It  also proposes requiring the Minister of Justice to  issue a new decree  on 
the points system applicable to the assessment of applications for judicial posts, in order to 
enable  the  NJC  to  exercise  its  co-decision-making  powers  in  that  respect.  Additionally,  the 
report suggests changing the way Kúria judges are represented in the NJC11, and introducing 
the possibility of re-electing NJC members. The NJC approved the report on 1 July 2026. 

In  January  2026,  the National  Judicial  Council  issued  statements  in  defence  of  judges 
who  faced  undue  pressure.  A  number  of  judges  continued  to  face  undue  pressure, 
particularly in  relation to internal and public debates concerning key issues such as judicial 
independence and the freedom of expression of judges. In November and December 2025, it 
was reported that several judges were subject to political attacks and smear campaigns based 
on leaked personal data12. The presidents of the courts where the affected judges adjudicate 
did  not  condemn  the  attacks  but  launched  internal  investigations  into  the  integrity  of  those 
judges13, while public statements by the Kúria President put into question the impartiality of 
the  judges  concerned14.  Subsequently,  the  NJC  issued  statements  in  defence  of  judicial 
independence and judges’ freedom of expression, which then led to a public debate within the 
NJC and between the NJC and the Kúria President15.  

Amendments to the rules regarding the career of judges will further strengthen judicial 
independence.  The  omnibus  law  of  June  2026  removed  the  transitional  provision  allowing 
sitting  members  of  the  Constitutional  Court,  who  have  already  become  judges  without 
following the normal  application procedure, to  be appointed to  the  regional  appeal  court of 

5).  See  also  National  Judicial  Council  (2025),  pp.  71-73;  National  Judicial  Council  (2026b),  pp.  23-48; 
National Judicial Council (2026a), p. 8.  

10   The NJC’s powers do not extend to supervising the administrative duties of  any court president, including 

those of the Kúria President (Kúria, written reply). 

11   The NJC 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. 

12   See NJC (2026), p. 9; Hungarian Association of Judges (2026), pp. 9-10, 21; MEDEL (2026), pp. 10-11. 
13   Integrity  procedures  are  governed  by  internal  regulations,  and  court  presidents  conduct  investigations 
without the safeguards offered by service courts. The service courts are composed of members elected by 
the NJC from among judges, hear cases related to the assessment, fitness for office and disciplinary liability 
of judges. The Kúria President regularly questions in public the legitimacy of the service courts (2025 Rule 
of Law Report, Hungary, p. 7). See also HVG.hu (2026). 

14   On 6 November 2025, the Kúria issued a press release suggesting that the concerned judges might be held 
responsible for breaching their duties, and stating that if the  Kúria received credible information, it would 
be ready to conduct the appropriate procedures (Kúria (2025b)). 

15   Kúria (2025b), Kúria (2026). In January 2026, the NJC rejected a motion by five of its judges-members to 
amend  the  Code  of  Ethics  for  Judges,  which  would  have  clarified  that  registering  with  a  political  party 
constitutes political activity that is prohibited for judges (National Judicial Council (2026c), pp. 7-26). On 
11 June 2026, the Constitutional Court rejected the motion filed by the Kúria President that questioned the 
NJC’s competence to issue a Code of Ethics and highlights the absence of a reference to the Fundamental 
Law in its text. The Constitutional Court found that it cannot review the Code of Ethics because it is not a 
normative act. The Constitutional Court established ex officio as a constitutional requirement that if ethical 
rules  affect  the  legal  status  of  judges,  the  guarantees  pertaining  to  them  must  be  regulated  in  statute.  It 
called upon Parliament to fulfil its legislative duty by 31 March 2027 (Decision 4/2026. (VI. 19.) AB). 

5 

 
 
their  choice  after  their  service  at  the  Constitutional  Court16.  In  June  2026,  the  new 
Government submitted a draft constitutional amendment (‘the Seventeenth Amendment’) for 
public consultation; it was adopted by the National Assembly on 13 July 2026 and is yet to be 
promulgated.  The  Seventeenth  Amendment  to  the  Fundamental  Law  would  allow  the 
judiciary  to  play  a  more  decisive  role  in  the  appointment  and  removal  from  office  of  the 
Kúria President and the NOJ President17. 

The  Kúria  continues  to  enforce  uniformity  of  case  law  through  its  uniformity  panel18. 
From  1  January  2026,  the  Kúria’s  role  in  ensuring  case  law  consistency  was  reinforced  by 
expanding  the  scope  for  reviewing  binding  lower  court  judgments  on  points  of  law19.  A 
uniformity  decision  of  the  Kúria  is  binding  on  all  courts20.  Under  national  law,  only  the 
Kúria’s  uniformity  panel  may  amend  or  set  aside  a  uniformity  decision21.  Also,  the 
adjudicating panels of the Kúria may only depart from the legal interpretation set out in the 
Kúria’s  published  precedent  decisions  by  initiating  a  uniformity  procedure  before  the 
uniformity panel. The Kúria considers that only the uniformity panel can remove the binding 
force  of  the  legal  interpretation  provided  by  the  Kúria  in  previously  published  precedent 
decisions.  According  to  the  Kúria,  where  such  precedent  decision  of  the  Kúria  would  be 
contrary to the interpretation given by the Court of Justice of the EU (Court of Justice), the 
Kúria’s  uniformity  panel  would  need  to  decide  on  the  binding  force  of  such  precedent 
decision  of  the  Kúria22.  In  2024,  the  Court  of  Justice  already  confirmed  in  a  preliminary 
reference from a Hungarian court that any court must be able to disregard any binding ruling 
of a national court if it considers, in the light of the interpretation of EU law provided by the 
Court  of  Justice,  that  such  ruling  is  not  consistent  with  EU  law23.  Certain  uniformity 
decisions  have  raised  questions  of  compatibility  with  existing  preliminary  rulings  of  the 
Court of Justice. This has prompted courts to refer further questions to the Court of Justice24.  

There has been no progress on the recommendation to improve the transparency of case 
allocation  in  lower-instance  courts25.  According  to  the  former  Government,  there  was  no 
need  to  revise  the  legislation  applicable  to  case  allocation  in  lower  courts26.  Stakeholders 

16  Section  41  of  the  omnibus  law  of  June  2026  amending  Section  232/X(1)  of  the  Legal  Status  and 

Remuneration of Judges Act. See also 2023 Rule of Law Report, Hungary, p. 7. 

17  T/324. 
18   The ‘uniformity complaint panel’ was renamed to ‘uniformity panel’ as of 15 February 2026. 
19   Act XLIX of 2025 amended the Code of Civil Procedure by allowing the parties in each case to request that 
the  Kúria review the binding decision of the lower-tier courts on points  of  law. This means that all legal 
disputes now may be considered by the Kúria, enabling the highest court to provide an interpretation of the 
law that lower courts must adhere to. 

20   See  Article  25(3)  of  the  Fundamental  Law.  If  a  departure  nevertheless  occurs,  the  parties  may  avail 
themselves  of  review  proceedings  before  the  Kúria  on  points  of  law  (Constitutional  Court  Decision 
3002/2025.  (I.  21.),  paras  37-39)  or  –  in  the  case  of  Kúria  decisions  –  initiate  uniformity  complaint 
proceedings before the Kúria’s uniformity panel (Jpe.II.60.012/2024/7, para 41).  

21   Section  32(1)(a)  of  the  Organisation  and  Administration  of  Courts  Act  and  uniformity  decision  15/2025. 

JEH, para 67. 
22   Kúria, written reply. 
23   CJEU judgment, Global Ink Trade. 
24   These  cases  affected  for  instance  foreign  currency  loan  agreements  (C-679/24  -  UniCredit  Bank  and 
Momentum Credit; C-761/24 - AXA Bank Belgium and Others; C-351/25 - Trive Bank Hungary and Erinum 
Capital;  C-1/26  -  ERSTE  Bank  Hungary  and  Intrum)  and  the  return  of  illegally  staying  third-country 
nationals (C-26/25, Bukla). On 16 July 2026, the CJEU handed down a judgment in Bukla. 

25   The 2025 Rule of Law Report Recommended that Hungary ‘[i]mprove the transparency of case allocation 
systems in lower-instance courts, taking into account European standards on case allocation’.  No progress 
was previously assessed on this recommendation in 2024. 

26   Country visit, Hungary. 

6 

 
 
maintain  their  concerns  as  regards  the  lack  of  transparency  of  case  allocation  in  lower 
courts27.  The  most  recent  survey  by  the  European  Network  of  Councils  for  the  Judiciary 
shows that 30% of Hungarian judges believe that, over the past three years, not all cases have 
been  allocated  in  accordance  with  the  established  rules,  with  the  aim  of  influencing  the 
outcome of particular cases28. Therefore, no progress has been made on the recommendation.  

The  election  procedure  for  the  Prosecutor  General,  combined  with  the  hierarchical 
structure of the prosecution service, gives rise to a risk of undue political interference in 
individual  cases.  The  Prosecutor  General  is  elected  by  the  National  Assembly  without  the 
involvement of a prosecutorial body and without strict eligibility criteria29. Hungary has not 
implemented  the  recommendation  of  the  Venice  Commission  on  further  amending  the 
eligibility criteria and considering the introduction of guarantees in the appointment process, 
such as the establishment of a Prosecutorial Council in order to de-politicise the position of 
the Prosecutor General30. The hierarchical structure of the prosecution service remains intact, 
which – viewed together with the lack of internal checks and balances – constitutes a risk that 
senior prosecutors can influence the work of subordinate prosecutors, including in individual 
cases31.  Hungary  has  still  not  implemented  GRECO’s  recommendation  to  review  the 
possibility  to  keep  the  incumbent  Prosecutor  General  in  office  after  the  expiry  of  their 
mandate by a parliamentary minority blocking the election of a successor32.  

Quality  

Salaries  in  the  justice  system  have  been  increased  further,  while  no  progress  has  yet 
been made on the recommendation to take measures to ensure that such increases are 
carried  out  in  a  structured  way33.  As  of  1  January  2026,  the  National  Assembly  further 
increased  the  salary  base  for  judges  by  10%34.  According  to  stakeholders,  the  absence  of 
automatic indexation or similar guarantees makes salary adjustments to account for inflation 
unpredictable35.  Also,  the  statutory  system  of  remuneration  for  court  staff  makes  their 

27   European Network of Councils for the Judiciary (2026), p. 13. Hungarian Association of Judges (2026), p. 

8; MEDEL (2026), p. 9.  

28   Figure 54, 2026 EU Justice Scoreboard. 
29   Beside the mandatory three-year legal traineeship needed to pass the bar exam and the further requirement 
of having one year of professional experience, no further professional expertise is required to be elected as 
the Prosecutor General. 

30   Venice Commission (2025), paras. 29, 43-45. 
31   2025 Rule of Law  Report,  Hungary, p. 8;  Amnesty International Hungary et al. (2026), p. 16; Hungarian 

Helsinki Committee (2026), p. 16; K-Monitor (2026), p. 10. 

32   GRECO (2023), pp. 9-10. 
33   The  2025  Rule  of  Law  Report  recommended  that  Hungary  ‘[t]ake  measures  to  ensure  that  the  ongoing 
increase in the remuneration of judges, prosecutors and judicial and prosecutorial staff is carried out in a 
structured manner, taking into account European standards on remuneration for the justice system’. 

34   From  HUF  651 660  (around  EUR  1 840)  to  HUF  716 830  (around  EUR  2 024).  See  Section  67  of  Act 
LXIX of 2025 on the 2026 annual central budget of Hungary. In December 2024, the National Assembly 
adopted the 2025 annual central budget raising the salary base for judges by 15% as of 1 January 2025 (see 
2025 Rule of Law Report, Hungary, pp. 8-9).  

35   Amnesty  International  Hungary  et  al.  (2026),  pp.  4,  23;  European  Network  of  Councils  for  the  Judiciary 
(2026), p. 13; country visit, Hungary, National Judicial Council. Contrary to salaries in the justice system, 
the  salaries  of  several  other  categories  of  key  public  officials  –  including  the  top  management  of  the 
Competition  Authority,  the  Public  Procurement  Authority,  the  National  Media  and  Infocommunications 
Authority, the Integrity Authority and the Sovereignty Protection Office – are calculated on the basis of the 
previous  year’s  gross  average  salary  in  the  national  economy,  published  by  the  Central  Statistical  Office 
(2025 Rule of Law Report, Hungary, p. 9). 

7 

 
 
recruitment difficult in the central region36. Therefore, no further progress has yet been made 
on the recommendation. 

Shortcomings  in  the  legal  aid  scheme  remain.  Stakeholders  pointed  out  that  the  cost  of 
litigation often prevents small and medium-sized enterprises from defending their economic 
interests  in  court,  while  access  to  free  alternative  dispute  resolution  in  front  of  conciliation 
boards has been extended37. The eligibility threshold for legal aid in civil procedure is high, 
meaning  that  even  a  person  with  an  income  well  below  the  poverty  threshold  may  not  be 
eligible  for  legal  aid38.  On  21  November  2025,  the  Commission  opened  an  infringement 
procedure against Hungary for failing to correctly transpose EU rules on legal aid in criminal 
proceedings39.  Although  in  2026  the  fees  for  defence  lawyers  under  the  legal  aid  scheme 
were raised40, they are still  regarded as critically low,  risking  to  have a negative  impact  on 
access to justice and the right to a fair trial41. As reported in the 2025 Rule of Law Report, 
Hungary is lagging behind as regards specific arrangements for access to justice for persons 
at risk of discrimination and older persons42.  

Overall, the level of digitalisation in the justice system remains high. Hungary performs 
particularly well in terms of digital solutions for initiating and tracking civil, commercial and 
administrative  proceedings,  and  in  providing  the  public  with  online  access  to  published 
judgments.  Also,  Hungary  is  among  the  top-performing  Member  States  with  regard  to 
implementation  of  digital  solutions  for  conducting  and  following  court  proceedings  in 
criminal  cases43.  However,  stakeholders  have  raised  concerns  about  the  confidentiality  and 
reliability  of  communication  systems  in  practice,  which  they  fear  may  hinder  an  effective 
defence when holding hearings remotely for detained individuals44. 

Efficiency 

The  justice  system  continues  to  perform  efficiently  overall.  The  time  taken  to  reach  a 
decision  in  civil  and  commercial  cases  in  first  instance  courts  has  increased  slightly,  but  at 
140  days  (compared  to  135  days  in  2023)  it  remains  one  of  the  lowest  in  the  EU.  The 
estimated time taken to resolve administrative cases at first instance increased slightly (from 

36   Hungarian Association of Judges (2026), pp. 11-12; MEDEL (2026), p. 11. 
37   Country  visit,  Hungary,  Hungarian  Chamber  of  Commerce  and  Industry.  Conciliation  boards  attached  to 
regional chambers of commerce and industry have been operating in consumer/business dispute resolution 
for over 25 years. From 1 January 2026, access to these boards was extended to include micro, small and 
medium-sized enterprises (SMEs) buying goods or services as ‘end users’. This provides SMEs with a free, 
settlement-focused legal avenue. 

38   Figure 22, 2026 EU Justice Scoreboard. The income threshold for legal aid in Hungary is the lowest in all 
European  Union  countries.  Hungary  provides  free  legal  aid  (legal  counsel)  for  people  with  a  monthly 
maximum income of HUF 28 500 (EUR 80) per person as a general rule. 

39   INFR(2025)2163. The Commission found that in Hungary, not all persons covered by EU rules have access 
to  legal  aid.  Also,  the  granting  of  legal  aid  depends  on  a  request  by  the  individual.  Additionally,  while 
Hungary applies a system of mandatory defence, this system does not cover all scenarios set out by EU law, 
and it does not ensure that legal aid is granted without undue delay. 

40   The  generally  applicable  fee  remained  HUF  7 000  (around  EUR  20)  per  hour  (see  Section  67(4)  of  Act 
LXIX of 2025 on the annual budget of 2026). As of February 2026, a new hourly fee applicable during the 
criminal investigation was introduced and set at HUF 11 000 (around EUR 31) (see Section 7(1a) of Decree 
32/2017 of 27 December 2017 of the Minister of Justice, amended by Decree 3/2026 of 30 January 2026). 

41   Amnesty International Hungary et al. (2026), p. 22; Hungarian Helsinki Committee (2026), p. 19. 
42   2025  Rule  of  Law  Report,  Hungary,  p.  9.  Figure  27,  2025  EU  Justice  Scoreboard.  Hungary  ranks  25 th 

among EU Member States. 

43   Figure 47, 2026 EU Justice Scoreboard. 
44   Amnesty International Hungary et al. (2026), pp. 27-28. 

8 

 
 
125 days in 2023 to 131 days in 2024) yet remaining amongst the shortest in the EU. On 19 
August  2025,  new  provisions  of  the  Civil  Procedure  Code  entered  into  force  introducing 
simplified rules for certain proceedings45. 

While  a  compensation  scheme  has  been  introduced  for  contentious  civil  and 
administrative  proceedings,  there  is  still  no  adequate  scheme  for  cases  involving 
protracted  criminal  and  non-contentious  civil  proceedings.  The  compensation  scheme 
introduced  in  civil  lawsuits  as  of  1  January  2022  was  found  satisfactory  by  the  European 
Court of Human Rights in 202346. A 2025 amendment to the procedural rules applicable to 
contentious  civil  and, as  of 1 July  2026, administrative proceedings  introduce an additional 
compensation scheme47.  The new rules  oblige the court itself to  pay the parties  ex officio a 
daily lump sum as compensation for any procedural deadline breached by the judge hearing 
the case48. Stakeholders have expressed concerns as regards this new compensation scheme 
introduced  on  top  of  the  existing  one49.  In  the  context  of  the  enhanced  supervision  of  the 
implementation of the Gazsó judgment of the European Court of Human Rights, on 11 March 
2026 the Committee of Ministers of the Council of Europe reiterated its grave concern about 
the  continued  lack  of  any  development  ‘as  regards  the  outstanding  issue  of  compensatory 
remedy  in  respect  of  excessively  long  criminal,  administrative,  and  non-contentious  civil 
proceedings’50.    

II. 

ANTI-CORRUPTION FRAMEWORK  

The  perception  among  experts,  citizens  and  business  executives  is  that  the  level  of 
corruption in the public sector remains high. In the 2025 Corruption Perceptions Index by 
Transparency  International,  Hungary  scores  40/10051  and  ranks  26th  in  the  EU  and  84th 
globally.  This  perception  has  been  relatively  stable  over  the  past  five  years52.  The  2025 
Special  Eurobarometer  on  Corruption  shows  that  83%  of  respondents  consider  corruption 
widespread  in  their  country  (EU  average  71%)  and  35%  of  respondents  feel  personally 
affected by corruption in their daily lives (EU average 30%). As regards businesses, 88% of 
companies consider that corruption is widespread (EU average 65%) and 56% consider that 
corruption  is  a  problem  when  doing  business  (EU  average  37%).  Furthermore,  43%  of 
respondents find that there are enough successful prosecutions to deter people from  corrupt 

45   Act XLIX of 2025 introducing Sections 591/A to 591/H to the Civil Procedure Code. With a few exceptions 
where  the rules  of  the  simplified  proceedings do not  apply  (e.g.  disputes  on  personal  status,  employment 
relationships, and consumer disputes), the parties themselves may decide to stipulate in their contract that 
their legal dispute shall be decided by the court in this procedure. In the simplified proceedings, thanks to 
specific rules, the court delivers its judgment within a short period of time, based on written pleadings or 
additional written submissions and evidence. Hungarian Government (2026), written input, p. 13. 

46   ECtHR judgment in Szaxon v Hungary, application no. 54421/21, 30 March 2023. The amount of pecuniary 

satisfaction is HUF 400 (around EUR 1.1) per day. 

47   Act XLIX of 2025. 
48   Hungarian Government (2026), written input, p. 13.  The amount of the daily lump sum is currently HUF 

4 842 (around EUR 14). 

49   According to stakeholders, these new rules may allow court managers to put judges under undue pressure 

(Amnesty International Hungary et al. (2026), p. 24. See also MEDEL (2026), p. 10). 

50   CM/Del/Dec(2026)1553/H46-23. 
51   The level of perceived corruption is categorised as follows: low (above 79); relatively low (between 79-60), 

relatively high (between 59-50), high (below 50). 

52   In 2021, the score was 43, while, in 2025, the score is 40. 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. 

9 

 
 
practices  (EU  average  38%),  while  13%  of  companies  believe  that  people  and  businesses 
caught for bribing a senior official are appropriately punished (EU average 31%)53.  

Work  is  advancing  to  remedy  the  previously  identified  systemic  breaches  to  the 
principles  of  the  rule  of  law.  To  protect  the  EU  budget  against  corruption  and  systemic 
breaches to the principles of the rule of law, in 2022 the Council partially suspended funds 
under  three  EU  cohesion  policy  programmes  and  prohibited  entering  into  new  legal 
commitments  with  public  interest  trusts  (PITs)  and  entities  maintained  by  them,  until  the 
breaches of the principles of the rule of law and/or their effects or risks for the Union budget 
or  the  Union’s  financial  interests  are  remedied54.  On  23  June  2026,  the  National  Assembly 
adopted  an  omnibus  law  which  seeks  to  increase  transparency  and  strengthen  the  anti-
corruption  framework55.  These  legislative  amendments  aim  to  reinforce  the  powers  of  the 
Integrity Authority and ensure that it has access to data necessary for carrying out its work, 
address  conflicts  of  interest  and  transparency  concerns  related  to  the  operation  of  PITs 
pending their dissolution, extend judicial review of the decisions of investigative authorities 
and  the  prosecution  service,  increase  the  transparency  of  beneficial  owner  data  of  private 
equity funds, as well as increase the transparency of public procurement data and strengthen 
public  procurement  rules  to  facilitate  competition  and  the  prevention  of  corruption  and 
conflict of interest. By delivering on the commitments undertaken in the milestones linked to 
the rule of law in its Recovery and Resilience Plan, Hungary aims to also take the necessary 
remedial  measures  for  the  lifting  of  the  measures  under  the  Conditionality  Regulation 
procedure56.  

The  timeline  for  implementing  the  2024-2025  National  Anti-Corruption  Strategy  and 
related  Action  Plan  ended  in  November  2025andcertain  actions  remain  pending.  The 
former Government reported that out of 81 sub-measures defined in the Action Plan, 48 had 
been  completed,  while  33  are  ongoing,  partially  implemented  or  contingent  upon  the 
completion of ongoing  activities57. An independent  evaluation  of the implementation  of the 
Strategy  was  completed  in  February  2026.  Important  outstanding  actions  relate  to 
strengthening the transparency of political party financing, reinforcing integrity of members 
of Parliament and high-level  officials  through codes of conduct  and training,  as well as the 
adoption of legislation on lobbying. Completed actions mainly concern measures such as risk 
analysis  in  government  offices,  the  provision  of  ethics  and  integrity  training  to  judges, 
prosecutors, police staff and civil servants, a review of the Code of Ethics of the Police, the 
provision  of  trainings  on  whistleblower  protection  and  preparation  of  methodological 
guidance58. A decision on the preparation of a follow-up Strategy is yet to be taken59. 

The omnibus law of June 2026 aims to tackle obstacles to the effective functioning of the 
Integrity Authority. The  Integrity Authority  (IA)  continued  to  report  insufficient  access  to 

53   Data from Special Eurobarometer 561 (2025) and Flash Eurobarometer 557 (2025). 
54  Council Implementing Decision (EU) 2022/2506 of 15 December 2022. 
55  Act XVIII of 2026 on the amendment of certain Acts necessary for accessing European Union funds. 
56  The assessments included in this country chapter do not prejudge any future assessment under Regulation 
(EU, Euratom) 2020/2092, Article 24 of Regulation (EU) 2021/241, or under Article 15 of Regulation (EU) 
2021/1060. 

57   Information based on data available in the Monitoring Matrix for Q4 2025. Hungarian Government (2026), 

written input, p. 21. The deadline for implementation of the Strategy was set at 30 November 2025.  

58   Monitoring Matrix.  
59   Hungarian Government (2026), written input, pp. 21-22. Two evaluation reports are also under preparation 
as regards the implementation of the 2024 Strategy against Fraud and Corruption involving EU Funds. 

10 

 
 
the  databases  needed  for  the  full  execution  of  its  mandate60.  To  address  this  issue,  the 
omnibus  law  of  June  2026  aims  to  strengthen  the  IA’s  access  to  data  in  the  context  of 
administrative investigations and asset declaration verification procedures61. Amendments to 
the  appointment  process  and  governance  of  the  IA  seek  to  further  strengthen  its 
independence.  For  any  future  appointment,  the  eligibility  committee  is  tasked  to  draw  up  a 
ranking of candidates, from which the President of the State Audit Office, as the appointing 
authority,  may  depart  only  exceptionally  and  in  duly  justified  cases62.  Moreover,  a  new 
governance structure of the IA is established, consisting of a five-member board composed of 
the President and four Vice-Presidents63. On 16 June 2026, the President of the State  Audit 
Office petitioned the Budapest Regional Court to remove the President of the IA from office, 
following an indictment against him for abuse of office and forgery of official documents64. 
As  regards  the  follow-up  to  the  IA’s  recommendations,  the  former  Government  agreed  or 
partially  agreed  with  ten  of  the  42  recommendations  made  by  the  IA  in  its  third  analytical 
integrity report, disagreed with  17 and considered that no further action was  needed on the 
remaining 1565. In 2025, the IA referred four cases to the prosecution service66. In July 2025, 
the  eligibility  committee  published  its  report  on  the  functioning  of  the  IA  with 
recommendations,  including  amendments  to  the  IA’s  internal  rules67.  The  IA  committed  to 
examining the possibility of their implementation, while it criticised the methodology, as well 
as supporting evidence for the conclusions.  

The omnibus law of June 2026 also aims to strengthen the functioning  and impact of the 
Anti-Corruption Task Force. The Anti-Corruption Task Force (ACTF) held eight meetings 
in 2025 and adopted its 2025 annual report in March 202668. Non-governmental members of 
the  ACTF  remained  concerned  about  an  overall  lack  of  impact  of  its  work  and  a  limited 
uptake  of  its  proposals  by  the  previous  government69. The ACTF  failed  to  adopt  its  annual 
report  in  spring  2025  due  to  lack  of  consensus,  which  prevented  it  from  addressing  its 

60   Country visit Hungary, Integrity Authority. The IA’s latest annual report to Parliament refers specifically to 
the personal income tax and beneficial owner databases; the  Integrated Portal-based Query System (IPL), 
ensuring  access  to  the  registers  managed  by  Ministry  of  Interior’s  Deputy  State  Secretariat  for  the 
Management of Registers; data provision by financial institutions maintaining accounts; civil status data to 
identify relatives; company registry; the Prime Minister’s Office’s Electronic Public Procurement System, 
the  public  procurement  database  and  EUPR  (System  of  European  Union  Programmes)  database;  the 
Hungarian State Treasury’s Integrated Administration and Control System (IACS) insolvency registers.  
61  Such  access  may  be  ensured upon request  or  through direct  data  connection.  The  legislation  also  obliges 
data controllers to comply with the Authority’s request for data and in case they fail to do so, it envisages 
that the Integrity Authority may bring an administrative non-compliance action.  

62  Section 35(2) of the Integrity Authority Act. 
63  Section 32(1)  of the Integrity Authority Act.  Furthermore, the amended Section 34(2)  of that Act  defines 

the decision-making powers of the Board of the Authority, alongside those of the President.  

64   According  to  the  State  Audit  Office,  these  charges  would  disqualify  the  IA  President  from  holding  the 
position.  News  item  of  the  prosecution  service  of  9  June  2026.  24.hu  (2026).  Stakeholders  expressed 
concerns that the uncertainty due to the fourteen-month-long investigation  may have  negatively impacted 
the effective functioning of the IA. Amnesty International Hungary et al. (2026), p. 54. 

65   The recommendations concern proposals affecting the operation of the institutional system responsible for 
monitoring  EU  funds,  market  concentration  analysis,  enhancing  competition  in  public  procurement  (anti-
competitive  solutions  /  single-bidder  procedures  /  sham  bidding)  and  centralised  public  procurement. 
the  uptake  of 
Integrity  Authority  (2025).  This  marks  a  substantial  decrease  compared  with 
recommendations in the second annual analytical integrity report. See 2025 Rule of Law Report, Hungary, 
p. 12. 

66   Country visit Hungary, Integrity Authority. 
67   In line with the Integrity Authority Act, the functioning of the IA and its board is subject to a review two 

years after the appointment of the members of the board.  

68  ACTF (2026). 
69   Amnesty International Hungary et al. (2026), pp.38-39. See also ACTF (2026).  

11 

 
 
proposals  to  the  Government70. To  avoid  a  similar  situation, in  September  2025,  the  ACTF 
revised  its  rules  of  procedure  whereby  the  ACTF  will  produce  shorter,  focused  thematic 
reports which will form part of the annual report71. The omnibus law of June 2026 sets a five-
year term for the members of the ACTF, establishes a right to remuneration for the members 
representing non-governmental actors, and empowers the ACTF to establish its own rules of 
procedure and annual work plan.  

The  number  of  accepted  motions  for  revision  of  decisions  of  investigative  authorities 
remained  stable  compared  to  the  previous  year.  In  2025,  85  motions  for  a  revision  of  a 
decision  not  to  investigate  corruption  suspicions  or  terminate  ongoing  investigations  were 
submitted  to  the  Buda  Central  District  Court.  The  court  upheld  the  motion  for  revision  in 
seven cases, annulling the decision of the investigating authority, and rejected or terminated 
the procedure in 71 cases, with seven cases still pending as of 31 December 202572. Between 
1  January  2023  and  30  June  2025,  the  prosecution  service  granted  58  motions  on  its  own 
authority73. According to some CSOs, law enforcement bodies have been inclined to interpret 
the law in a restrictive manner to justify dismissals and avoid the filing of motions, thereby 
preventing  the  court  from  ordering  the  continuation  of  a  previously  dismissed  or  closed 
investigation74.  The  omnibus  law  of  June  2026  strengthens  the  procedure  by  extending  its 
scope of application to (non-time-barred) criminal offences committed before 1 January 2023 
and by giving greater weight to the court’s decisions75. Moreover, the law reinforces the role 
of the IA in the procedure by enabling it to review the original decision and request access to 
the criminal proceeding files76. No private prosecution has been initiated so far77. 

Lifestyle  checks  and  integrity  tests  as  regards  ‘protected  staff’  remain  in use  with  the 
extensive  use  of  secret  surveillance  and  insufficient  safeguards  raising  concerns  with 
regard to the right to privacy,  while no information is available about checks of high-
level officials. The powers of the National Protective Service (NPS), responsible for carrying 
out integrity tests and lifestyle monitoring, have been extended to allow for the use of covert 
means in cases of active bribery and abuse of function, as well as the use of polygraph testing 
in  the  context  of  such  activities78.  The  prosecution  service  reported  that  this  had  led  to  an 
increased rate of detections and indictments as regards protected staff79. At the same time, a 

70   According to the Integrity Authority Act, the ACTF must adopt its annual report by 15 March of the year 
following the year in question. The Government is then required to discuss the conclusions and proposals 
made in it and send a detailed reasoning to the chair of the ACTF, if it decides not to implement a proposal. 
In  the  absence  an  adopted  report  for  2024,  due  to  disagreement  between  state  and  non-governmental 
members, this did not occur.  

71   Hungarian Government (2026), written input, pp. 19-20. Amnesty International Hungary et al. (2026), pp. 
38-39. Permanent sub-groups will be replaced by ad hoc expert committees. The first thematic report will 
cover  education  and  awareness-raising  to  prevent  corruption,  whereas  public  procurement  processes, 
prosecution of corruption and access to information will not be covered. 

72   Hungarian Government (2026), written input, p. 37. In 2024, 80 cases were received, of which 7 motions 

for revision were upheld. 

73   Hungarian Government (2026), written input, p. 36.  
74   Amnesty International Hungary et al. (2026), p. 51. See also K-Monitor (2025). 
75  The  new  provisions  require  the  investigative  authorities  concerned  to  make  efforts  to  eliminate  the 

deficiencies identified by the court and to effectively remedy them.  

76  Prior to the amendments, the IA could only access an anonymised decision of the investigative authorities. 
77   Hungarian Government (2026), written input, p. 36. See 2023 Rule of Law Report, Hungary, p. 13. 
78   Hungarian Government (2026), written input, p. 16. Section 182 of Act XLIX of 2025, as well as Section 3 
of  Government  Decree  388/2025  of  10  December  2025  on  the  Amendment  of  Government  Decrees 
concerning criminal law matters.  

79   Country visit Hungary, prosecution  service. ‘Protected staff’ covers the range of bodies and personnel for 
which the NPS is competent. It includes law enforcement, public education and state healthcare institutions, 

12 

 
 
judgment  of  European  Court  of  Human  Rights  found  that  the  indiscriminate  use  of  secret 
surveillance  and  the  lack  of  effective  safeguards  raised  concerns  as  regards  privacy80.  The 
NPS has further expanded and upgraded its technical equipment. It has continued its training 
and awareness-raising activities among certain categories of ‘protected staff’81. There is still 
no  publicly  available  statistical  data  on  the  reliability  tests  or  national  security  vetting 
conducted  by  the  Constitution  Protection  Office,  responsible  for  carrying  out  checks  as 
regards high-ranking officials, given the confidentiality of its activities82.   

Whereas  the  number  of  indictments  for  corruption-related  crimes  has  generally 
increased,  there  has  been  overall  no  progress  on  the  recommendation  to  establish  a 
robust track record in cases of high-level corruption83. The prosecution service reports a 
43%  increase  in  the  number  of  indictments  for  corruption  offences  overall.  The  former 
Government  reported  that  these  improved  indicators  may  be  attributed  to  the  targeted 
activities of the NPS and to the level of specialisation of the Central Chief Prosecution Office 
of Investigation, which has an exclusive jurisdiction in investigating corruption offences84. In 
2025, 380 persons received a final conviction for corruption crimes85. High-level corruption 
cases  have  been  pending  before  the  first-instance  courts  for  years86.  The  risk  of  political 
influence  and  undue  interference  in  individual  cases  within  the  prosecution  service  and  the 
police,  as  well  as  clientelism,  favouritism  and  nepotism  in  high-level  public  administration 
remain areas of concern87. In June 2026, the new Government submitted a draft constitutional 
amendment  (‘the  Seventeenth  Amendment’)  and  a  draft  law  setting  up  a  National  Asset 
Recovery  and  Protection  Office  (‘NARPO’)  for  public  consultation.  The  Seventeenth 
Amendment  was  adopted  by  the  National  Assembly  on  13  July  2026  and  is  yet  to  be 
promulgated. The  NARPO  is planned to  be an independent  agency  combining a significant 
number of competences, including financial analysis, public asset-focused investigations, law 
enforcement, prosecution and litigation88. The former Government reported good cooperation 
between  the  prosecution  service  and  OLAF,  with  investigations  initiated  in  all  cases  where 

employees  of  territorial  government  administration  bodies  and  several  other  authorities.  See  Hungarian 
Government (2026), written input, p.15.  

80   Judgment of the ECtHR, 15147/23 and 38303/23, Szelényi and Others v Hungary. See pillar IV. 
81   Hungarian  Government  (2026),  written  input,  pp.  22-23.  With  regard  to  the  National  Tax  and  Customs 
Administration, the program is currently being developed (in collaboration with the relevant departments). 
82   Country  visit,  Hungary,  Constitution  Protection  Office.  Reliability  checks  by  the  Constitution  Protection 

Office are carried out on the basis of a classified authorisation decision. 

83   The  2025  Rule  of  Law  Report  recommended  that  Hungary  ‘[e]stablish  a  robust  track  record  of 
investigations,  prosecutions  and  final  judgments  for  high-level  corruption  cases.’  No  progress  was 
previously assessed on this recommendation in 2025, 2024 and 2023. 

84   Hungarian Government (2026), written input, p. 37.  
85   Country visit, Hungary, written contribution from the prosecution service. 
86   In a case involving a former deputy mayor, charged in 2010, the criminal trial began in 2016, and the final 
binding  sentence  was  delivered  in  2025  but  was  not  enforced.  See  Amnesty  International  Hungary  et  al. 
(2026), pp. 50-51. See wanted notice issued by the Budapest Regional Court - 7.SZV.2638/2025/11. In the 
case  of  a  former  Deputy  Minister  of  Justice,  indicted  in  2022,  or  the  budgetary  fraud  case  of  a  former 
member of Parliament, initiated in 2021, the courts have so far not reached a first-instance deliberation on 
the merits. The case of a Deputy Secretary of State, indicted in 2022, is also pending in court. Country visit, 
Hungary,  written  contribution  from  the  prosecution  service.  See  also  OLAF  (2026).  Stakeholders  raise 
concerns that in a recent case of misappropriation of assets held by foundations endowed by the Hungarian 
National  Bank,  key  procedural  steps,  including  interrogation  of  suspects,  are  still  to  be  taken  (Amnesty 
International Hungary et al. (2026), pp. 36, 53-54). 

87   See  2025  Rule  of  Law  report,  Hungary,  p.  15.  See  also  GRECO  (2022),  p.  6,  paras.  31-35;  GRECO 
(2023b), p. 29, para. 126, pointing at hierarchical pressure on police officers to discontinue investigations in 
certain sensitive cases. See also the reference to risks of undue political interference in individual cases on 
pp. 4-5. See K-Monitor (2025).  
 T/357. 

88 

13 

 
 
judicial  recommendations  were  sent  by  OLAF89.  On  29  May  2026,  Hungary  notified  its 
intention  to  participate  in  the  enhanced  cooperation  on  the  European  Public  Prosecutor’s 
Office (EPPO) and the  Commission subsequently adopted a decision confirming Hungary’s 
participation90. The positive changes recently initiated in the anti-corruption framework have 
not yet come into effect and therefore no progress has yet been made on establishing a robust 
track  record  of  investigations,  prosecutions  and  final  judgments  for  high-level  corruption 
cases. 

Legislative amendments have strengthened the framework for liability of legal persons, 
in line with international recommendations related to foreign bribery. The amendments 
eliminate  the  regulatory  gap  between  active  bribery  in  the  public  and  private  sectors, 
strengthen  corporate  liability  and  introduce  a  new  three-tiered  time  limit  system  for 
investigations91. In December 2025, the former Government introduced provisions requiring 
Hungarian  companies  that  apply  for  non-refundable  state  aid  for  foreign  investments  to 
possess  a  verified  anti-corruption  strategy  addressing  specifically  foreign  bribery  risks92. 
Cooperation  between  the  National  Tax  and  Customs  Administration  and  the  Prosecutor 
General’s  Office  has  been  formalised  through  a  new  agreement  to  enhance  information 
sharing  and  crime  reporting93.  An  international  experience-sharing  training  session  on 
international corruption cases was held in January 2026 for prosecutors94.  

New legislation aims to improve the system of asset declarations, providing for effective 
oversight and enforcement95.  The omnibus  law  of June 2026  establishes a comprehensive 
system of asset declarations applicable to a broad range of public officials and their relatives, 
including  senior political executives and high-risk officials such as  members of Parliament, 
the  President  of  the  Republic,  heads  of  key  regulatory  authorities,  local  government 
representatives, judges, prosecutors, as well as other high-ranking civil servants. The scope of 
assets to be declared now includes the declarant’s primary residence. Furthermore, the asset 
declarations of members of Parliament and senior political executives  must be submitted in 
electronic format and stored in a digital register maintained by the National Assembly. They 
are to be made public on the website of the National Assembly. The IA is granted exclusive 
powers  for  the  verification  of  asset  declarations  of  senior  political  executives,  whereas  for 
other categories of public officials its powers are shared with other competent bodies96. The 
law  also  sets  out  a  system  of  administrative  and  criminal  sanctions  for  different  types  of 
violations of asset declaration obligations, including failure to submit an asset declaration or 
intentionally providing false data. Administrative sanctions proportionate to the gravity of the 

89   The indictment rate of Hungary following judicial recommendations by OLAF stands at 60% (EU average 

37%). OLAF (2026).  

90  Commission  Decision  (EU)  2026/1701  of  10  July  2026  confirming  the  participation  of  Hungary  in  the 
enhanced cooperation on the establishment of the European Public Prosecutor’s Office. The EPPO will be 
competent  to  investigate  and  prosecute  crimes  affecting  the  Union's  financial  interests  committed  in 
Hungary after 1 June 2021.  

91   Hungarian Government (2026), written input, pp. 34-35. Act XLIX of 2025.  
92   Decree 12/2025 (IX. 25.) of the Minister of Foreign Affairs and Trade amending Decree 31/2021 (VIII. 31.) 
of  the  Minister  of  Foreign  Affairs  and  Trade  on  the  rules  of  support  under  the  Foreign  Market  Growth 
Support Program. 

93   Country visit Hungary, prosecution service.  
94   Monitoring Matrix. It was originally planned to take place by 31 December 2024. 
95  The  2025  Rule  of  Law  Report  recommended  that  Hungary  ‘[…]  further  improve  the  system  of  asset 

declarations, providing for effective oversight and enforcement’. 

96  Senior  political  executives  are  listed  in  Section  183  of  Government  Administration  Act  and  include  the 
Prime Minister, Ministers, Secretaries of State, the political director of the Prime Minister and the national 
security adviser of the Prime Minister.  

14 

 
 
violation,  including  a  fine  or  dismissal,  may  be  imposed  by  the  IA  or  by  other  competent 
bodies, depending on the legal status of the declarant97. The omnibus law of June 2026 also 
expands the definition of beneficial owner and broadens third-party access to the beneficial 
ownership register98. Since legislation was adopted to improve the asset declaration system, 
including  oversight  and  enforcement,  this  part  of  the  recommendation  has  been  fully 
implemented. 

lobbying  and  revolving  doors99.  Despite  plans 

There  has  been  no  progress  yet  on  the  recommendation  to  adopt  comprehensive 
legislative  reforms  on 
to  adopt 
comprehensive legislation on lobbying by 30 November 2025, no steps have yet been taken 
in  this  regard100.  CSOs  stress  that  the  lack  of  transparency  leaves  the  legislative  process 
vulnerable to undue  external  influence101. The  absence of post-employment restrictions  and 
of an effective enforcement mechanism also remains a concern102. In this regard, stakeholders 
signal  that  senior  officials  frequently  transition  between  the  executive,  the  legislature,  and 
independent  oversight  bodies  without  cooling-off  periods  or  substantive  conflict-of-interest 
assessments103. Since no steps have been taken for a comprehensive reform on lobbying and 
post-employment rules, there has been no progress on this part of the recommendation. 

Steps  have  been  taken  to  address  conflicts  of  interest  in  the  governance  structures  of 
public  interest  trusts  and  non-binding  measures  on  conflicts  of  interests  have  been 
adopted in certain sectors. In line with the Sixteenth Amendment to the Fundamental Law, 
the omnibus law of June 2026 provides for the dissolution of public interest trusts (PITs)104. 
PITs  not  maintaining  a  higher  education  institution  in  Hungary  must  be  dissolved  by  31 
August  2026,  while  higher  education  PITs  must  be  dissolved  by  1  August  2027.  Pending 
dissolution,  board  members  and  executive  officers,  including  incumbent  ones,  must  meet 
strict integrity requirements. These include appointment via an open call, eligibility criteria, 
incompatibility rules, and a four-year mandate limitation. Moreover, they would be subject to 
independent  vetting  by  the  State  Audit  Office  and  verification  of  their  asset  and  interest 
declarations  by  the  IA.  Following  the  adoption  of  a  Code  of  Ethics  and  Conduct  for  civil 
servants  of  the  Office  of  the  National  Assembly  in  2024,  an  integrity  awareness-raising 
training  programme  and  assessment  questionnaire  have  been  developed105.  No  dedicated 
codes  of  ethics  have  been  drafted  for  members  of  Parliament  and  persons  in  top  executive 
functions, as recommended by GRECO106. There are no rules in place regarding situations of 

97   Where the IA may not impose a sanction itself, a competent authority that does not act on the findings of 

the IA is required to provide a detailed statement of reasons, which must be published.  

98  These  legislative  changes  increase  transparency  of  ultimate  beneficial  owners  of  private  equity  funds, 
facilitating the detection of unjustified wealth. See also see 2025 Rule of Law Report, Hungary, p.16. 
99   The  2025  Rule  of  Law  Report  recommended  that  Hungary  ‘[p]ut  forward  comprehensive  legislative 
reforms on lobbying and revolving doors’. No progress was previously assessed on this recommendation in 
2025, 2024 and 2023. 

100   The adoption of rules on lobbying has also been recommended by GRECO. See GRECO (2023), p. 3 and 

GRECO (2022), p. 56.  

101   Country visit Hungary, CSOs.  
102   The  adoption  of  rules  on  post-employment  restrictions  has  also  been  recommended  by  GRECO.  See 

GRECO (2023), p. 57. 

103   Amnesty  International  Hungary  et  al.  (2026),  p.  42.  This  includes,  for  instance,  a  former  Minister  of 

Finance transitioning directly to a position as President of the Hungarian National Bank. 

104   Until  the  dissolutions  are  completed,  full  founder’s  rights  revert  to  the  Hungarian  government.  Assets 

granted to the dissolved foundations are to be returned to the state.  

105   Hungarian Government (2026), written input, p. 24.  
106   Under  the  fourth  evaluation  round,  GRECO  recommended  that  a  code  of  ethics/conduct  for  members  of 
parliament be adopted, covering various situations of conflicts of interest and that it be complemented by 
practical measures for its implementation, such as dedicated training and counselling. GRECO (2023). 

15 

 
 
personal  conflicts  of  interest  of  members  of  Parliament.  In  2025,  no  incompatibility  and 
conflicts of interest proceedings were initiated for members of Parliament107. The Hungarian 
Corps  of  Government  Officials  approved  a  revised  Code  of  Professional  Ethics  on  10  July 
2025,  including  rules  on  avoiding  conflicts  of  interest  and  managing  interactions  with 
lobbyists108. In November 2025, the NOJ President, with the consent of the National Judicial 
Council, updated the integrity rules to be followed in the event of judges accepting gifts109. 
Previously identified weaknesses, such as the fragmentation of the legislative framework on 
conflicts of interest, the lack of a general definition of conflicts of interest and the absence of 
a central supervisory body, remain to be addressed. 

The framework for the protection of whistleblowers is in place, however, the existence 
of  different  regimes  for  whistleblower  reporting  risks  weakening  protection.  The 
Commissioner  for  Fundamental  Rights  continues  to  oversee  the  national  whistleblowing 
regime110.  In  2024,  submissions  to  the  Commissioner’s  protected  electronic  system  rose  by 
16%  but  the  vast  majority  did  not  concern  corruption111.  The  Office  of  the  Commissioner 
submitted its first comprehensive data report under  the Whistleblowing Act, in the standard 
format prescribed by the European Commission, by the statutory deadline of 31 March 2025. 
Disclosures  may  be  submitted  anonymously,  their  status  can  be  tracked  online,  and 
anonymised extracts of reports and their outcomes are published on the Office’s website112. 
Whistleblower reports have proven a more effective tool in specific regulated areas, as 43% 
of  reports  submitted  to  the  Public  Procurement  Authority  led  to  the  initiation  of  contract 
audits and remedy procedures before the Arbitration Board, and 11% of submissions to the 
Competition  Authority  resulted  in  the  launch  of  formal  competition  law  infringement 
proceedings113.  An  information-sharing  exercise  on  whistleblowing  targeting  the  business 
sector  was  implemented  in  partnership  with  the  Hungarian  Chamber  of  Commerce  and 
Industry114.  CSOs  continue  to  express  concerns  that  the  separate  regime  for  reports  falling 
outside the Directive’s scope leaves potential whistleblowers with no or very weak protection 
and that whistleblower reports disclosed to the media are still left without protection115. 

Shortcomings  related  to  the  transparency  of  the  financing  of  political  parties  and 
electoral campaigns remain. In June 2025, legislative amendments resulted in the abolition 
of Hungary’s long-standing legal limit on campaign spending for parliamentary elections116. 

107   Hungarian Government (2026), written input, p. 25. In 2025, fourteen  members of Parliament voluntarily 
corrected information in their declarations by clarifying the positions they held. There is no mechanism in 
place to sanction refusals to rectify the declarations, if discrepancies are signalled or detected. 

108   Hungarian Corps of Government Officials (2025). 
109    Recommendation 2/2025 (XI. 5.) OBH of the NOJ President amending Recommendation 3/2018 (VI. 26.) 
OBH of the NOJ President on the procedural rules for handling events that violate organisational integrity 
for regional appeal courts and regional courts. 

110   See pillar IV on the independence and effective functioning of the Commissioner for Fundamental Rights. 
111   Commissioner for Fundamental Rights (2025). 
112  Hungarian Government (2026), additional written input. 
113   Public  Procurement  Authority:  Register  of  Public  Interest  Disclosures.  Hungarian  Competition  Authority 

(2025).  

114   Hungarian  Government  (2026),  written  input,  p.  26.  The  broad  public  campaign  on  whistleblowing 
included in the National Anti-Corruption Strategy did not take place. The Office of the Commissioner for 
Fundamental Rights also prepared a phased training campaign for public administration staff and provides 
detailed information through its website, informational booklets, and regional offices.  

115   Amnesty International Hungary et al. (2026), pp. 46-47. Media informants are protected under the Criminal 

Procedure Code and the Media Act. Hungarian Government (2026), additional written input.  

116   Act LXVIII of 2025 on the amendment of Act LXXXVII of 2013 on the transparency of campaign costs for 
the  election  of  Members  of  Parliament.  The  Council  of  Europe  has  recommended  adopting  measures  to 

16 

 
 
Challenges previously identified regarding political party and campaign financing rules have 
not  been  addressed  in  the  reporting  period117.  Stakeholders  reported  that  state-funded 
information or national consultation initiatives were used as a tool of electoral campaigning 
and  that  the  involvement  of  third-party  actors  undermined  the  transparency  of  campaign 
financing118.  A  legislative  amendment  adopted  in  December  2025  aims  to  sanction  ‘proxy’ 
campaigning, meaning activities indistinguishable from a party’s image or conducted under a 
party’s direction, only when it is financed, even in part, by foreign sources119. Political parties 
continue  to  submit  their  annual  accounts  as  required.  However,  the  accessibility  and 
searchability of reports published in the Official Gazette is limited. Moreover, information on 
the results of audits, including any breaches identified, investigations conducted, or sanctions 
applied, is not systematically made available120. In June 2026, a legislative amendment was 
adopted under which parliamentary groups can no longer transfer their budget surpluses for 
the  current  year  to  political  parties121.  Overall,  concerns  therefore  remain  as  regards  the 
transparency of political party and campaign financing.  

The  omnibus  law  of  June  2026  addresses  corruption  risks  in  public  procurement 
procedures and increases the transparency of private equity funds. Businesses’ attitudes 
towards  corruption  in  the  EU  show  that  48%  of  companies  in  Hungary  (EU  average  30%) 
think  that  corruption  has  prevented  them  from  winning  a  public  tender  or  a  public 
procurement contract in practice in the last three years122. Only 17% of businesses perceive 
the  level  of  independence  of  the  public  procurement  review  body  (Public  Procurement 
Arbitration  Board)  as  very  or  fairly  good123.  The  Single  Market  and  Competitiveness 
Scoreboard on access to public procurement in Hungary reports 24% of single bids for 2025 
(EU  average  27%)124.  At  the  same  time,  the  share  by  contract  value  of  single-bid  public 
procurements  conducted  under  national  rules  or  financed  from  national  resources  has 
increased125.  The  omnibus  law  of  June  2026  strengthens  the  transparency  of  public 
procurement procedures and provides for the possible inclusion of anti-corruption conditions 
in  procurement  contracts.  It  also  enables  the  IA  to  initiate  proceedings  before  the  Public 
Procurement Arbitration Board and to bring actions for failure to act against it. In particular, 
the law clarifies the IA’s power to act in respect of defence and security procurements and to 

prevent excessive funding needs of political parties, such as, establishing limits on expenditure on electoral 
campaigns. See Article 9 of Recommendation Rec(2003)4 of the Committee of Ministers. 

117   See 2025 Rule of Law Report, Hungary, p. 18. 
118   Amnesty International Hungary et al. (2026), pp. 43-44. See also 2020 Rule of Law Report, Hungary, p. 5 

as regards national consultations. 

119   Act C of 2025 amending laws affecting the financial intermediary system.  
120   OECD (2026). 
121  Act XVII of 2026 on the amendment of Act XXXVI of 2012 on the National Assembly and certain related 

Acts concerning cost reduction. 

122   Flash  Eurobarometer  557  on  Businesses’  attitudes  towards  corruption  in  the  EU  (2025).  This  is  11 

percentage points above the EU average. 
123   Figure 59, 2026 EU Justice Scoreboard. 
124   This trend is mixed however as the share of public procurement procedures with single bids decreased for 
both  EU-financed  and  national  procurements  until  2024,  in  2025,  the  share  of  EU-funded  single  bid 
procedures  doubled  compared  to  2024  (increased  to  9.5%  from  4.2%  in  2024).  In  addition,  the  target 
committed  to  by  Hungary  for  domestically  financed  public  procurements  was  not  met  for  the  third 
consecutive year: in 2023 it was 29% vs the target of 24%, in 2024 it was 22.3% vs the target of 15% and in 
2025  it  was  22%  vs  the  target  of  15%.  According  to  the  new  Government,  this  figure  applies  only  to 
procedures  conducted  under  EU  rules.  If  procedures  conducted  under  national  rules  are  included,  the 
proportion  is  below  20%.  Hungary  has  fulfilled  its  commitment  to  reduce  the  proportion  of  single-bid 
public  procurements  to  below  15%  for  procedures  financed  at  least  in  part  by  EU  funds;  this  proportion 
now stands at 9.5%. Hungarian Government (2026), additional input.  
125   Analysis of single-bid public procurements 2021-2025 (13 February 2026) 

17 

 
 
in 

to  competition 

challenge  an  exclusion  from  public  procurement  rules  based  on  national  security  grounds. 
the  public  procurement  market  remain126. 
Important  constraints 
Stakeholders also report that competition in public procurement has not improved in practice, 
as  the  largest  tenders  continue  to  be  won  by  a  limited  number  of  economic  actors127.  In 
addition,  the  share  and  volume  of  framework  agreements  rose  substantially128.  These  may 
limit competition, as a vast majority are concluded with one single market participant129. The 
share  of  private  equity  funds  involved  in  public  procurement  increased  (5%  in  case  of  all 
procurement and over 9% in case of EU-funded procurements). In order to address risks of 
corruption and conflicts of interest associated with private equity funds, the omnibus law of 
June  2026  establishes  stricter  transparency  and  due  diligence  requirements130.  EU  rules  on 
public procurement and concessions have not been respected in high-value projects related to 
motorways131 and waste management132. In 2025, the visibility of notices, guidance and other 
documents  on  public  procurement  in  the  Electronic  Public  Procurement  System  was 
improved,  and  the  indicators  of  the  performance  measurement  framework  were  refined 
further133. State administrative bodies have assessed the integrity and corruption risks related 
to  their  operations.  The  most  common  types  of  corruption  risk  relate  to  administrative  and 
regulatory  proceedings,  customer  relations  and  data  management  activities134.  Other  areas 
exposed  to  corruption  risks  include  official  licensing  and  official  inspection135.  As  regards 
regimes  for  issuing  of  official  permits,  the  designation  of  projects  as  being  of  ‘strategic 

126   The  IA  reports  increasing  market  concentration,  especially  related  to  companies  belonging  to  the  same 
ownership  structures  (over  40%  for  the  top  10  companies);  when  EU-funding  is  involved,  and  in  certain 
sectors  (concentration  is  over  50%  in  business  services  and  IT  services).  Also,  it  underlines  that  the 
improving  trend  of  single  bids  may  conceal  the  existence  of  ‘supporting  bids’  and  would  require  more 
targeted analysis. Integrity Authority (2025).  

127   Amnesty  International  Hungary  et  al.  (2026),  pp.  48-49.  See  also  Transparency  International  Hungary’s 
Tender  Champion  database  according  to  which  companies  linked  to  a  close  friend  of  the  former  Prime 
Minister has won public procurement contracts worth a total of more  than EUR 2.6 billion, amounting to 
8.6% of the total value of the tenders examined for the period between 2021and 2023. 

128   In 2025, their value exceeded that of all other tenders (ca. 60%) and close to 75% of them was concluded 
with  a  single  bidder.  The  most  notable  example  of  this  is  the  commissioning  of  PR  and  communication 
services by a central purchasing body. The Government does not include framework agreements in statistics 
on single bids in line with the Single Market Scoreboard methodology. 

129   In 2024, 74% of framework agreements did not reopen competition, as they were concluded with only one 
economic  operator.  See  Performance  measurement  framework  for  evaluating  the  efficiency  and  cost-
effectiveness  of  public  procurement,  indicator  n47.  One  example  is  the  communication  sector  where 
companies  owned  by  one  person  won  74%  of  contracts  between  2021  and  2023.  Corruption  Research 
Centre Budapest (2024).  

130  The  new  rules  extend  the  definition  of  ultimate  beneficial  owners  to  capture  all  natural  persons  who 
exercise de facto control or hold blocking voting rights and make mandatory the identification of ownership 
chains established through parallel funds, holding structures or multi-jurisdictional arrangements. 

131   On 17 July 2025, the Commission sent an additional letter of formal notice to Hungary for failing to comply 
with  EU  rules  on  public  procurement  and  concessions  when  awarding  a  contract  for  the  construction, 
operation and maintenance of its motorway network (INFR(2024)4006). 

132   On 21 November 2025, the Commission opened an infringement procedure against Hungary for failing to 
comply  with  EU  rules  when  awarding  its  waste  management  concession  for  the  entire  territory  of  the 
country (INFR(2025)4020). The Commission considers that the eligibility criteria applied in this procedure 
were discriminatory and that the 35-year duration of the concession exceeds the period permitted under EU 
law. In addition, the original terms of the concession appear to have been modified in breach of EU rules. 
133   Hungarian  Government  (2026),  written  input,  pp.  38-39.  The  Action  Plan  on  increasing  competition  has 

also been supplemented with further measures in 2025. 

134   Hungarian Government (2026), written input, pp. 22-24. 
135   Hungarian Government (2026), written input, p. 31. 

18 

 
 
importance  for  the  national  economy’  allows  to  circumvent  standard  procedures136.  This 
increases the opacity of the permitting process and accordingly corruption risks.  

III.  MEDIA PLURALISM AND MEDIA FREEDOM  

Amendments  to  the  Media  Act  have  introduced  reforms  to  the  Hungarian  media 
regulator137. By means of an Act, adopted in June 2026, which amends the 2010 Media Act 
and  other  related  acts138,  the  term  of  office  of  the  President  and  members  of  the  Media 
Council  have  been  terminated.  The  legislation  introduces  new  rules  in  relation  to  the 
competences, tasks and roles of the Media Authority, its Media Council, its President, Vice-
Presidents  and  its  Office,  and  establishes  new  criteria  for  the  nomination,  appointment  and 
dismissal  of  all  relevant  office  holders  within  these  structures.  Furthermore,  the  new  rules 
reform the rules regulating the salaries of these office holders and the financing regime of the 
Media Authority. Prior to the adoption of these reforms, the 2026 Media Pluralism Monitor 
(MPM)  considered  that  the  indicator  relating  to  the  independence  and  effectiveness  of  the 
Media  Authority  was  an  area  presenting  high  risk139.  On  26  February  2026,  the  Court  of 
Justice  ruled  that  certain  provisions  of  Hungary’s  media  law  and  the  decision  of  the  media 
regulator  based  thereon  refusing  renewal  of  radio  station  Klubrádió’s  broadcasting  licence, 
had failed to observe the principles of proportionality, transparency and good administration 
and  had  infringed  freedom  of  expression  and  information  enshrined  in  the  EU  Charter  of 
Fundamental Rights140. In the light of the legislative steps taken with a view to implement the 
European Media Freedom Act, some progress has been made in this area. 

Transparency  and  fairness  in  the  distribution  of  state  advertising  has  not  been 
addressed  yet141. Hungary has not  adopted  any legislative or regulatory measures  aimed at 
ensuring  that  state  advertising  is  allocated  in  accordance  with  transparent,  objective, 
proportionate and non-discriminatory criteria made publicly available in advance. During the 
reporting period, the State remained by far the most important player in the media advertising 
market,  channelling  significant  state  resources  to  pro-government  media  and  increasing  its 
spending. As in the previous year, stakeholder media monitoring reports that state advertising 
accounts  for  over  30%  of  the  total  advertising  market  and  the  Central  European  Press  and 
Media Foundation (KESMA), a group of pro-government media outlets receives up to 75%-
80%  of  its  total  revenue  from  state  advertising142.  The  2026  MPM  confirms  its  previous 
analysis  given  that  ‘the  unfair  distribution  of  state  advertising,  including  advertising  from 
state-owned companies, still prevails’143. Given that no measures have been taken to improve 
fairness in the distribution of state advertising, there has been no progress yet as regards the 
recommendations made in previous years.  

136   Such projects are exempted from regular requirements and safeguards in order to simplify and accelerate 

investment procedures (2023 Rule of Law Report, Hungary, p. 19). 

137   The  2025  Rule  of  Law  Reports  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’. No progress was previously assessed on this recommendation in  2025, 
2024 and 2023. 
138  Act XXI of 2026.  
139  Media Pluralism Monitor (2026), pp. 15-18. 
140  Judgment of the CJEU, case C-92/23, Commission v Hungary (Right to provide media services on a radio 

frequency). 

141   The 2025 Rule of Law report recommended to Hungary to ‘[a]dopt legislation to ensure fair and transparent 
distribution  of  advertising  expenditure  by  the  state  and  state-owned  companies’.  No  progress  was 
previously assessed on this recommendation in 2025, 2024 and 2023. 

142   Mertek Media Monitor (2026), International Press Institute (2026) and Reporters Without Borders (2026).  
143   Media Pluralism Monitor (2026), pp. 33-34. 

19 

 
 
Transparency  in  the  ownership  structure  of  media  companies  is  not  regulated  by 
specific provisions. Section 41 of the Media Act mandates the NMHH to maintain registers 
on  media  service  providers,  but  these  registers  contain  no  information  on  ownership  or 
beneficial  ownership  of  these  companies.  Direct  ownership  information  is  available  via  the 
business register. MPM 2026 has raised its risk level for this area from high to very high-risk 
given  that  ‘there  are  no  detailed  transparency  rules  requiring  the  disclosure  of  media 
companies’  ownership  structures’  and  ‘neither  the  direct  nor  the  indirect  ownership 
background of media service providers is included’144.  

Amendments to the Media Act have introduced reforms to the system regulating public 
service  media  supervision,  regulation  and  financing145.  On  11  December  2025,  the 
European  Commission  opened  an  infringement  procedure146  against  Hungary  for  failing  to 
comply  with  several  provisions  under  the  European  Media  Freedom  Act147  and  certain 
requirements under the Audiovisual Media Services Directive148, including the provisions on 
the independence of public service media governance and financing149. Prior to the adoption 
of the amendments  to  the Media Act, the MPM maintained its very high-risk score for this 
area highlighting biased coverage, the lack of transparent appointment mechanisms and high 
levels of political control150. The Media Act adopted in June brought about the termination of 
the previous Public Service Foundation and the  establishment of a new  Independent  Public 
Media Board  and an Office which shall carry out  the day-to-day activities on  behalf of the 
former.  The  legislation  establishes  new  rules  regulating  the  composition  of  the  entities, 
nominations  thereto,  conflict  of  interests,  termination  of  office,  as  well  as  the  respective 
tasks,  powers  and  remuneration  of  these  institutions  and  office  holders  thereof.  It  also 
establishes a new Charter and Civil Service Council for public service media, rules governing 
the public service provider itself including the appointment of the provider’s CEO, financing 
and  management  and  new  specific  employment  law  rules  for  this  entity.  In  the  light  of  the 
legislative  steps  taken  with  a  view  to  implement  the  European  Media  Freedom  Act,  some 
progress has been made in this area.   

Although  the  processing  of  court  cases  relating  to  access  to  information  has  been 
accelerated  and  new  procedural  rules  may  further  strengthen  the  rights  of  data 
requestors,  the  scope  of  access  remains  limited,  particularly  with  regard  to  the  use  of 
public  funding.  The  short  procedural  deadlines  introduced  in  2023  have  led  to  faster 
litigation  in  cases  involving  access  to  information  of  public  interest.  Most  restrictions  on 
freedom of information introduced in 2023, 2024 and 2025 are still in force151. Stakeholders 
report  that  access  to  information  on  the  use  of  public  funding  via  promotional  banks  and 

144   Media Pluralism Monitor (2026), p. 20. 
145   The  2025  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’. No progress was previously assessed on this recommendation 
in 2025, 2024 and 2023. 

146   INFR(2025)2194. 
147   Regulation (EU) 2024/1083. 
148   Directive (EU) 2018/1808. 
149   Infringement INFR(2025)2194. 
150   Media Pluralism Monitor (2026), pp. 34-36 
151   2024  Rule  of  Law  Report,  Hungary,  pp.  28-29,  2025  Rule  of  Law  Report,  Hungary,  pp.  21-22.  Public 
bodies  are  no  longer  obliged  to  fulfil  requests  for  information  not  held  directly  by  them,  but  by  their 
subordinate  entities.  Additionally,  state-owned  enterprises  are  authorised  to keep  the  data  of  their  foreign 
investments secret for 10 years, and the government can block some of its decisions for 20 years instead of 
10.  Also,  Act  CXXVIII  of  2025  introduced  a  new  ground  for  rejection  in  the  event  of  cybersecurity 
concerns. 

20 

 
 
private  equity  funds  is  severely  limited152.  Certain  public  bodies  are  reported  to  allow  only 
on-the-spot  examination  of  documents,  which  is  an  unlawful  practice153.  The  National 
Assembly  has  yet  to  implement  the  Constitutional  Court’s  2020  decision  that  effective 
judicial  protection  must  be  ensured  in  cases  concerning  freedom  of  information  requests 
relating to public funds addressed to the recipients of such funds154. In some instances, case 
law from both the Kúria and the Constitutional Court has validated the lack of judicial review 
in  cases  where  access  to  documents  is  denied  on  the  grounds  of  foreign  policy155. 
Furthermore, the Kúria has overturned binding decisions of lower courts and denied access to 
the  requested  documents156.  The  omnibus  law  of  June  2026  introduced  the  requirement  of 
cooperation  in  good  faith  between  the  data  requestor  and  the  public  service  entity157  and 
reduced  the  possibility  for  public  service  entities  to  dismiss  requests  for  access  to 
documents158. Stakeholders report that certain public bodies do not comply with enforcement 
orders granting access to documents159. With regard to proactive disclosure, the omnibus law 
of June 2026 extended the scope of data to be published160 and the list of entities required to 
publish information in the Central Public Data Information Register161. The Media Pluralism 
Monitor continues to consider this to be an area presenting very high risk162. 

During a large part of  the reporting period, journalists and other media  professionals 
continued to encounter numerous and serious challenges to their work. A wide array of 

152   Transparency International Hungary (2025), pp. 15-19. 
153   Under Section 29(3) of  the Freedom of Information Act, the applicant is entitled to receive a copy of the 

documents or document section containing the data, regardless of its mode of storage. 

154   Decision  7/2020  (V.  13.)  AB  of  the  Constitutional  Court  found  that  the  right  to  freedom  of  information 
extends to all public data and that judicial remedies must exist to fulfil this fundamental right vis-à-vis all 
persons handling public data. The legislative measure directly related to this has not been implemented. 
155   In a case related to the Budapest–Belgrade railway project, the Kúria found that the discretionary decision 
by  the  Minister  of  Foreign  Affairs  to  deny  access  to  information  based  on  foreign  policy  considerations 
cannot  be  reviewed  by  the  court  (judgment  Pfv.IV.20.100/2022/5,  29  June  2022,  confirmed  by  decision 
3200/2025. (VI. 23.) AB of the Constitutional Court).  

156   In  one  case,  overturning  the  lower  court  judgments,  the  Kúria  ruled  that  access  to  anonymised  invoices 
issued by a ‘VIP ward’ of a public hospital could not be granted since they might still contain information 
that  could  be  used  to  identify  the  patients  (judgment  Pfv.IV.21.030/2025.  of  the  Kúria  of  17  November 
2025). In another case, the Kúria overturned the appeal court’s ruling and decided that decisions rejecting 
access to large data sets (in this case, government decisions) could not be challenged in a single lawsuit, but 
separate  claims  had  to  be  submitted  regarding  each  element  of  the  sought-after  dataset  (order 
IV.Pfv.20.614/2025/8-II. of the Kúria of 10 September 2025).  

157  Section 26 of the omnibus law of June 2026 introducing Section 26(1a) to the Freedom of Information Act. 
158  Section 30 of the omnibus law of June 2026 repealing Section 30(2a) of the Freedom of Information Act. 
That provision, introduced as of 1 January 2024, provided 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 (see 2024 
Rule of Law Report, Hungary, p. 29). 

159   Amnesty  International  Hungary  et  al.  (2026),  pp.  92-93.  The  execution  of  the  ECtHR  judgment  in  case 
Kenedi v Hungary is still pending. On 11 June 2026, the Committee of Ministers of the Council of Europe 
called  again  on  the  Hungarian  authorities  to  adopt  additional  targeted  general  measures  (i)  to  address  the 
recurring  reluctance  of  state  authorities  to  comply  with  the  domestic  courts’  orders  granting  access  to 
documents, and (ii) to ensure that effective and genuinely coercive enforcement tools are available for the 
implementation of such orders (CM/Del/Dec(2026)1563/H46-17). 

160  Section 27(2) and (3) of the omnibus law of June 2026 amending Section 37/C(2) and (3) of the Freedom of 
Information  Act.  Under  the  law,  the  Register  will  enable  machine  readability,  bulk  download,  grouping, 
searchability, extraction and comparability of data. 

161  Section  27(1)  of  Act  of  the  omnibus  law  of  June  2026  amending  Section  37/C(1)  of  the  Freedom  of 
Information Act. The list now also includes public interest trusts and entities maintained by them, publicly 
owned companies and their foundations and the HUN-REN Hungarian Research Network. 

162   Media Pluralism Monitor (2026), p. 14. 

21 

 
 
stakeholders  emphasised  that  a  number  of  factors  had  exacerbated  the  obstacles  media 
workers  faced  when  carrying  out  their  work163  which  a  recent  report  summarised  as  ‘the 
weaponization  of  laws  against  independent  media  outlets’164,  targeted  exclusion  of 
independent journalists165, the use of smear campaigns against journalists and media outlets, 
SLAPP lawsuits, the deployment of unlawful surveillance and the actions of the Sovereignty 
Protection Office166. The 2026 MPM considers the safety of journalists to be an area which 
presented medium-high risk, flagging that surveillance and source protection remained areas 
of  serious  concern167  The  Council  of  Europe’s  Platform  to  promote  the  protection  of 
journalism  and  safety  of  journalists  registered  three  new  alerts  relating  to,  respectively, 
continued  political  influence  over  public  service  media,  an  investigative  journalist  charged 
with espionage amid a smear campaign and surveillance concerns and the forced removal of 
two  journalists  from  a  political  event168.  The  Mapping  Media  Freedom  monitoring  report 
flagged 24 alerts, relating, among others, to various cases of access being denied to political 
events or information, political influence and pressure exerted on media outlets, defamation 
cases lodged by politicians, the use of public funds to target journalists via paid social media 
adverts and Distributed Denial of Service attacks169. 

IV.  OTHER INSTITUTIONAL ISSUES RELATED TO CHECKS AND BALANCES 

The former government continued to use its emergency powers extensively until 13 May 
2026,  undermining  legal  certainty  and  affecting  businesses’  ability  to  operate  in  the 
single market. The former government further extended the ‘state of danger’, declared 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’,  until  13  May  2026170.  This  allowed  the  former 
government  to  override  Acts  of  Parliament.  Several  emergency  measures  adopted  in  the 
reporting period had an impact on the business environment and appear unrelated to the ‘state 
of  danger’171.  In  2025,  the  Constitutional  Court  did  not  make  any  substantive  decisions 
regarding the constitutionality of emergency measures but rejected applications in that regard 

163   Mertek Media Monitor (2026), International Press Institute (2026) and Reporters Without Borders (2026).  
164   Foremost among which the Sovereignty Protection Act.  
165   From government press conferences and other events.  
166   The Repression of Independent Media in Hungary 2010-2025 (2026), Rule of Law Lab and Mertek Media 

Monitor. 

167   Media Pluralism Monitor (2026), pp. 14-15.  
168   Council of Europe Platform to promote the protection of journalism and safety of journalists (2026). 
169   European Centre for Press and Media Freedom (2026). 
170   See 2025 Rule of Law Report, Hungary, p. 23. Government Decree 343/2025 of 31 October 2025 amended 
Government Decree 424/2022 of 28 October 2022 by  further extending the ‘state of danger’ until 13 May 
2026. The Government needed an authorisation from the National Assembly to extend the ‘state of danger’. 
This  authorisation  was  given  through  Section  2(1)  of  Act  XLII  of  2022,  as  amended  by  Act  2025  of 
LXXVII. Act XLII of 2022 became inapplicable on 15 May 2026 (see Section 6(2)). In parallel, Hungary 
has been under a ‘crisis situation caused by mass immigration’ since 10 March 2016; this has been further 
extended until 7 September 2026. 

171   E.g.  Government  Decree  129/2025  of  5  June  2025  prohibited  credit  institutions  from  decommissioning 
automatic teller machines. Government Decree 358/2025 of 13 November 2025 amended the rules on the 
sectoral  tax  for  credit  institutions  and  financial  enterprises.  Government  Decrees  252/2025  of  7  August 
2025, 304/2025 of 6 October 2025 and 324/2025 of 20 October 2025 amended the rules on reorganisation, 
bankruptcy  and  winding-up  of  certain  companies.  Government  Decree  293/2025  of  24  September  2025 
granted the Minister of Justice full access to all documents and information related to the ongoing criminal 
investigation  into  the  alleged  crimes  committed  in  a  secured  youth  detention  centre.  Government  Decree 
49/2026 of 9 March 2026 introduced measures ‘necessary in the interest of national security in connection 
with the unusual quantities of cash and gold bars transported through the territory of Hungary’. 

22 

 
 
on formal grounds172. Additionally, the governing majority elevated most of these emergency 
measures, which were intended to address a temporary exceptional situation, to the level of 
statutory  law173.  Stakeholders  reported  that  the  extensive  and  prolonged  use  of  the  former 
government’s emergency powers, with measures often adopted at short notice and amended 
frequently, undermined legal certainty174. 

The law-making process remains a cause for concern, and certain important legislative 
processes  have  not  been  subject  to  public  consultation  requirements.  Under  the  former 
government,  public  consultations  were  formalistic,  and  the  legislative  procedure  offered 
limited  opportunities  for  stakeholders  to  effectively  intervene  or  influence  the  decision-
making process175. According to stakeholders, compliance with public consultation rules was 
neither effectively monitored nor enforced176. The quality of the impact assessments of draft 
legislation  and  the  summaries  published  during  the  public  consultation  process  were 
criticised by stakeholders  for being  inadequate177.  The omnibus law of June 2026  extended 
the  public  consultation  requirement  to  cover  specific  topics178.  In  May  2026,  the  new 
Parliament  established  a  new  Committee  on  Social  Participation  with  the  intention  of 
facilitating  stakeholder  involvement  in  the  legislative  process179.  In  2025,  the  National 
Assembly adopted two laws in urgent procedure180 and five laws in exceptional procedure181. 

172   In  2025,  the  Constitutional  Court  considered  24  cases  based  on  constitutional  complaints,  judicial 
initiatives,  or  petitions  for  posterior  norm  control,  with  the  aim  of  reviewing  the  constitutionality  of 
emergency  measures.  Nine  petitions  were  rejected  on  formal  grounds,  and  the  Court  discontinued  the 
procedure in 15 cases because the challenged norm had been repealed in the meantime. According to the 
new Government, the Constitutional Court adjudicates within the limits of the petitions submitted to it and 
has no power to review emergency measures of its own motion (ex officio). 

173   E.g. Act L of 2025 ‘on raising emergency decrees promulgated in view of the armed conflict in Ukraine to 
the level of an Act of Parliament’; Act CXXV of 2025 ‘on the amendment of certain Acts of Parliament 
serving  to  protect  public  order  and  strengthen  public  safety,  combat  terrorism  and  maintain  unity  of  the 
legal system’, Act XIV of 2026 ‘on raising emergency decrees promulgated in view of the armed conflict in 
Ukraine to the level of an Act of Parliament’. 

174   Amnesty International Hungary et al. (2026), p. 80. See also 2025 Rule of Law Report, Hungary, p. 23. 
175   Country visit Hungary, Hungarian Chamber of Commerce and Industry. According to European standards, 
the  legislative  process  needs  to  be  efficient,  transparent,  inclusive  and  democratic,  and  the  legislature 
should follow the standard legislative procedure and avoid resorting to expedited adoption of legal acts on a 
regular basis (Venice Commission, Updated Rule of Law Checklist (December 2025), para. 34). 

176   Amnesty International Hungary et al.  (2026), p. 75, Háttér Society (2026), p. 20. The statutory minimum 
consultation  period  of  eight  days  is  observed,  regardless  of  the  length  and  complexity  of  the  draft  law. 
Explanatory  memoranda  are very  brief,  often  containing one  general  sentence.  The  authorities  ignore  the 
overwhelming  majority  of  stakeholder  contributions  without  providing  any  meaningful  reasoning.  Some 
pieces of legislation are presented to Parliament or adopted while the consultation period is still open. The 
government control body conducts annual audits to verify whether the ministers responsible for preparing 
legislation fulfil their obligations under  the Public Participation  Act and prepares an annual report on the 
results of the audits and the fines imposed. 

177   Amnesty International Hungary et al. (2026), p. 76. As of 15 January 2025, a new impact assessment sheet 
was introduced. According to the new Government, the procedure of public consultation complies with the 
provisions of Public Participation Act. 

178  These topics include the decree determining the names that parents can legally give to their children, as well 
as  all  matters  relating  to  nature  conservation  or  environmental  protection  (see  Section  13  of  the  omnibus 
law of June 2026, amending Section 5 of the Public Participation Act). 

179  The  Committee  will  also  facilitate  thematic  public  hearings  involving  CSOs,  trade  unions,  economic 
chambers,  and  other  organisations  representing  various  social  interests,  to  determine  whether  the 
Parliament’s further legislative action is necessary (additional input from the new Government). 

180   Primarily  used  to  expedite  bills  that  require  relatively  quick  adoption  without  completely  bypassing 
parliamentary debate. The time between the decision to use the urgent procedure and the final vote cannot 
be less than six days. It can be invoked a maximum of six times per calendar semester. 

181   The detailed debate occurs in a designated committee (the Committee on Legislation) rather than in plenary. 
There is no general debate in the plenary session; the plenary only meets the proposal for  the final debate 

23 

 
 
On  23  June  2026,  Parliament  extended  the  possibility  of  such  deviations  from  the  general 
procedural rules until the end of the year182. The former government continued its practice of 
including  only  technical  amendments  in  draft  laws,  before  introducing  new,  substantive 
amendments  to  the  bill  at  a  late  stage  in  the  legislative  process  through  the  Committee  on 
Legislation,  just  before  the  final  parliamentary  vote.  This  prevented  regular  parliamentary 
debate  and  public  consultation.  Cardinal  acts  are  still  being  used  beyond  what  is  strictly 
necessary,  and  even  in  respect  of  detailed  legislation;  this  makes  it  difficult  to  introduce 
reforms in the future as their adoption or amendment requires two-thirds of the votes of the 
members of Parliament present183. 

Less than half of companies surveyed in Hungary express confidence in the effectiveness 
of investment protection. 49% of companies are very or fairly confident that investments are 
protected by law and courts, a figure which has slightly increased in comparison with 2025 
(46%)184.  The  main  reason  among  companies  for  their  lack  of  confidence  are  the  frequent 
changes  in  legislation  or  concerns  about  quality  of  the  law-making  process  (28%)185.  As 
regards authorities relevant for economic operators, 21% of companies perceive the level of 
independence of the national competition authority (Competition Authority) as very or fairly 
good,  a  figure  which  has  significantly  decreased  in  comparison  with  2025  (37%)186.  The 
Kúria  has  jurisdiction  in  several  business-related  cases,  including  in  cases  related  to  public 
procurement,  public  concessions,  public  contracts  and  economic  regulation.  A  number  of 
judicial  mechanisms  to  improve  efficiency  are  available  in  these  cases,  including  the 
possibility to apply interim measures and the consolidation of multiple appeals187. 

Foreign  companies,  including  those  from  other  EU  Member  States,  operating  in 
strategic  sectors,  continue  to  face  intensified  regulatory  pressure  from  state  action. 
Stakeholders  report  that,  over  recent  years,  a  consistent  pattern  of  targeted  legislation  and 
administrative  practice  has  disproportionately  affected  foreign-owned  companies  and 
cumulatively  undermined  legal  certainty,  market  access  and  the  freedom  of  establishment. 
These  measures  span  over  multiple  sectors  and  have  resulted  in  sustained  de-investment, 
distortion  of  competition  and  a  progressive  deterioration  of  investor  confidence.  A  core 
concern is the persistence of tailor-made sectoral legislation and special taxes that effectively 
remove the financial base of foreign investors, adversely affecting the operation of the single 
market188.  In  the  food  retail  sector,  market  leaders,  which  are  predominantly  multinational 
companies,  continue  to  be  affected  by  the  progressive  retail  tax,  while  Hungarian 
cooperatives benefit from significantly lower taxation due to a preferential treatment of their 

and vote. Unlike the urgent procedure, there is no minimum timeframe between the decision and the final 
vote, allowing for extremely rapid passage. It can be used only four times per calendar semester. 

182  Resolution 35/2026 (VI. 23.) OGY of the National Assembly amending Resolution 10/2014 (II. 24.) OGY 
on certain provisions of the Rules of Procedure. The maximum number of urgent procedures per semester 
was increased from six to 15, and the maximum number of exceptional procedures was increased from four 
to 10. 

183   See  2020  Rule  of  Law  Report,  Hungary,  p.  16.  The  Seventeenth  Amendment  to  the  Fundamental  Law 

would reduce the number of issues to be regulated through a cardinal law. 

184   Figure 52, 2026 EU Justice Scoreboard.  
185   Figure  53,  2026  EU  Justice  Scoreboard.  22%  of  the  surveyed  investors  perceive  concerns  about  quality, 

efficiency or independence of justice as a reason for the lack of confidence in investment protection.  

186   Figure 60, 2026 EU Justice Scoreboard.  
187   Figures 66 and 67, 2026 EU Justice Scoreboard. The data presented reflects exclusively the mechanisms in 
place at the level of the highest administrative jurisdictions; the same or other mechanisms may be in place 
at lower instance administrative courts. 

188   Ost-Ausschuss der Deutschen Wirtschaft – German Eastern Business Association (2026), pp. 21-22; WKÖ 

– Austrian Federal Economic Chamber (2026), pp. 21-22. 

24 

 
 
store networks. On 29 April 2026, the Commission decided to refer Hungary to the Court of 
Justice for failing to abolish its retail tax regime189. Price and price margin regulation regimes 
further  exacerbate  the  situation190.  Foreign  retailers  also  face  systematic  restrictions  on 
expansion191. Comparable discriminatory patterns exist in the construction materials industry. 
Measures  include  export  restrictions192,  mandatory  production  volumes,  supplementary 
mining royalties of up to 90% of turnover193 and a carbon dioxide quota tax combined with a 
transaction  fee  on  free  EU  emissions  trading  system  allowances194.  On  11  June  2025,  the 
National  Assembly  passed  an  omnibus  law  that  turned  these  emergency  measures  into 
statutory legislation195. In the mining sector, further practices can be observed, such as non-
transparent  and discriminatory tender procedures for sand and gravel mining sites that limit 
competition196. 

The  legal  framework  that  allows  the  selective  application  of  competition  rules  further 
weakens  legal  certainty  for  businesses.  The  December  2025  amendment  to  the  national 
competition  rules  allows  the  Competition  Authority  to  declare  a  mining  or  construction 
undertaking  ‘to  be  of  cross-market  significance’  and  impose  far-reaching  obligations  on  it, 
without  the  need  to  show  any  breach  of  competition  rules197.  The  possibility  for  the 

189   INFR(2024)4022.  Due  to  the  current  design  of  the  retail  tax  regime,  foreign  controlled  retail  companies 
operating  in  Hungary  as  integrated  companies  or  linked  undertakings,  are  subject  to  high  and  steeply 
progressive  tax rates  on  their  turnover.  Domestic  retailers  operating  on  the  Hungarian market  under  their 
respective  brands  and  logos  via  franchise  systems  are  not  subject  to  the  same  highest  rates  because  their 
turnover is not consolidated for taxation purposes.  

190  First, the CJEU ruled that the price cap measure introduced by the Hungarian  authorities in 2022 violates 
EU law (judgment of 12 September 2024, SPAR Magyarország, C-557/23). Then, the CJEU found that the 
mandatory  promotion  scheme  introduced  in  2023  in  the  food  retail  sector  is  in  breach  of  EU  agricultural 
and internal market rules (judgment of 18 June 2026, Penny Market, C-658/24). Most recently, on 8 July 
2026,  the  Commission  decided  to  refer  Hungary  to  the  CJEU  in  two  infringement  cases  concerning 
measures that impose price margin restrictions on all non-Hungarian businesses but only some Hungarian 
firms.  One  procedure  (INFR(2025)2052)  concerns  restrictions  with  regard  to  the  sale  of  certain  food 
products by food retailers (see also joint cases C-840/25, Penny Market II and C-10/26, Lidl Magyarország, 
pending before the CJEU). The other procedure (INFR(2025)2102) covers similar restrictions for the sale of 
certain non-food products by drugstores.  

191   Under the long-standing ‘Plaza Stop’ regime, permits are required for the construction, renovation, leasing 
or  acquisition  of  retail  spaces  measuring  over  400  square  metres.  In  practice,  permits  for  multinational 
retailers  are  routinely  denied  without  transparent  reasoning.  A  tightening  of  the  regulations  in  2025 
invalidated existing permits upon ownership or tenancy changes, effectively blocking all expansion. Further 
limitations introduced by Government Decree 280/2024 of 30 September 2024 restrict the maximum size of 
stores in residential areas to between 400 and 800 square metres. 

192   On  13  November  2025,  the  CJEU  found  that  the  procedure  established  by  Hungary  for  exports  of  raw 
materials  and  construction  materials  is  contrary  to  EU  law  (case  C-499/23,  Commission  v  Hungary 
(Construction materials for critical infrastructure)). On 11 March 2026, the Commission decided to further 
pursue an infringement procedure by sending a letter of formal notice to Hungary (INFR(2021)2158) under 
Article 260 TFEU for not complying with the judgment in case C-499/23.  

193   On  22  January 2026,  the  CJEU  ruled  that  the  additional  mining  fee  introduced  by  Hungary  infringes  EU 
law  (judgment  of  the  CJEU,  case  C-144/24,  Commission  v  Hungary  (Additional  mining  fee)).  Under  the 
new  Government,  the  authorities  decided  not  to  collect  the  supplementary  mining  royalties  from  1  June 
2026. On 8 July 2026, the Commission called on Hungary to comply with the judgment. 

194   On  18  June  2025,  the  Commission  opened  an  infringement  procedure  (INFR(2025)4016)  for  applying  a 
carbon quota tax and a transaction fee to recipients of a significant free allocation of allowances under the 
EU Emissions Trading System, as those charges interfere with EU law. On 16 April 2026, in a preliminary 
reference case, the CJEU found that the national carbon quota tax under Government Decree 320/2023 of 
17 July 2023 was incompatible with EU law (judgment of the CJEU, case C‑519/24, Nitrogénművek).  

195   See Sections 92-95, 119-122 and 243-245 of Act L of 2025. 
196  See infringement procedure INFR(2025)2051.  
197   In particular, the  Competition Authority can oblige shareholders to divest their shares partly or fully  (Act 
XCVIII of 2025 amending the Competition Act, see in particular Section 43/F). See also HVG.hu (2025b).   

25 

 
 
Government to interfere with the application of merger control rules continues to give rise to 
legal  uncertainty198.  The  Competition  Authority  reportedly  continues  to  apply  the  rules 
selectively199.   

Issues  remain  with  the  way  institutional  checks  and  balances  are  applied.  Concerns 
remain  regarding  the  independence  and  effective  functioning  of  the  Commissioner  for 
Fundamental Rights200. On 22 September 2025, the National Assembly – voting with a two-
thirds  majority  as  required  by  the  Fundamental  Law  –  elected  a  new  Commissioner, 
following  a  recommendation  by  the  President  of  the  Republic,  with  no  prior  call  for 
applications  or  meaningful  consultation  with  civil  society  and  professional  organisations. 
Shortly  after  the  new  Commissioner  took  office,  position  papers  by  the  former  deputy 
Commissioner for the Rights of Minorities, published after the expiry of her mandate, were 
removed  from  the  Commissioner’s  website201.  On  6  February  2026,  the  Commissioner  for 
Fundamental  Rights  requested  that  the  Constitutional  Court  assesses  whether  the  rules  of 
Regulation  (EU)  2024/900  on  the  transparency  and  targeting  of  political  advertising  are 
compatible with the Fundamental Law’s provisions on conferral and political advertisement 
and  whether  the  Regulation  must  be  ‘set  aside’  if  found  incompatible  with  these 
provisions202.  The  Constitutional  Court,  composed  of  members  elected  by  the  National 
Assembly  without  the  involvement  of  the  judiciary,  is  still  reviewing  the  merits  of  final 
rulings by ordinary courts in politically sensitive cases203. The Constitutional Court does not 

198   2025  Rule  of  Law  Report,  Hungary,  p.  26.  The  Government  can  still  declare  certain  mergers  and 
acquisitions to be of ‘strategic importance for the national economy’. Such transactions do not need to be 
notified  to  the  Competition  Authority,  which  consequently  cannot  perform  its  control  function.  Such 
Government decrees are not subject to judicial review and increase legal uncertainty for both domestic and 
foreign  companies.  This  practice  has  enabled  the  implementation  of  a  nationalisation  strategy  in  key 
sectors, such as energy, media and telecommunication. 

199   2025 Rule of Law 2025, Hungary, p. 26. According to stakeholders (Amnesty International Hungary et al. 
(2026),  p.  55;  K-Monitor  (2026),  p.  28;  Transparency  International  Hungary  (2026),  p.  24),  more  recent 
examples  include  the  cartel  investigations  opened  into  companies  owned  by  an  entrepreneur  who  has 
publicly criticized the governing party (see also HVG.hu (2025a)) and by a businessman who divorced the 
daughter of a tycoon close to the former Prime Minister (see also 24.hu (2025a)). 

200   The Commissioner for Fundamental Rights continues to be downgraded by the Global Alliance of National 
Human Rights Institutions (GANHRI) from ‘A’ to ‘B’ status due to its inactivity in a number of areas (e.g. 
the  rights  of  ethnic  minorities,  LGBTI+  persons,  human  rights  defenders,  refugees  and  migrants,  media 
pluralism,  civic  space  and  judicial  independence),  which  has  evidenced  a  lack  of  independence  and 
compromised  compliance  with  the  Paris  Principles.  GANHRI  also  deemed  the  Commissioner's  selection 
and appointment process to be insufficiently broad and transparent (see 2024 Rule of Law Report, Hungary, 
p.  33).  The  downgrade  was  decided  in  a  reaccreditation  procedure  reviewing  the  2014–2019  period  and 
predates  the  mandate  of  the  incumbent  Commissioner,  elected  in  September  2025  by  a  two-thirds 
parliamentary  majority;  the  Office  of  the  Commissioner  has  formally  challenged  the  downgrade  (further 
input from the new Government). 

201   Qubit  (2025).  The  work  of  the  deputy  commissioner  was  considered  vital  public  documentation  of  the 
situation of vulnerable groups, including hate crimes and hate speech. According to the office of the new 
commissioner,  the  documents  concerned  were  published  on  4  November  2025,  after  the  expiry  of  the 
former Deputy Commissioner’s mandate, and did not meet the statutory requirements of Act CXI of 2011, 
under which only the Commissioner is entitled to issue reports on inquiries, while Deputy Commissioners 
may issue policy statements within their field of competence following professional consultation with the 
Commissioner.  Nevertheless,  all  policy  statements  and  documents  lawfully  issued  by  the  former  Deputy 
Commissioner during her mandate remain accessible in the Office’s archives.  

202  Case X/00538/2026, pending. 
203   E.g.  the  Constitutional  Court  annulled  a  Kúria  decision  that  allowed  a  referendum  on  the  verification  of 
asset  declarations  (Decision  7/2025.  (VII.  24.)  AB).  It  also  annulled  a  Kúria  decision  finding  the  public 
broadcaster  in  breach  of  the  requirement  for  balanced  programming  by  predominantly  covering  the 
governing  party’s  political  campaign  (cases  IV/825/2026  and  IV/964/2026).  According  to  the  new 
Government,  the  constitutional  complaint  against  final  judicial  decisions  is  a  general  individual  remedy 

26 

 
 
have a transparent  case  allocation scheme in  place, nor is  it bound by procedural  deadlines 
when  hearing  constitutional  complaints204.  The  omnibus  law  of  June  2026  repealed  the 
provision in the Constitutional Court Act, introduced in December 2023, which allowed the 
Constitutional Court to give an advisory opinion – upon request of the Court of Justice of the 
EU – on the interpretation of the rules related to a series of constitutional elements205.  

A constitutional  revision process  has been initiated.  The Seventeenth  Amendment to  the 
Fundamental Law would reinstate a retirement age of 70 for members of the Constitutional 
Court. Consequently, the terms of office of four of the 15 members, including the president, 
would  expire  when  the  constitutional  amendment  comes  into  effect.  The  Seventeenth 
Amendment  would  also  allow  the  Constitutional  Court  to  elect  its  own  president  and  to 
review  the  constitutionality  of  tax  laws206.  Moreover,  the  constitutional  amendment  would 
terminate  the  mandate  of  the  incumbent  President  of  the  Republic207.  Following  public 
consultation, the Seventeenth Amendment was adopted by the National Assembly on 13 July 
2026 and is yet to be promulgated. 

Effective  judicial  review  of  administrative  decisions  is  lacking  in  sensitive  cases.  An 
omnibus  law  adopted  on  21  October  2025  amended  the  Code  of  Administrative  Litigation, 
seeking  to  streamline  the  judicial  review  of  administrative  decisions208.  Procedural  rules 
assign  an  increasing  list  of  cases  to  the  Kúria  as  a  first  and  last  instance  court209.  In  some 
cases, no judicial review is available at all. This notably included investigations and reports 
by the Sovereignty Protection Office210. Similar provisions are being  considered  for  certain 
proceedings  of  the  future  National  Asset  Recovery  and  Protection  Office.  Also,  on  3 
February 2026, an emergency measure211 issued by the former government under the ‘state of 
danger’  regime  removed  municipalities’  ability  to  challenge  before  the  competent  courts 
administrative  decisions  related  to  the  ‘solidarity  levy’  imposed  on  them  by  the  former 

available  to  any  party  in  any  individual  case  who  alleges  the  violation  of  a  right  guaranteed  by  the 
Fundamental Law. 

204   See  2025  Rule  of  Law  Report,  p.  26.  There  is  no  deadline  for  the  final  decision  to  be  taken  in  a 
constitutional  complaint  procedure.  Under  Section  53(1)  of  the  Internal  Rules  of  Procedure,  the 
Constitutional Court must decide on the admissibility of a constitutional complaint within 120 days of the 
Secretary  General’s  notification  of  the  initiation  of  proceedings,  and  under  Section  53(2),  the  rapporteur 
judge  must  submit  the  first  draft  within  180  days  of  admission.  The  average  time  taken  to  resolve 
constitutional complaints was 290 days in 2025 and 287 days in the first quarter of 2026. 

205  Section 35 of the omnibus law of June 2026, repealing Section 1c) and Sub-title 16/A of the Constitutional 

Court Act. See 2024 Rule of Law Report, Hungary, pp. 35-36. 

206  T/324. 
207  Following the termination of the mandate of the President of the Republic in office, the National Assembly 
would  elect  a  President  of  the  Republic  for  a  term  lasting  until  the  date  of  entry  into  force  of  a  new 
Constitution, but for a maximum period of five years. 

208   Act LXXIX of 2025 amended  the Code of Administrative Court Procedure. The new rules make it easier 
for unrepresented individuals to submit petitions to the court, clarify the composition of the bench (whether 
a single judge or a panel of judges will hear the case) in certain instances, and speed up the process. 
209   These include cases related to elections, referenda, freedom of assembly, ‘suspension’ of citizenship. 
210   Section  8(2)  of  the  Protection  of  National  Sovereignty  Law.  The  Constitutional  Court  did  not  rule  this 

provision as unconstitutional (Decision 20/2024. (XI. 28.) AB). 

211   Government Decree 15/2026 of 3 February 2026. The decree came into force on 4 February 2026. Under 
the  emergency  measure,  courts  were  also  prevented  from  granting  immediate  legal  protection  (interim 
relief) in such cases. Introduced in 2012, the municipal ‘solidarity levy’ redistributes some of the revenues 
from local business taxes from wealthier municipalities to poorer ones. Its rate has increased steadily over 
time.  According  to  the  Constitutional  Court,  the  local  governments  concerned  must  be  involved  in  this 
procedure and it must be ascertained that the collection of the levy does not endanger their functioning. 

27 

 
 
government; it also obliged courts to discontinue ongoing cases212. In certain cases, following 
annulment by the courts, the authorities fail to adhere to the legal interpretation set out in the 
court  judgment  that  overturned  the  administrative  decision.  This  forces  citizens  and 
businesses  to  challenge  such  decisions  in  court  repeatedly  within  the  same  case213.  In  the 
context of the possibility to ‘suspend’ the citizenship of a Hungarian citizen who also holds 
the citizenship of another State, the Venice Commission found that the rigid procedural time-
limit for contesting the administrative decision and the absence of a suspensive effect of an 
application  to  the  court  (the  Kúria),  combined  with  a  risk  of  expulsion  following  the 
suspension of citizenship, may adversely affect the effective exercise of the  right to judicial 
review by the person concerned214.  

On  1  January  2026,  Hungary  had  49  leading  judgments  of  the  European  Court  of 
Human  Rights  pending  implementation,  an  increase  of  2  compared  to  the  previous 
year215.  At  that  time,  Hungary’s  rate  of  leading  judgments  from  the  past  10  years  that  had 
been implemented was at 29% (compared to 26% in 2025; 71% remained pending), and the 
average time that the judgments had been pending implementation was 6 years and 9 months 
(compared  to  6  years  and  6  months  in  2025)216.  The  oldest  leading  judgment,  pending 
implementation  for  more  than  16  years,  concerns  the  violation  of  the  right  to  freedom  of 
assembly217. As regards the respect of payment deadlines, on 31 December 2025 there were 
24 cases in total awaiting confirmation of payments (compared to 32 in 2024)218. On 17 June 
2026, the number of leading judgments pending implementation had increased to 53219.  

The  absence  of  procedural  safeguards  and  effective  oversight  in  the  event  of  secret 
surveillance  measures  outside  of  criminal  proceedings  is  a  concern  that  still  has  not 
been addressed220. The relevant judgments of the European Court of Human Rights have not 
yet been executed221. On 11 June 2026, the Committee of Ministers of the Council of Europe 
invited the Hungarian authorities ‘to advance the necessary legislative reforms to ensure that 
the  domestic  framework  on  secret  surveillance  for  national  security  purposes  fully  and 
effectively  complies  with  the  Convention,  addressing  all  shortcomings  identified  by  the 
Court’222. In a judgment of 3 February 2026, the European Court of Human Rights found that 

212   Pursuant to a motion submitted by the National Judicial Council, on 6 May 2026, the Constitutional Court 

annulled the justice-related provisions of the emergency measure (case IX/673/2026). 

213   Country visit Hungary, Háttér Society. This phenomenon was already described in the CJEU’s judgment of 

29 July 2019, Torubarov, Case C–556/17. 

214   Venice  Commission  (2025),  paras.  68  and  69.  The  possibility  to  ‘suspend’  Hungarian  citizenship  was 
introduced by the Fifteenth Amendment to the Fundamental Law (See Article G(3)) and Act LXIV of 2025, 
inserting Sections 9/A to 9/E to Act LV of 1993. 

215   For an explanation of the supervision process, see the website of the Council of Europe.   
216   All figures calculated by the European Implementation Network (EIN) and based on the number of cases 
that are considered pending at the annual cut-off date of 1 January 2026. EIN (2026), written input, p. 5. 

217   Judgment of the ECtHR, 5529/05, Patyi and Others v. Hungary, pending implementation since 2009.  
218   Council of Europe (2026), p. 162.   
219   Data according to the online database of the Council of Europe (HUDOC). 
220   See 2025 Rule of Law Report, Hungary, pp. 26-27. 
221   Judgments of the ECtHR, 37138/14, Szabó and Vissy v Hungary, 58032/16, Hüttl v Hungary and 31091/16, 

Klaudia Csikós v Hungary. 

222  CM/Del/Dec(2026)1563/H46-19.  In  the  Klaudia  Csikós  case,  the  Committee  of  Ministers  ‘noted  with 
interest the new  Code of Criminal Procedure, which has introduced a number of safeguards in respect of 
covert  investigative  measures  in  criminal  proceedings,  including  a  clearer  definition  of  the  persons  who 
may be subject to such measures, the requirement of a prior balancing exercise with particular emphasis on 
the protection of journalists and their sources, and an obligation to notify individuals of such measures after 
the fact’. 

28 

 
 
the  provisions  in  the  Police  Act223  relating  to  integrity  testing  carried  out  by  the  National 
Protective Service and the use of related secret surveillance fail to satisfy the requirements of 
Article 8 of the European Convention on Human Rights due to the indiscriminate nature of 
the  measures  in  question  and  the  lack  of  adequate  safeguards224.  An  emergency  measure 
issued by the former Government under the ‘state of danger’ regime authorised the National 
Tax  and  Customs  Administration  on  an  ad  hoc  basis  to  engage  in  covert  information 
gathering without applying the rules on criminal procedure225. 

Independent  civil  society  organisations  continued  to  be  under  pressure  under  the 
former government, whilst some progress has been made under the new government on 
the  recommendation  to  remove  obstacles  hindering  the  work  of  civil  society 
organisations226.  Civic  space  continues  to  be  rated  as  ‘obstructed’  by  Civicus227.  Although 
the  statutory  framework  for  setting  up  civil  society  organisations  (CSOs)  aligns  with 
European standards228, the complexity of the registration procedure may pose a challenge for 
smaller organisations with limited resources229. CSOs, particularly those with public benefit 
status,  must  comply  with  extensive  documentation  and  reporting  obligations230.  Although 
several  public  assemblies  aimed  at  promoting  equality  and  diversity  were  banned  by  the 
police, as confirmed partially by the Kúria, ‘Pride events’ were held in Budapest and Pécs on 
28 June and 4 October 2025, respectively. Despite the new rules, no fines were imposed on 
the  participants  of  these  events.  In  the  criminal  cases  brought  against  the  organisers  of  the 
Pride  events  held  in  Budapest  and  Pécs  in  2025,  the  prosecution  office  decided  on  4  June 
2026 to  drop the charges;  the competent  courts  consequently dismissed the cases231. On 27 
June 2026, the Budapest Pride took place with the assistance of the police. Further legislation 
hampering  CSOs’  capacity  of  working  remains  in  force,  although  it  is  not  being  applied  in 

223   See pillar II. These measures include the secret observation of individuals, places or vehicles; the gathering 
of information about what has happened in such places and the recording of such happenings by technical 
tools, such as video or audio recording. They also include the obtaining of data necessary to establish the 
communication via electronic devices or to identify or locate such devices. 

224   Judgment of the ECtHR, 15147/23 and 38303/23, Szelényi and Others v Hungary. 
225   Section 2(3) of Government Decree 49/2026 of 9 March 2026 on the measures necessary in the interest of 
national  security  in  connection  with  the  unusual  quantities  of  cash  and  gold  bars  transported  through  the 
territory of Hungary. 

226   The 2025 Rule of Law Report recommended that Hungary ‘[e]nsure that there are no obstacles hindering 
the  work  of  civil  society  organisations,  including  by  repealing  legislation  that  hampers  their  capacity  of 
working,  and  foster  a  safe  and  enabling  civic  space’.  No  progress  was  previously  assessed  on  this 
recommendation in 2025, 2024 and 2023. 

227   Ratings  by  Civicus  are  on  a  five-category  scale  defined  as:  open,  narrowed,  obstructed,  repressed  and 
closed.  The  score  for  Hungary  is  46/100.  In 2023,  61  076  CSOs  were  active  according  to  the  Hungarian 
Central  Statistical  Office.  The  number  of registered  CSOs  remained  stable,  and  no  forced  dissolutions  of 
CSOs were reported (Monitoring Action for Civic Space, Country Report, 2025: Hungary, p. 7). 

228   Article  11  of  the  European  Convention  on  Human  Rights  and  Recommendation  CM/Rec(2007)14  of  the 

Council of Europe. 

229   Amnesty  International  Hungary  et  al.  (2026),  pp.  96-97.  According  to  the  new  Government,  a  Civil 
Community  Service  Centre  Network  provides  administrative  support  to  CSOs.  They  offer  a  free,  public 
professional advisory service covering legal and public-benefit issues, as well as financial, accounting, and 
taxation matters. 

230   Amnesty International Hungary et al. (2026), p. 97; Centre for Reproductive Rights (2026), p. 23. 
231   The Pest Central District Court and the Pécs District Court, which were hearing the criminal cases brought 
against  the  organisers,  had  decided  to  suspend  the  proceedings  and  challenged  certain  provisions  of  the 
‘child  protection  law’  and  the  Freedom  of  Assembly  Act  before  the  Constitutional  Court  (cases 
III/00880/2026  and  III/00898/2026).  On  21  April  2026,  the  CJEU  found  that  by  adopting  a  law  which 
stigmatises  and  marginalises  LGBTI+  persons,  Hungary  had  acted  in  breach of EU  law  (judgment of  the 
CJEU, case C-769/22, Commission v Hungary (Values of the European Union)). Relying on that judgment, 
on 4 June 2026, the prosecution service dropped the charges. 

29 

 
 
practice232. On its  election platform, the new Government committed to  repealing laws that 
restrict and stigmatise the activities of CSOs. Critical narratives targeting independent CSOs 
ceased  following  the  general  elections  of  12  April  2026.  Under  the  former  government, 
pressure  on  activists  in  rural  areas  was  intensified  by  threats  of  losing  employment  in  the 
public  sector233.  Stigmatisation  was  further  exacerbated  under  the  former  government  by 
reports  of  the  Sovereignty  Protection  Office  that  continued  to  conduct  investigations  into 
various CSOs and media outlets234. A constitutional amendment and a legislative amendment, 
adopted on 15 and 30 June 2026, respectively, abolished the Sovereignty Protection Office as 
of 15 July 2026235; the infringement proceedings brought by the Commission are pending236. 
Under  the  former  government,  the  distribution  of  State  funding  earmarked  for  civil  society 
privileged government-aligned organisations237. The number of public interest trusts (PITs), 
as  well  as  the  value  of  the  public  assets  transferred  to  these  organisations  and  the  public 
funding  they  received  from  the  national  budget,  increased  further  under  the  previous 
government238. A constitutional amendment adopted on 15 June 2026 and the omnibus law of 
June 2026, allow the Government to phase out PITs, renationalise their assets received from 
the State and to appoint and remove in the transitional period their board members who need 
to  meet  strict  eligibility  criteria239.  Independent  CSOs  continue  to  depend  on  foreign 
institutional  and  private  donors240.  Under  the  former  government,  CSOs  receiving  grants 
from  abroad  were  among  the  primary  targets  of  smear  campaigns,  including  reports  of  the 
Sovereignty  Protection  Office241.  Stakeholders  reported  deteriorating  conditions  as  some 
CSOs had given up on applying for certain  foreign funds  or renounced previously  awarded 
foreign funding. Stakeholders reported that some CSOs had given up on certain activities and 
limited  their  communication  critical  of  the  former  government242.  Overall,  given  measures 

232   See  Section  253  of  Act  XLI  of  2018  introducing  a  special  25%  immigration  tax  applicable  to  financial 
support received by organisations carrying out ‘activities facilitating immigration’ and Section of 353/A of 
Act C of 2012 that deters the provision of legal assistance to asylum-seekers through criminalisation. Under 
Act  XLIX  of  2021  ‘on  the  transparency  of  organisations  carrying  out  activities  capable  of  influencing 
public  life’,  the  State  Audit  Office  continues  to  publish  yearly  summary  reports,  without  mentioning 
specific  CSOs.  The  draft  law  ‘on  transparency  in  public  life’,  tabled  on  13  May  2025  (see  2025  Rule  of 
Law Report, Hungary, p. 28), is no longer pending before the National Assembly. 

233   Monitoring Action for Civic Space, Country Report, 2025: Hungary, p. 6. 
234   On 4 December 2025, the Budapest Regional Court ruled that a report published by the Office in 2024 had 
wrongly  accused  Átlátszó,  an  investigative  portal,  of  spying  and  spreading  disinformation  (Judgment 
19.P.20.067/2025/19). On 28 May 2026, the  Budapest Regional Appeal Court quashed the judgment, and 
remitted the case to the first-instance court. 

235  Article  3  of  the  Sixteenth  Amendment  repealing  the  second  sentence  of  Article  R(4)  of  the  Fundamental 

Law and Act XXIV of 2026. 

236   Case C-829/24. On 12 February 2026, Advocate General Kokott invited the Court to find that Hungary has 

infringed EU law by adopting the Law on the protection of national sovereignty. 

237   444.hu  (2025).  There  are  several  state  instruments,  e.g.  the  National  Cooperation  Fund  and  the  City  and 
Village Civil Funds, that support CSOs with significant amounts: the former with HUF 16 billion (EUR 45 
million), while the latter with HUF 4.8 billion (EUR 13.5 million) each in 2025. 

238   The  ÉLVONAL  Top  Research  and  Talent  Development  Foundation  was  established  by  Act  LII  of  2025. 

The ZalaZONE Foundation was established by Act LIII of 2025.  

239  Article  4  of  the  Sixteenth  Amendment  repealing  Article  38(6)  of  the  Fundamental  Law,  Article  5  of  the 
Sixteenth Amendment introducing point 33 to the closing and miscellaneous provisions of the Fundamental 
Law and the omnibus law of 2026 amending the PIT Act and repealing the dedicated laws authorising the 
government to endow PITs that do not maintain higher education institutions  in Hungary. Such PITs will 
need to be de-registered by 31 August 2026. PITs maintaining higher education institutions in Hungary will 
be de-registered by 1 August 2027. See also pillar II. 

240   CSOs also rely on 1% of personal income tax based on citizens’ assignation, as well as on micro-donations, 

which they collect with increasing efficiency Ökotárs (2026), p. 24. 

241   Monitoring Action for Civic Space, Country Report, 2025: Hungary, p. 8. Ökotárs (2026), p. 17. 
242   Amnesty International Hungary et al. (2026), p. 100. 

30 

 
 
such as the abolition of the Sovereignty Protection Office, some progress has been made on 
this recommendation.  

31 

 
Annex I: List of sources in alphabetical order* 

* The list of contributions received in the context of the consultation for the 2026 Rule of Law Report 
can 
https://commission.europa.eu/publications/2026-rule-law-report-targeted-
found 
stakeholder-consultation_en.  

be 

at 

24.hu  (2026),  László  Windisch  has  taken  action:  the  President  of  the  SAO  has  initiated  the 
termination  of 
Integrity  Authority, 
https://24.hu/belfold/2026/06/16/windisch-laszlo-asz-integritas-hatosag-felmentes-breking/. 

the  President  of 

relationship  of 

legal 

the 

the 

24.hu  (2025),  The  competition  authority  forced  into  liquidation  the  company  of  Lőrinc  Mészáros's 
disgraced  ex-son-in-law  (Bedöntötte  a  versenyhivatal  Mészáros  Lőrinc  kegyvesztett  exvejének  a 
cégét) 
https://24.hu/fn/gazdasag/2025/11/19/homlok-zsolt-meszaros-lorinc-kegyvesztett-ex-veje-
felszamolas-csodvedelem-megabirsag/#paywall. 

24.hu (2025b), The President of the Integrity Authority, who is suspected of abuse of office, will not be 
fired  (Nem  rúgják  ki  az  Integritás  Hatóság  elnökét,  akit  hivatali  visszaéléssel  gyanúsítanak). 
https://24.hu/belfold/2025/08/19/integritas-hatosag-biro-ferenc-hivatali-visszaeles-allami-
szamvevoszek-ugyeszseg/. 

444.hu  (2025),  The  government’s  money  tap  has  been  reopened,  pouring  public  money  into  NGOs 
close to the state party (Újra kinyílt a kormányzati pénzcsap, ami közpénzt önt az állampárthoz közel 
https://444.hu/2025/05/21/ujra-kinyilt-a-kormanyzati-penzcsap-ami-
álló 
kozpenzt-ont-az-allamparthoz-kozel-allo-civil-szervezetekre.  

szervezetekre) 

civil 

444.hu (2025), The court has ruled: we cannot access the contracts related to the preparations for the 
Chad  mission  because  the  court  cannot  review  Péter  Szijjártó’s  ‘opinion’  (Döntött  a  bíróság:  nem 
ismerhetjük  meg  a  csádi  misszió  előkészítéséhez  kötődő  szerződéseket,  mert  Szijjártó  Péter 
„Véleményét”  a  bíróság  nem  vizsgálhatja  felül)  https://444.hu/2025/11/23/dontott-a-birosag-nem-
ismerhetjuk-meg-a-csadi-misszio-elokeszitesehez-kotodo-szerzodeseket-mert-szijjarto-peter-
velemenyet-a-birosag-nem-vizsgalhatja-felul.  

Amnesty International Hungary, Hungarian Civil Liberties Union, Hungarian Helsinki Committee, K-
Monitor,  Mérték  Media  Monitor,  Ökotárs  –  Hungarian  Environmental  Partnership  Foundation, 
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Anti-Corruption  Task  Force 
(2026),  Annual  report 
content/uploads/2026/03/KEMCS_2025_Eves_Jelentes.pdf.  

for  2025,  https://www.kemcs.hu/wp-

Center for Reproductive Rights (2026), Contribution for the 2026 Rule of Law Report. 

Centre  for  Media  Pluralism  and  Media  Freedom  (2026),  Media  Pluralism  Monitor  2026,  Country 
report for Hungary, https://cmpf.eui.eu/projects/media-pluralism-monitor/. 

CIVICUS (2026), CIVICUS Monitor https://monitor.civicus.org/country/hungary/.  

Commissioner  For  Fundamental  Rights  (2025),  Report  on  the  activities  of  the  Commissioner  for 
Fundamental Rights and his deputies 2024, https://www.parlament.hu/irom42/11125/11125.pdf.   

Corruption  Research  Center  Budapest  (2026),  The  New  Trends  of  Corruption  Risk  in  Hungarian 
Public Procurement from January 1998 to September 2025; CRCB Statistical Flash Report 2026:1. 

Court of Justice  of  the  European  Union, judgment of  12  September  2024,  SPAR  Magyarország,  C-
557/23, ECLI:EU:C:2024:737. 

Court  of  Justice  of  the  European  Union,  judgment  of  13  November  2025,  Commission  v  Hungary 
(Construction materials for critical infrastructure), C-499/23, ECLI:EU:C:2025:875. 

32 

 
Court  of  Justice  of  the  European  Union,  judgment  of  16  April  2026,  Nitrogénművek,  C‑519/24, 
ECLI:EU:C:2026:297. 

Court  of  Justice  of  the  European  Union,  judgment  of  18  June  2026,  Penny  Market,  C-658/24, 
ECLI:EU:C:2026:495. 

Court  of  Justice  of  the  European  Union,  judgment  of  22  January  2026,  Commission  v  Hungary 
(Additional mining fee), C-144/24, ECLI:EU:C:2026:34. 

Court  of  Justice  of  the  European  Union,  judgment  of  26  February  2026,  the  CJEU,  Commission  v 
Hungary (Right to provide media services on a radio frequency), C-92/93, ECLI: EU:C:2026:108. 

EDMO  (2026),  Unstoppable  political  ads,  anti-Ukrainian  narratives,  and  misleading  stats  in  the 
Hungarian  election  campaign,  https://edmo.eu/publications/unstoppable-political-ads-anti-ukrainian-
narratives-and-misleading-stats-in-the-hungarian-election-campaign/.  

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

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

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

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

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

European  Court  of  Human  Rights,  judgment  of  28  November  2024,  Klaudia  Csikós  v  Hungary, 
31091/16.  

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

European  Court  of  Human  Rights,  judgment  of  3  February  2026,  Szelényi  and  Others  v  Hungary, 
15147/23 and 38303/23. 

European Court of Human Rights, judgment of 30 March 2023, Szaxon v Hungary, 54421/21. 

European  Network  of  Councils  for  the  Judiciary  (2026),  Contribution  for  the  2026  Rule  of  Law 
Report. 

GRECO (2019), Third Evaluation Round – Second Addendum to the Second Compliance Report on 
Hungary  on  incriminations  and  transparency  of  party  funding,  https://rm.coe.int/third-evaluation-
round-second-addendum-to-the-second-compliancereport/168096947e. 

(2022),  Fourth  Evaluation  Round 

GRECO 
https://rm.coe.int/fourth-evaluation-round-corruption-prevention-in-respect-of-
membersof/1680a7f171. 

–  Third 

Interim  Compliance  Report, 

GRECO (2023a), 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-preventingcorruption-and-promoting-integrity-
i/1680ab87f5. 

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

in 

Háttér Society (2026), Contribution for the 2026 Rule of Law Report. 

Hungarian Association of Judges (MABIE) (2026), Contribution for the 2026 Rule of Law Report. 

Hungarian Civil Liberties Union (2026), Contribution for the 2026 Rule of Law Report. 

Hungarian 
Report. 
https://www.gvh.hu/pfile/file?path=/gvh/orszaggyulesi_beszamolok/gvh_ogy_pb_2024&inline=true.  

Competition 

Authority 

(2025), 

Annual 

2024 

33 

 
Hungarian  Corps  of  Government  Officials,  Code  of  Professional  Ethics  of  the  Hungarian  Corps  of 
Government Officials, 15 July 2025.   

Hungarian Helsinki Committee (2026), Contribution for the 2026 Rule of Law Report. 

HVG.hu  (2025)  The  court  ruled  on  the  digital  civic  circles’  money  distribution  mechanism  in  51 
minutes,  while  others  wait  weeks  for  the  same  thing (51  perc  alatt  bírálták  el  a  bíróságon  a  DPK-k 
pénzosztó  gépezetét,  miközben  mások  heteket  várnak  ugyanerre)  https://hvg.hu/360/20251016_hvg-
dpk-alapitvany-Fovarosi-Torvenyszek-gyors-bejegyzes-51-perc-ugyfelerdek.  

HVG.hu (2025), ‘We’ve reached the end of our resources’ – due to a shortage of clerks, the president 
of  the  Budapest  Regional  Court  requested  assistance  in  a  letter  („Erőforrásaink  végére  értünk”  – 
levélben 
elnöke) 
https://hvg.hu/360/20250903_levelben-kert-segitseget-a-jegyzohiany-miatt-a-Fovarosi-Torvenyszek-
elnoke.  

Fővárosi  Törvényszék 

jegyzőhiány  miatt 

segítséget 

kért 

a 

a 

(2025a),  The  [Competition  Authority]  has  opened 

HVG.hu 
Nitrogénművek 
https://hvg.hu/kkv/20251119_GVH-Nitrogenmuvek-eljaras-Bige-Laszlo.  

eljárást 

indított 

(Újabb 

GVH 

a 

further  proceedings  against 
ellen) 
a 

Nitrogénművek 

HVG.hu  (2025b),  The  government  would  use  the  [Competition  Authority]  to  break  up  foreign 
construction  companies  (A  GVH-n  keresztül darabolná  fel  a külföldi  építőipari  cégeket  a  kormány) 
https://hvg.hu/kkv/20251209_GVH-versenyjogi-torveny-epitoipari-cegek-feldarabolas.  

HVG.hu (2026) János Lázár would rid the judiciary of ‘TISZA judges’ (Lázár János megszabadítaná 
„a 
https://hvg.hu/itthon/20260130_lazar-janos-
az 
megszabaditana-a-tiszas-biroktol-az-igazsagszolgaltatast.  

igazságszolgáltatást) 

bíróktól” 

tiszás 

HVG.hu (2026), A judge never registered with the Tisza app, yet they tried to discredit her in every 
way  possible  (Sosem  regisztrált  a  Tisza  applikációba  az  egyik  bírónő,  mégis  megpróbálták 
mindenhogyan  lejáratni)  https://hvg.hu/360/20260224_tisza-applikacio-birono-regisztracio-politikai-
tamadas.  

Integrity  Authority  (2025a),  The  Integrity  Authority's  response  to  the  Eligibility  Committee  report, 
https://integritashatosag.hu/en/reports/.   

Integrity  Authority  (2025b),  The  Eligibility  Committee's  report  on  the  Integrity  Authority's  work, 
https://integritashatosag.hu/en/reports/.   

Integrity 
https://integritashatosag.hu/en/reports/ .  

Authority 

(2025c), 

Annual 

Analytical 

Integrity 

Report 

2024, 

Integrity  Authority  (2026),  2025  Annual  report  to  Parliament,  https://integritashatosag.hu/wp-
content/uploads/2026/06/Eves-elemzo-integritasjelentes-20250630.pdf .  

K-Monitor (2025), Péter Polt, the unpunishable: the prosecutor's office used tricks to prevent us from 
review, 
submitting 
https://k.blog.hu/2025/08/22/polt_peter_a_buntethetetlen_trukkozessel_lehetetlenitette_el_az_ugyeszs
eg_a_felulbiralati_inditvanyu.  

motion 

our 

for 

K-Monitor (2026), Contribution for the 2026 Rule of Law Report. 

Kúria  (2025a),  Press  release  of  24  November  2025.  https://kuria-birosag.hu/hu/sajto/kuria-
kozlemenye-19.  

Kúria  (2025b),  Press  release  of  6  November  2025.  https://kuria-birosag.hu/hu/sajto/kuria-
kozlemenye-17.  

Kúria  (2026),  Press  release  of  16  February  2026.  https://kuria-birosag.hu/hu/sajto/kuria-elnokenek-
kozlemenye-frissitettuk.  

MEDEL (2026), Contribution for the 2026 Rule of Law Report. 

34 

 
National  Judicial  Council  (2025),  Verbatim  minutes  of  the  3  December  2025  meeting.  https://obt-
jud.hu/sites/default/files/ulesek/Jegyzokonyv_2025.12.03.pdf.  

National Judicial Council (2026a), Contribution for the 2026 Rule of Law Report. 

National  Judicial  Council  (2026b),  Verbatim  minutes  of  the  4  February  2026  meeting.  https://obt-
jud.hu/sites/default/files/ulesek/Jegyzokonyv_2026.02.04.pdf.  

National  Judicial  Council  (2026c),  Verbatim  minutes  of  the  14  January  2026  meeting.  https://obt-
jud.hu/sites/default/files/ulesek/Jegyzokonyv_2026.01.14.pdf. 

(2026), 

OECD 
https://www.oecd.org/en/publications/anti-corruption-and-integrity-outlook-2026_0c8910f8-
en/hungary_c2686ea4-en.html#section-d1e295 . 

Anti‑Corruption 

Integrity 

Outlook 

2026: 

and 

Hungary, 

Office of the Commissioner for Fundamental Rights (2025),  Press statement of 18 November 2025. 
https://www.ajbh.hu/en/-/2670755-298.  

Ökotárs (2026), Contribution for the 2026 Rule of Law Report. 

Ost-Ausschuss  der  Deutschen  Wirtschaft  –  German  Eastern  Business  Association  (2026), 
Contribution for the 2026 Rule of Law Report. 

Prosecution  service  (2026),  Indictment  Filed  Against  the  President  of  the  Hungarian  Integrity 
June  2026,  https://ugyeszseg.hu/en/indictment-filed-against-the-president-of-the-
Authority,  9 
integrity-authority/.  

Qubit  (2025),  Twelve  years’  worth  of  revealing  documents  were  secretly  removed  from  the 
ombudsman’s website overnight (Egyik napról a másikra, titokban eltüntették 12 év leleplező értékű 
dokumentumait  az  ombudsmani  hivatal  honlapjáról)  https://qubit.hu/2025/11/17/egyik-naprol-a-
masikratitokban-eltuntettek-12-ev-leleplezo-erteku-dokumentumait-az-ombudsmani-hivatal-
honlapjarol.    

Telex (2025), The penitentiary authority is issuing a warrant for the former Socialist deputy mayor of 
Terézváros,  who  was  sentenced  to  prison,  https://telex.hu/belfold/2025/10/22/korozteti-a-buntetes-
vegrehajtas-terezvaros-volt-szocialista-alpolgarmesteret-akit-letoltendo-bortonre-iteltek. 

Transparency  International  Hungary  (2025),  Public  Funds  and  Private  Profits:  The  Role  of  State 
Resources 
https://transparency.hu/wp-
content/uploads/2025/12/Ti-Hu_public_funds_and_private_profits_web-1.pdf.   

Hungarian 

Private 

Equity 

Funds 

in 

Transparency  International  Hungary  (2025),  Tender  Champions  –  The  performance  of  companies 
winning  public  procurement  contracts  and  the  role  of  their  owners  in  public  administration, 
https://transparency.hu/wp-content/uploads/2025/03/tenderbajnok_web_elemzes_final.pdf. 

Venice  Commission  (2025),  Hungary  -  Opinion  on  the  Compatibility  with  International  Human 
Rights Standards of the Fifteenth Amendment to the Fundamental Law of Hungary, 13 October 2025 
https://www.venice.coe.int/webforms/documents/default.aspx?pdffile=CDL-AD(2025)043-e.  

Venice Commission (2025), Venice Commission (2025), Hungary - Opinion on the constitutional and 
legislative  amendments  concerning  the  requirements  to  be  appointed  Prosecutor  General  and 
judges,  16  June  2025 
Constitutional  Court  Judge  of  as  well  as 
https://www.venice.coe.int/webforms/documents/default.aspx?pdffile=CDL-AD(2025)028-e.  

the  appointment  and 

Verfassungsblog  (2025),  Doxing  Judges  -  How  a  Serious  Personal  Data  Breach  Exposed  the 
Continuing Vulnerability of Hungary’s Judges https://verfassungsblog.de/hungary-judges-leak-list/.  

WKÖ – Austrian Federal Economic Chamber (2026), Contribution for the 2026 Rule of Law Report. 

35 

 
 
 
National legislation: 

Act on XXXIV of 1994 on Police (‘the Police Act’) 

Act  LVII  of  1996  on  the  prohibition  of  unfair  trading  practices  and  unfair  competition  (‘the 
Competition Act’)  

Act CXXXI of 2010 on public participation in the preparation of legislation (‘the Public Participation 
Act’) 

Act CLXXXV of 2010 on media services and on the mass media (‘the Media Act’) 

Act CXII of 2011 on the right of informational self-determination and freedom of information (‘the 
Freedom of Information Act’)  

Act CLI of 2011 on the Constitutional Court (‘the Constitutional Court Act’) 

Act  CLXI  of  2011  on  the  organisation  and  administration  of  courts  (‘the  Organisation  and 
Administration of Courts Act’) 

Act  CLXII  of  2011  on  the  legal  status  and  remuneration  of  judges  (‘the  Legal  Status  and 
Remuneration of Judges Act’) 

Act  LXXXVII  of  2013  on  the  transparency  of  campaign  costs  for  the  election  of  Members  of 
Parliament 

Act CXXX of 2016 on civil procedure (‘the Civil Procedure Code’) 

Act I of 2017 on administrative court procedure (‘the Code of Administrative Court Procedure’)  

Act XC of 2017 on criminal procedure (‘the Criminal Procedure Code’) 

Act CXXV of 2018 on Government administration (‘the Government Administration Act’) 

Act  XXVII  of  2022  on  the  control  of  the  use  of  European  Union  budget  funds  (‘the  Integrity 
Authority Act’) 

Act XXV of 2023 on complaints and public interest disclosures, and on the rules of whistleblowing 
notifications (‘the Whistleblowing Act’) 

Act  LXXXVIII  of  2023  on  the  protection  of  national  sovereignty  (‘the  Protection  of  National 
Sovereignty Law’) 

Act XLIX of 2025 on the amendment of laws related to judicial matters 

Act C of 2025 amending laws affecting the financial intermediary system 

Act XVIII of 2026 on the amendment of certain Acts necessary for accessing European Union funds 
(‘the omnibus law of June 2026’) 

36 

 
Annex II: Country visit to Hungary 

The Commission services held virtual meetings in February 2026 with: 

Integrity Authority   

•  Amnesty International Hungary  
•  Átlátszó 
•  Buda Central District Court   
•  Corruption Research Center Budapest   
•  Hungarian Association of Journalists (MÚOSZ)   
•  Hungarian Association of Judges (MABIE) 
•  Hungarian Bar Association (MÜK)   
•  Hungarian Civil Liberties Union (TASZ)   
•  Hungarian Helsinki Committee   
• 
•  K-Monitor  
•  Mathias Corvinus Collegium 
•  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 Office for the Judiciary (OBH)  
•  Office of the Commissioner for Fundamental Rights   
•  Prosecution Service of Hungary   
•  Res Iudicata - Judges for Social Awareness Association  
•  State Audit Office (Állami Számvevőszék)  
•  Transparency International Hungary 

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

•  Civil Liberties Union for Europe 
•  Civil Society Europe 
•  End FGM EU 
•  European Civic Forum 
•  European Partnership for Democracy 
•  Human Rights Watch 
• 
ILGA-Europe 
• 
International Federation for Human Rights 
•  Philea - Philanthropy Europe Association 
•  Transparency International EU 

37