COMMISSION STAFF WORKING DOCUMENT 2025 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 2025 Rule of Law Report The rule of law situation in the European Union

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COMMISSION
Strasbourg, 8.7.2025
SWD(2025) 917 final
COMMISSION STAFF WORKING DOCUMENT
2025 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
2025 Rule of Law Report
The rule of law situation in the European Union
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1
ABSTRACT
In Hungary, the National Judicial Council has continued to exercise the powers acquired
by means of the judicial reform of 2023. New rules have been introduced on the
appointment and career of judges. In line with the legislation in force, the process did not
always include the consultation of the National Judicial Council on some of the relevant
legislative amendments. The transparency of case allocation in lower courts has not been
improved, whereas the case allocation in the Kúria is being implemented well. The Kúria
continues to enforce uniformity of case law through its uniformity complaint panel.
Undue pressure on some judges continues within the judiciary, notably in relation to
internal debates on key issues related to judicial independence. An increase in salaries in
the justice system is being done in three steps until 2027. The efficiency of the judiciary
and digitalisation of the justice system continues to be high overall.
The implementation of the 2024-2025 National Anti-Corruption Strategy and related
Action Plan is ongoing, while important actions remain pending. The number of
convictions for corruption crimes has decreased and there has been no progress to
establish a robust track record on high-level corruption. Court decisions reviewing
prosecutorial decisions not to investigate or prosecute corruption continue to be non-
binding. There has been no progress yet to adopt new lobbying and post-employment
rules, although there are plans to legislate in this area by November 2025. The Integrity
Authority continues to report obstacles in fulfilling its oversight tasks effectively. Key
shortcomings with regard to the transparency of the financing of political parties and
electoral campaigns remain. Competition in public procurement has been improved, and
different levels of control remain for national and EU-funds related procurements.
The threats to media pluralism highlighted in previous Rule of Law Reports have
remained unaddressed. No measures have been adopted or are planned to regulate the
channelling of state advertising to media outlets, to guarantee the functional
independence of the media authority and to ensure the editorial and financial
independence of public service media. Journalists continue to face numerous and serious
challenges to their work. Journalists and media outlets have been investigated by the
Sovereignty Protection Office for allegedly ‘serving foreign interests’, and access to
public interest events and press conferences continues to be selectively denied. While the
accelerated treatment of court cases related to access to information continues, the scope
of access to information remains limited especially as regards public funding.
The Government continues to use its emergency powers extensively, undermining legal
certainty and affecting the operation of businesses in the single market. The law-making
process remains a serious source of concern, with certain important legislative processes
not being linked to public consultation requirements. Foreign companies, including from
other EU Member States, operating in strategic sectors face intensified regulatory
pressure from state action. The possibility for the Government to interfere with the
application of merger control rules continues to create legal uncertainty. Concerns related
to the absence of procedural safeguards and effective oversight in case of secret
surveillance measures outside criminal proceedings have not been addressed. A
deteriorating environment for civil society organisations and legal uncertainty further
obstruct civic space.
2
RECOMMENDATIONS
Overall, concerning the recommendations in the 2024 Rule of Law Report, Hungary has
made:
• No progress on improving the transparency of case allocation systems in lower-
instance courts, taking into account European standards on case allocation.
• Significant progress on increasing the remuneration of judges, prosecutors, and
judicial and prosecutorial staff, without however taking structural measures, taking
into account European standards on remuneration for the justice system.
• No progress yet on adopting comprehensive reforms on lobbying and revolving
doors, and further improving the system of asset declarations, providing for effective
oversight and enforcement.
• No progress on establishing a robust track record of investigations, prosecutions and
final judgments for high-level corruption cases.
• No progressing on introducing mechanisms to enhance the functional independence
of the media regulatory authority taking into account European standards on the
independence of media regulators.
• No progress on adopting legislation to ensure fair and transparent distribution of
advertising expenditure by the state and state-owned companies.
• No progress on strengthening the rules and mechanisms to enhance the independent
governance and editorial independence of public service media taking into account
European standards on public service media.
• No progress on removing obstacles affecting civil society organisations and foster a
safe and enabling civic space, including by repealing legislation that hampers their
capacity of working, in particular the immigration tax.
On this basis, and considering other developments that took place in the period of
reference, in addition to recalling the obligation to comply with the rule of law-related
rulings of the 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 relevant country-specific recommendations under the European
Semester, it is recommended to Hungary to:
• Improve the transparency of case allocation systems in lower-instance courts, taking
into account European standards on case allocation.
• Take 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.
• Put forward comprehensive legislative reforms on lobbying and revolving doors, and
further improve the system of asset declarations, providing for effective oversight and
enforcement.
• Establish a robust track record of investigations, prosecutions and final judgments for
high-level corruption cases.
• Introduce mechanisms to enhance the functional independence of the media
regulatory authority taking into account European standards on the independence of
media regulators.
3
• Adopt measures to ensure fair and transparent distribution of advertising expenditure
by the state and state-owned companies.
• Strengthen the rules and mechanisms to enhance the independent governance and
editorial independence of public service media taking into account European
standards on public service media.
• Ensure 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.
4
I. JUSTICE SYSTEM1
Independence
The level of perceived judicial independence in Hungary is low among the general
public and companies. Overall, 37% of the general population and 38% of companies
perceive the level of independence of courts and judges to be ‘fairly or very good’ in
20252
. The perceived level of independence among the general public has decreased in
comparison with 2024 (41%), as well as in comparison with 2021 (41%). The perceived
level of judicial independence among companies has slightly decreased since 2024 (40%)
but remains higher than in 2021 (32%).
The National Judicial Council has continued to exercise the powers acquired by
means of the judicial reform of 2023. In particular, the Council gave positive opinions
on the suitability of candidates for the post of Kúria Vice-Presidents3
and considered the
2023 appointment by the Kúria President of four court managers in the Kúria in line with
the law4
. After the retirement of the head of the Civil Department and the appointment of
the heads of the Criminal and Administrative Departments to the post of Vice-President,
the Kúria President did not propose the appointment of new heads of department, as a
Vice-President may also perform the duties of a head of department5
. Also, the Council
gave consent to the secondment of a judge to the National Directorate-General for
Hospitals.
New rules have been introduced on the appointment and career of judges, but the
process did not always include the consultation of the National Judicial Council on
some of the relevant legislative amendments, in line with the legislation in force. On
22 November 2024, the Ministry of Justice signed an agreement with the National
Judicial Council, the National Office for the Judiciary and the Kúria that includes salary
increases for judges and court staff and announces some reforms to the judicial system6
.
As a follow-up to this four-party agreement, in December 2024, the National Assembly
introduced several reforms. First, it passed legislation introducing the first step of a
staggered salary raise in the justice system. Second, it adopted an amendment to the
1
An overview of the institutional framework for all four pillars can be found here. 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.
2
Figures 51 and 53, 2025 EU Justice Scoreboard and Figures 49 and 51, 2023 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
Decision 51/2024 of 27 March 2024.
4
Decision 151/2024 of 4 September 2024.
5
See Section 123(4) of Organisation and Administration of Courts Act. Kúria Vice-Presidents are
appointed by the President of the Republic, upon the recommendation of the Kúria President. See also
Kúria (2025a).
6
The topics listed in the agreement include: an increase of salaries of judges and court staff; the
possibility for judges to serve until the age of 70; raising the minimum age requirement for becoming a
judge; incentivising applications from outside the judiciary; centralised training for trainee judges,
prosecutors, lawyers, notaries; the Kúria’s role in securing the uniformity of case law at all court
instances; extending the territorial jurisdiction of district court judges to the entire area of jurisdiction
of the regional court (that is the given county); the possibility of online presence during hearings; the
possibility not to hand down reasoned judicial decisions in civil cases if it is presumed that the parties
will not exercise their right of appeal; moving the registration of companies and CSOs from courts to
the public administration.
5
Fundamental Law (Fourteenth Amendment) which raises the minimum age for becoming
a judge and opens the possibility to continue serving as a judge after reaching the general
retirement age. Third, it introduced new requirements in terms of prior experience needed
to appoint judges from outside the judiciary. The reforms proposed by the Government
attracted criticism and protests from judicial associations and judges on the grounds of
judicial independence. Following these protests, the President of the National Judicial
Council resigned on 3 December 2024. Although the National Judicial Council had
discussed and signed the four-party agreement, it was not consulted on the subsequent
legislative amendments. In fact, the Council considered that new provisions will have a
negative impact on the working conditions of judges and on judicial training and will
create unjustified differences of treatment within the judiciary. On 15 January 2025, the
National Judicial Council withdrew from the four-party agreement, declaring it invalid.
However, the Minister of Justice announced that the Government would still continue
implementing the four-party agreement. On 11 June 2025, the National Assembly
adopted a cardinal law setting in statute the detailed rules of some of the reforms
mentioned in that agreement7
. The new law introduced rules related to the functioning of
the justice system, including detailed rules on the possibility for judges and prosecutors
to serve until the age of 70, the Kúria’s role in securing the uniformity of case law, the
possibility of online presence during hearings for members of the audience, the
possibility not to hand down reasoned judicial decisions in civil cases if it is presumed
that the parties will not exercise their right of appeal and the obligation of the courts to
pay the parties a daily lump sum as compensation for any breach of a procedural deadline
by the judge hearing the civil or administrative case. The National Judicial Council was
consulted on the draft in a procedure described by the Council as ineffective8
.
The Fourteenth Amendment to the Fundamental Law and other legislative
amendments9 changed the rules on judicial appointments. They raised the lower age
limit for becoming a judge from 30 to 35 years as of 1 March 2025 and introduced new
requirements of prior experience outside the judiciary for first-time appointments to
judicial posts10
. According to the Government, these changes will increase the quality of
the judicial system11
. The new appointment criteria are not applicable if the applicant for
a judicial position is a junior judge who was employed in the judicial system before 1
January 2025, or a junior judge who was employed in the judicial system as a trainee
judge before 1 January 2025. According to stakeholders, these changes favour candidates
who apply from outside the judiciary12
. On 16 June 2025, the Venice Commission found
that raising the minimum age for the appointment of judges from 30 to 35 years, although
7
Act XLIX of 2025.
8
See National Judicial Council (2025a) and National Judicial Council (2025b). The Council maintains
that the time allowed for comments on the draft law was insufficient, its representatives were not
invited to a consultation meeting held before the tabling of the draft law in Parliament and its
comments were not taken on board. On 1 July 2025, the National Judicial Council challenged the new
law before the Constitutional Court, maintaining a breach of its prerogatives.
9
Act LXXIV of 2024 and Act XLIX of 2025.
10
Under the new rules applicable from 1 March 2025, candidates must meet two conditions: (i) have
gained 2 years’ experience outside the judiciary (new requirement) and (ii) have worked at least 1 year
as a junior judge, deputy prosecutor, lawyer, notary public, legal adviser, government official or civil
servant, member of the Constitutional Court, judge, military judge, prosecutor, served as a judge at an
international organisation or any EU institution or carried out any other justice-related activity (not a
new requirement).
11
Country visit, Ministries. The Venice Commission could not answer at this early stage whether these
changes will serve, alone and in the abstract, to enhance public confidence in the judiciary and the
quality of judicial decision-making. Venice Commission (2025), para. 49.
12
Amnesty International Hungary et al (2025), p. 5; Hungarian Association of Judges (2025), p. 9.
6
rather high, is not per se contrary to international standards, and the requirement to have
a fresh outside view into the court system may be welcomed. The new rules introduced –
as of 1 January 2026 – the possibility for judges who have already reached the general
retirement age to stay on the bench until the age of 70. If the judge concerned requests
such extension in the timeframe determined by law, the President of the National Office
for the Judiciary or – in the case of Kúria judges – the Kúria President must
automatically grant the request13
.
The transparency of case allocation in lower courts has not been improved, whereas
the case allocation in the Kúria is being implemented well14. According to the
Government, there is no need to revise the legislation applicable to case allocation in
lower courts because the method of case allocation chosen by the court president has to
ensure the objective and even distribution of cases; deviation from the pre-established
rules is only allowed for reasons defined by law or because of important circumstances
affecting the functioning of the court15
. Several stakeholders note that the discretion
allowed to court managers in lower courts, the existing exemptions to the case allocation
rules and the frequent changes of these rules prevent the general public and the parties
from verifying whether the rules are being followed16
. Therefore, there has been no
progress on the recommendation regarding case allocation in lower courts. As regards
case allocation in the Kúria, following legislative reforms in 2023, the parties to the
proceedings at the Kúria are able to verify on the basis of the case file whether the rules
on case allocation have been duly applied17
. No complaints were reported from parties in
proceedings as regards case allocation at the Kúria18
.
The Kúria continues to enforce uniformity of case law through its uniformity
complaint panel. In 2024, the Kúria handed down 17 uniformity decisions and 40
uniformity complaint decisions (14 of them being on-the-merits decisions, including
three having the effect of a uniformity decision)19
. The Kúria’s uniformity decisions are
binding on Hungarian courts until the uniformity complaint panel changes the decision.
Preliminary references in the interest of uniformity of law and uniformity complaints are
heard by the uniformity complaint panel composed of the Kúria President or Vice
President and 40 senior judges (the Secretary General, heads and deputy heads of
department and presiding judges)20
. The Kúria maintains that, following a decision
handed down by the Court of Justice under Article 267 TFEU following a preliminary
reference, Kúria judges and panels are required to seek the opinion of the uniformity
complaint panel before setting aside (disapplying) a precedent decision of the Kúria,
13
Sections 25/B to 25/F of the Legal Status and Remuneration of Judges Act, as amended. This is in line
with the recommendation of the Venice Commission.
14
The 2024 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’.
15
Hungarian Government (2025), written input, p. 4.
16
Amnesty International Hungary et al (2024), p. 11; CCBE (2025), p. 99; Hungarian Association of
Judges (2025), p. 8; Hungarian Helsinki Committee (2025a); p. 12; MEDEL (2025), p. 7; Res Iudicata
(2025), p. 8; Ügyvédkör (2025), p. 7.
17
2023 Rule of Law Report, Hungary, p. 5; 2024 Rule of Law Report, Hungary, p. 6.
18
Kúria (2025c), p. 1.
19
In 2023, the Kúria delivered 9 uniformity decisions and 52 uniformity complaint decisions (21 of them
being on-the-merits decisions, including 4 having the effect of a uniformity decision). See also 2024
Rule of Law Report, Hungary, p. 7.
20
Section 41/A (1) of the Organisation and Administration of Courts Act. According to the case
allocation scheme, the uniformity complaint panel has two subpanels, each composed of a chairperson
and 20 members.
7
found incompatible with EU law21
. This is necessary because the uniformity complaint
panel has the exclusive competence to remove the binding force of legal interpretations
contained in previously published Kúria decisions. 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 law22
. A new law23
adopted on 11 June 2025 further strengthens as of
1 January 2026 the Kúria’s role in enforcing the uniformity of case law when reviewing
binding judicial decisions in civil cases.
Undue pressure on some judges continues within the judiciary, notably in relation
to internal debates on key issues related to judicial independence. The Kúria
President regularly questions in public the legitimacy of the service courts24
and his
criticism intensified after the presidents of the service courts and several other judges
publicly criticised the four-party agreement25
. This prompted reactions from the National
Judicial Council, the Res Iudicata Association and the Hungarian Association of Judges,
which organised a demonstration in defence of judicial independence26
. On 17 March
2025, the Budapest Regional Court found that the Kúria President had unlawfully
relieved a presiding judge from his duties as a sanction for expressing his criticism in
relation to the Kúria27
. On 6 March 2025, in the context of the enhanced supervision of
the implementation of the Baka judgment of the European Court of Human Rights, the
Committee of Ministers of the Council of Europe invited the Hungarian authorities to
consider adopting further general measures to address the ‘chilling effect’ present in the
judiciary and to ensure that judges’ freedom of expression, notably related to matters of
public interest concerning the judiciary, is unambiguously guaranteed28
. Smear
campaigns against judges continue to be reported29
.
21
Information received from the Kúria in the context of the country visit. According to the applicable
legal rules as interpreted by the Kúria, lower-level courts may depart from Kúria decisions considered
incompatible with EU law but must state the reasons for such departure.
22
CJEU judgment, Global Ink Trade. The Court of Justice held that the principle of the primacy of EU
law does not preclude national legislation that merely requires lower national courts to state reasons
for any departure from the rulings of higher courts (para 30).
23
Act XLIX of 2025.
24
Service courts (‘szolgálati bíróság’), composed of members elected by the National Judicial Council
from among judges, hear cases related to the assessment, fitness for office and disciplinary liability of
judges.
25
Service courts (2025). See also Verfassungsblog (2025).
26
The International Association of Judges, the European Association of Judges, the Association of
European Administrative Judges, the Association of Administrative Judges (Austria), the Association
of Polish Administrative Judges and the Judges for Judges Association expressed their solidarity. The
demonstration was organised on 22 February 2025. The ENCJ Executive Board welcomed and
supported the fact that the National Judicial Council, the Hungarian Associations of Judges, and
individual judges decided to speak out about the need for judicial independence and the threats faced
by the Hungarian judiciary (ENCJ (2025)). See also Kúria (2025b) and HVG.hu (2025).
27
Judgment 20.M.71.080/2024/13, confirmed by the Budapest Regional Appeal Court on 17 June 2025.
See also Hungarian Helsinki Committee (2025d). According to the Government, the judge concerned
retained his title and remuneration as presiding judge, continued to serve on the panel – including on
the uniformity complaint panel where only presiding judges may sit – and could also preside over
panels in specific cases.
28
CM/Del/Dec(2025)1521/H46-15.
29
Amnesty International Hungary et al (2025), p. 20; Hungarian Helsinki Committee (2025), p. 16. See
Magyar Nemzet (2025), Reuters (2025), Szabad Európa (2025). European standards require that if
commenting on judges’ decisions, the executive and legislative powers avoid criticism that would
8
The Fourteenth Amendment to the Fundamental Law, adopted in December 2024,
removes the requirement that the Prosecutor General be selected from among
prosecutors. Following the entry into force of this constitutional amendment and related
legislative changes, 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 will be required to be elected as the Prosecutor General.
The Fifteenth Amendment to the Fundamental Law also fixes the retirement age of
prosecutors at 70 as of 1 January 202630
. As regards the appointment of the Prosecutor
General, the Venice Commission considered that stricter criteria, coupled with adequate
safeguards in the appointment process, could contribute to the de-politicisation of the
position, and recommended to this end further amending the eligibility criteria for the
position of Prosecutor General and considering the introduction of guarantees in the
Prosecutor General’s appointment process, such as the establishment of a Prosecutorial
Council31
. On 11 June 2025, the National Assembly elected a candidate from within the
prosecution service to serve as new Prosecutor General, for a period of nine years.
Hungary has 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 successor. The hierarchical structure of
the prosecution remains intact. This, together with the lack of internal checks and
balances, means that the risk continues that senior prosecutors can influence the work of
subordinate prosecutors, including in individual cases32
. The Ministry of Justice can still
access prosecutorial decisions relating to criminal procedures; according to stakeholders,
this allows to exert political influence and pressure on the prosecution service in
individual cases33
.
Quality
Significant progress has been made with the increase in salaries in the justice
system, which is being done in three steps until 202734. Judicial salaries are calculated
by applying various multiplying factors determined by law to the salary base35
. The
salary base is determined by the National Assembly in the law on the annual central
budget. The four-party agreement signed on 22 November 2024 envisages salary
increases for judges and judicial staffs in three steps, which, as regards judges, would
undermine the independence of or public confidence in the judiciary (Council of Europe (2010), para.
18).
30
See Sections 26/A to 26/C of the Legal Status of Prosecutors Act, introduced by Section 75 of Act
XLIX of 2025. The office of Prosecutor General is excluded from the application of this age limit. A
prosecutor who has reached the general retirement age may ask leave to remain in service until the age
of 70. Contrary to the regime applicable to judges, the Prosecutor General has discretion to grant or
deny such request.
31
Venice Commission (2025), paras. 29, 43-45.
32
2024 Rule of Law Report, Hungary, p. 9.
33
Amnesty International Hungary et al (2025), p. 19. See also, 2024 Rule of Law Report, Hungary, pp.
9-10.
34
The 2024 Rule of Law Report recommended that Hungary ‘[t]ake structural measures to increase the
remuneration of judges, prosecutors, and judicial and prosecutorial staff, taking into account European
standards on remuneration for the justice system’.
35
EU law requires in particular that the determination of the remuneration of judges by the legislature
and the executive do not involve the exercise of an arbitrary power and is based on detailed rules
which are objective, foreseeable, stable and transparent, and ensure that judges receive a level of
remuneration commensurate with the importance of the functions they carry out, having regard to the
economic, social and financial situation of the Member State concerned and the average salary in that
Member State (CJEU judgment Sąd Rejonowy w Białymstoku).
9
lead to the average salary for these categories being increased by 48% by 2027. In
December 2024, the National Assembly adopted the 2025 annual central budget raising
the salary base for judges by 15%. The 2026 annual central budget, adopted in June
2025, raised the salary base for judges by further 10%. However, the measures do not
introduce structural solutions, such as an automatic indexation of the salary base for
judges, as is the case for salaries of a number of key public officials36
. Since January
2022, when the salary base was last adjusted, inflation has had an accumulated effect of
40%, and in February 2024 the National Judicial Council and the President of the
National Office for the Judiciary had proposed a 35% increase. Some structural changes
raised more substantially the salaries for judicial and prosecutorial staff at all instances
and – based on a special agreement between the Minister of Justice and the Kúria
President – for judges and court managers of the Kúria37
. Their salaries are ultimately
also calculated based on the salary base for judges annually determined by Parliament.
Therefore, there has been significant progress with the increase in salaries in the justice
system.
Shortcomings exist in the legal aid scheme. The eligibility threshold for legal aid in
civil procedure is high, meaning that a person with an income well below the poverty
threshold may not be eligible for legal aid38
. At the same time, under the current legal
framework, the status of ‘certified victim’ provides a more favourable treatment for the
purposes of access to legal aid under the condition of social vulnerability. Even though
the fees for defence lawyers under the legal aid scheme were raised as of 2024, they are
still regarded as critically low, possibly impacting access to justice39
. As of 28 January
2025, at first instance, the court fee payable in small-value civil and commercial cases
decreased, whilst in higher-value cases it increased, and the statutory fee cap has been
removed. Hungary performs well as regards specific arrangements for child-friendly
justice/proceedings (both civil and criminal/juvenile justice proceedings)40
. Also, as
reported last year, access to justice could be improved through specific arrangements to
persons at risk of discrimination and older persons.
Digitalisation of the justice system continues to be overall high. The courts have
several digital tools at their disposal, including an electronic case management system,
distance communication technology and secure electronic communication. Hungary is
36
The salaries of several categories of key public officials – including members of Parliament, the
President of the Republic, the Prime Minister and the top management of the Hungarian National
Bank, the State Audit Office, the Competition Authority, the Public Procurement Authority, the
National Atomic Energy Authority, the Hungarian Energy and Public Utility Regulatory Authority, the
National Media and Infocommunications Authority, the Supervisory Authority for Regulatory Affairs,
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.
37
The remuneration for judges and court managers of the Kúria, as well as for prosecutors working at the
Prosecutor General’s Office, is now fixed to the remuneration of the Kúria President. Also, the
multipliers applicable to the calculation of the salaries of trainee judges and prosecutors, junior judges
(‘bírósági titkár’), deputy prosecutors (‘alügyész’) and staff of forensic institutions have been
increased by 0.15. Finally, the salaries of other judicial and prosecutorial staff are now calculated
using a multiplier increased by 0.15.
38
See Figure 23, 2025 EU Justice Scoreboard.
39
Amnesty International Hungary et al (2025), p. 22; CCBE (2025), p. 102. See Figure 23, 2025 EU
Justice Scoreboard. The fee amounts to EUR 17 (HUF 7 000) per hour; in addition, the legal aid
lawyer is entitled to (i) the reimbursement of expenses, determined on the basis of an itemised
statement or in the form of a 25% lump sum and (ii) a ‘preparation fee’ (see Section 4(2) of Decree
32/2017 (XII. 27) of the Minister of Justice).
40
Figure 29, 2025 EU Justice Scoreboard.
10
among the best performing EU Member States as regards the availability of digital
solutions to conduct and follow court proceedings in criminal cases41
. Judgments are not
yet assigned a European Case Law Identifier, and they are not yet modelled according to
a standard which would enable their machine readability42
. A legislative amendment
introduced as of 1 January 2026 the online streaming of court hearings for pre-registered
members of the audience in most civil and criminal cases43
.
Efficiency
The efficiency of the judiciary continues to be high overall. Hungary performed best
among Member States as regards the estimated time needed to resolve litigious civil and
commercial cases at all court instances in 202344
. The number of pending civil,
commercial and administrative and other cases in 2023 was the fourth lowest in the EU45
.
There is still no adequate compensation scheme for cases involving protracted
criminal and non-contentious civil proceedings, while such a scheme has been
introduced for contentious civil and administrative proceedings. In the context of the
enhanced supervision of the implementation of the Gazsó judgment of the European
Court of Human Rights, on 6 March 2025, the Committee of Ministers of the Council of
Europe reiterated its ‘profound 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, such as enforcement
proceedings46
. On 11 June 2025, the National Assembly adopted a new law47
amending
the procedural rules applicable to contentious civil and – as of 1 July 2026 –
administrative proceedings, 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 case48
.
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 2024 Corruption Perceptions
Index by Transparency International, Hungary scores 41/10049
and ranks 27th
in the EU
and 82nd
globally. This perception has been relatively stable over the past five years50
.
The 2025 Special Eurobarometer on Corruption shows that 88% of respondents consider
corruption widespread in their country (EU average 69%) and 32% of respondents feel
41
Figure 46, 2025 EU Justice Scoreboard.
42
Figure 48, 2025 EU Justice Scoreboard.
43
Sections 147 and 196 of Act XLIX of 2025 inserting Sections 232/A to 232/D in the Civil Procedure
Code and Sections 438/A to 438/G in the Criminal Procedure Code, respectively.
44
Figure 6, 2025 EU Justice Scoreboard.
45
Figure 12, 2025 EU Justice Scoreboard.
46
CM/Del/Dec(2025)1521/H46-17.
47
Sections 142 to 144 and 170 to 171 of Act XLIX of 2025 amending the Civil Procedure Code and the
Code of Administrative Court Procedure, respectively. The daily lump sum equals 1.5% of the
monthly minimum wage (currently EUR 11 or HUF 4 362 per day).
48
The National Judicial Council points to the risk of overlaps between the new compensation scheme
and the already existing one applicable to civil proceedings, drawing attention to the impact it may
have on court resources. National Judicial Council (2025a), National Judicial Council (2025b), pp. 9-
12.
49
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).
50
In 2020, the score was 44, while, in 2024, the score is 41. 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.
11
personally affected by corruption in their daily lives (EU average 30%). As regards
businesses, 83% of companies consider that corruption is widespread (EU average 63%)
and 50% consider that corruption is a problem when doing business (EU average 35%).
Furthermore, 34% of respondents find that there are enough successful prosecutions to
deter people from corrupt practices (EU average 36%), while 19% of companies believe
that people and businesses caught for bribing a senior official are appropriately punished
(EU average 33%)51
.
While implementation of some remedial measures in response to the EU
conditionality procedure is ongoing, important shortcomings remain. To protect the
EU budget against corruption and systemic rule of law issues, in 2022 the Council
temporarily partially suspended funds under several EU programmes and prohibited
entering into new legal commitments with public interest trusts, until the breaches of the
principle of the rule of law and/or their effects or risks for the Union budget or the
Union’s financial interests were remedied52
. On 2 December 2024, Hungary formally
notified legislative amendments regarding certain public interest trusts and entities
maintained by them and requested the Commission to propose to the Council to adapt or
lift the measure on public interest trusts adopted in 202253
. The Commission, having
assessed the legislative amendments, considered that they do not adequately address the
outstanding concerns on conflicts of interest in the boards of public interest trusts and
therefore the measures related to public interest trusts should stay in place54
.
Furthermore, no disbursement of funds under the Recovery and Resilience Plan can be
made to Hungary until all the ‘super milestones’, including those related to the
conditionality procedure, have been satisfactorily fulfilled.
The implementation of the 2024-2025 National Anti-Corruption Strategy and
related Action Plan is ongoing, while important actions remain pending55. The
implementation of the Strategy and Action Plan, applicable as of 15 February 2024, is
overseen by a monitoring committee and progress is tracked regularly56
. Certain
measures have been taken, such as codes of conduct for low or mid-level officials, but
important actions remain pending57
. These include measures on asset declarations, Codes
of ethics for persons in top executive functions and members of Parliament, political
party financing and the review of the motion for revision procedure58
. A final
51
Data from Special Eurobarometer 561 (2025) and Flash Eurobarometer 557 (2025).
52
Council Implementing Decision (EU) 2022/2506 of 15 December 2022.
53
The written notification did not concern the partial suspension of funds under three EU programmes.
54
Commission Decision C(2024) 9140 final of 16 December 2024. Hungary has challenged this
Decision before the General Court; the case is pending (T-138/25).
55
Government Decision 1025/2024. A separate Anti-Fraud and Anti-Corruption Strategy specifically for
the protection of EU funds entered into force in 2022 and was revised in August 2024. See also the
commitments under RRP milestones 178, 179, 220, 221. OECD has recommended enhancing
coherence between the two anti-corruption strategies, OECD (2024b).
56
The Monitoring Support Matrix is available on the Corruption Prevention website of the Hungarian
Government and provides general information on actions taken, updated every three months.
Hungarian Government (2025), written input, p.15.
57
At least 60% of actions supposed to be implemented by 31 December 2024 have not been
implemented within the indicated timeline. As noted also by the OECD and the Council of Europe, a
comprehensive and strategic policy approach to effectively tackling corruption, including high-level
corruption, remains missing from the strategy. Most integrity and corruption prevention measures
target low and mid-level officials and the integrity framework applicable to persons with top executive
functions remains weak.
58
The possibility of ‘motion for revision’, which allows for the review of the decision by the prosecution
service not to prosecute a case or the decision of the investigative authority not to investigate, was
12
implementation report is planned for 202659
. Concerns previously raised by the OECD
and the Council of Europe regarding the lack of a comprehensive and strategic policy
approach to effectively tackling corruption remain in essence valid60
. The government
informed that the evaluation of Hungary’s policy approach to effectively tackling
corruption is ongoing.
The Integrity Authority continues to report obstacles to fulfilling its oversight tasks
effectively, and the practical impact of the proposals made by the Anti-Corruption
Task Force has so far been limited. The Integrity Authority considers that it has
adequate capacity and the necessary level of independence to carry out its work.
Obstacles to the work of the Integrity Authority remain, particularly where it needs to
rely on cooperation with other public bodies61
. Whereas a government decree is expected
to give the Integrity Authority a right of direct access to a number of state databases62
,
and the Government indicated that the current legal framework provides all necessary
access rights, the Integrity Authority again reported obstacles related to access63
. The
Integrity Authority referred nine cases to the prosecution service in 202464
. As part of a
criminal investigation against the President of the Integrity Authority, the police and
prosecution service carried out an extensive raid of the Integrity Authority65
. The
Government agreed or partially agreed with half of the recommendations made by the
Integrity Authority in its second analytical integrity report, rejected about a third of them
and is currently assessing the remaining recommendations66
. In general, however, the
concrete follow-up given to accepted recommendations remains unclear67
. In May 2025,
the non-governmental members of Anti-Corruption Task Force (ACTF) rejected its draft
annual report68
. The ACTF launched an evaluation process to avoid similar situations in
the future. More broadly, non-governmental members of the Task Force remain
introduced in the Criminal Procedure Code by Act XLIV of 2022 to address the concerns raised in the
past as regards the accountability of the prosecution service.
59
See RRP milestone 179.
60
2024 Rule of Law Report, Hungary, p. 14.
61
Country visit Hungary, Integrity Authority. To enhance cooperation with other public bodies, the
Integrity Authority proposed to amend and mirror also in sectoral laws the powers it has under the Act
XXVII of 2022 establishing the Integrity Authority.
62
Country visit Hungary, Government. Government Decree 322/2024 of 6 November 2024.
63
The Authority reported not having access to banking, tax and insurance records which is key for
investigations. This includes the central register on beneficial ownership managed by the Tax and
Customs Administration, Obstacles related to access to data, are also reported in the Integrity
Authority’s 2024 annual report to the Hungarian Parliament. See Integrity Authority (2025).
64
Country visit Hungary, Integrity Authority. OLAF and the EPPO were also notified.
65
Country visit Hungary, Integrity Authority. The President of the State Audit Office has the power by
law to initiate administrative court proceedings to dismiss the President of the Integrity Authority.
Stakeholders consider that this is a disproportionate response considering the alleged irregularities, and
that it risks undermining the independent and effective functioning of the Integrity Authority. Amnesty
International Hungary et al (2024), p. 53.
66
Integrity Authority (2025). The Integrity Authority addressed 74 recommendations to the Government
on the audit system for EU funds, the effectiveness of public procurement rules, the analysis of public
procurement data and the asset declaration system. The Government’s position on the findings
presented in the Integrity Authority’s 2023 Annual Analytical Integrity Report is available on its
webpage. The Government is not required to agree with all of the recommendations, but it must reply
to the report and explain how it will address the findings.
67
The replies of the Government lack clear implementation proposals and timeline. Integrity Authority
(2023a).
68
In particular, they considered that it did not correctly reflect the gravity of the corruption situation in
Hungary and that their suggestions to the report were dismissed without substantive review. Non-
governmental members will publish their own shadow report. Átlátszó (2025). Anti-Corruption Task
Force Meeting (2025).
13
concerned as regards its impact, capacities, powers and the Government’s limited uptake
of proposals69
. Two of the organisations that are members of the ACTF have been subject
to an investigation by the Sovereignty Protection Office70
.
The number of submitted motions for revision of prosecutorial decisions doubled in
2024 and nearly a third resulted in the continuation of investigations. Since January
2023, it is possible for a judge to review prosecutorial authorities’ decisions not to
investigate corruption suspicions or to terminate ongoing corruption investigations
without indictment71
. In 2024, 80 motions for such a revision were submitted to the Buda
Central District Court (compared to 38 in 2023)72
. Whereas nearly a third of all motions
resulted in the continuation of investigations73
, a majority of the motions submitted by
the Integrity Authority have resulted in a resumption of investigations74
. Motions for
revision have proven a useful tool for the Integrity Authority, however it considers that
its powers remain limited as regards access to criminal proceedings and the ability to
present evidence in that context75
. Shortcomings of the new procedure concern the
temporal scope of the new measure and the lack of binding authority for court decisions
quashing prosecutorial decisions76
. The review by the Ministry of Justice of the
functioning and effectiveness of the provisions on judicial review is ongoing with a view
to proposing amendments77
. According to stakeholders, restricted access to case files and
stringent procedural deadlines negate the possibility to use the procedure for private
prosecution78
.
Integrity tests and lifestyle checks remain key tools to detect and deter corruption in
the administration, although their effectiveness in detecting high-level corruption is
limited. According to the prosecution, detection remains the main challenge in the
investigation and prosecution of corruption offences79
. Information and evidence of
corruption crimes are primarily obtained in ongoing criminal investigations and
prosecutions. Reports transmitted to prosecution by the National Protective Service,
which is tasked with carrying out integrity tests and lifestyle monitoring for staff
subordinated to the Ministry of Interior and other public administrative bodies, generally
69
Country visit Hungary, CSOs. See also K-Monitor and Transparency International Hungary (2024).
70
The ACTF reportedly operates in an environment of distrust between the government and CSOs. See
Sovereignty Protection Office (2024). The Office states that foreign-funded political pressure groups
exploited the Anti-Corruption Task Force to pressurise Hungary. See also Átlátszó (2024).
71
2024 Rule of Law Report, Hungary, p. 16.
72
Amnesty International Hungary et al (2025), p. 51, referring to a response by the Buda Central District
Court (2024.El.IV.H.17/4).
73
As reported by the Government, between 1 January 2023 and 31 December 2024, of the 185 motions
submitted in separate proceedings, 54 were successful. In 2023, the court granted the motion for
judicial review in only five cases, while in 2024 it was granted in four cases. Most recently, after an
initial refusal by the police, a logistics deal between the state-owned Magyar Posta and the Waberer’s
Group will be investigated following a successful motion by the NGO K-Monitor. This is the first
CSO to successfully use the motion for revision. See K-monitor (2025).
74
Integrity Authority (2025a).
75
In 2024 the Integrity Authority submitted a motion for revision in 12 cases. The prosecution service
and the court admitted the motion for revision in every case.
76
Council Implementing Decision (EU) 2022/2506 of 15 December 2022, recital 46.
77
Action 3.9 of the Action Plan to the National Anti-Corruption Strategy, with a deadline of 15 May
2024.
78
Amnesty International Hungary et al (2024). See also K-Monitor (2023).
79
Country visit Hungary, prosecution service.
14
concern more petty crimes of public officials80
. There is no publicly available data on the
reliability tests or national security vettings conducted by the Constitution Protection
Office, which is responsible for carrying out checks as regards high-ranking officials,
given the confidentiality of its activities81
. However, the prosecution service indicates
receiving few reports related to suspicions of corruption from the Constitition Protection
Office82
. Other tools that could be more effective in detecting a wider variety of
corruption cases, such as asset declarations, whistleblower reports and data from various
registers, such as the central register for beneficial ownership information managed by
the Tax and Customs Administration, play a relatively minor role in corruption
investigations83
.
The number of convictions for corruption crimes has decreased and there has been
no progress to establish a robust track record on high-level corruption84. Whereas
the prosecution service reports that sufficient human and financial resources, with an
adequate level of specialisation are allocated to corruption cases, it also highlights the
high rate of vacancies among junior prosecutors and the need for further specialisation85
.
The new IT system for the handling of case files by the prosecution service is planned to
be operational by the end of 202586
. The reported indictment rate for corruption crimes
continues to be high87
. In 2024, 264 persons were convicted at final instance for
corruption crimes, which is a decrease compared to the previous year88
. Since 2023,
criminal proceedings have been ongoing in a corruption and money laundering case
against a number of defendants involving a former high-level official89
. While four
defendants have been sentenced to prison in a corruption case involving primarily EU
80
In 2024, integrity checks were conducted on 835 individuals, resulting in nine persons reported for
breach of duty for undue advantage.The 17 271 lifestyle checks undertaken resulted in findings that
149 people did not meet the ethical standards.
81
Since the Constitution Protection Office is a national security service, the detection of potential
corruption by this Office falls under national security rules and remains undisclosed. The legality and
compliance with the law of the investigations carried out, including the question of a possible criminal
prosecution, is overseen by the designated prosecution service. No data on detected corruption cases is
available. See also 2023 Rule of Law Report, Hungary, p. 14.
82
Country visit Hungary, prosecution service.
83
Country visit Hungary, prosecution service.
84
The 2024 Rule of Law Report recommended to Hungary to ‘[e]stablish a robust track record of
investigations, prosecutions, and final judgments for high-level corruption cases’.
85
Country visit Hungary, prosecution service.
86
Financial data relevant for investigations is spread over numerous separate state registers. The new IT
system for the handling of sensitive documents was originally planned to be supported under the RRP
and fully functional and operational by Q2 2024, see 2023 Rule of Law Report, Hungary, p. 16, and
RRP milestone 180. In addition, a new case management IT system facilitating administrative work,
and the exchange of non-sensitive information is also planned under the RRP to be fully functional and
operational by the end of 2025, see RRP milestone 181.
87
A total of 164 investigations for corruption crimes were completed, with 120 procedures resulting with
an indictment. Hungarian Government (2025), written input, Annex, pp. 1-2.
88
Hungarian Government (2025), written input, p. 24. In 2023, there were 364 final convictions. In
November 2024, four defendants out of 54 were sentenced to prison at first instance in a corruption
case involving primarily EU funds (Prosecution service (2024)). In another case, the court-imposed
prison sentences on three people, and another defendant was sentenced to a suspended prison sentence
in a bribery case related to land tenders (Budapest Regional Court (2025)).
89
Allegations of evidence-tampering by the prosecution service upon Government instructions and the
obstruction of justice by the Government in this high-level corruption case involving a former state
secretary of the Ministry of Justice and the chief bailiff prompted the prosecution service to initiate
investigations for failure to report bribery. See Reuters (2024) and Telex (2024).
15
funds90
, convictions in high-level corruption cases continue to be rare91
. Generally, in
complex high-level corruption cases, court proceedings tend to be long92
. The risk of
political influence and undue interference with individual cases in the prosecution service
and the police, the absence of investigations of corruption allegations concerning high-
level officials and their immediate circle, as well as clientelism, favouritism and
nepotism in high-level public administration remain areas of concern93
. The lack of
enforcement against foreign bribery is a persistent concern, with no new investigations or
convictions and long-standing international recommendations remaining unaddressed94
.
Overall, no progress was made on establishing a robust track record to fight high-level
corruption, as recommended in the previous years.
There has been no progress yet on the recommendation regarding lobbying and
post-employment regulation, although there are plans to legislate in this area by
November 202595. The Government plans to adopt legislation on lobbying, including
rules on revolving doors, by 30 November 2025. Its exact elements are yet to be
decided96
. Pending its adoption, no steps have been taken to establish rules on contacts
between members of Parliament and lobbyists97
. Preparations are still ongoing for a non-
binding code of conduct for members of Parliament, including guidelines on lobbying
and post-employment98
. No steps have been taken to prepare the code of conduct for
persons in top executive functions, planned by 30 April 202499
. Hungary’s legislative
framework on lobbying and post-employment rules remains incomplete, with no
systematic follow-up ensured in case of non-compliance100
. Since no steps have been
taken for a comprehensive reform on lobbying and post-employment rules, there has
been no progress yet on the recommendation.
There has been no progress to improve the asset declaration system, including to
ensure effective oversight101
. Actions to strengthen the asset declaration system foreseen
in the 2024-2025 National Anti-Corruption Strategy are pending102
. The power to verify
90
The case involves 54 defendants and concerns a vast corruption network manipulating public tenders.
Officials from multiple ministries were implicated, including the Finance Ministry and the Prime
Minister’s Office. Prosecutor’s Office (2024).
91
Country visit, Transparency International Hungary and K-monitor. See also Council of Europe (2023)
and Amnesty International Hungary et al (2025), p. 50.
92
Transparency International Hungary and K-Monitor (2024). In one case involving a former Member of
Parliament indicted in 2019, the court case has restarted from the first hearing for the fourth time in
2024. Amnesty International Hungary et al (2025), p. 51.
93
See 2024 Rule of Law report, Hungary, p. 19. 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.
94
OECD (2023). See also OECD (2024).
95
The 2024 Rule of Law Report recommended to Hungary to ‘[a]dopt comprehensive reforms on
lobbying and revolving doors [...] providing for effective oversight and enforcement’.
96
Country visit, Hungarian Government.
97
See GRECO (2022), paras. 9-10.
98
Country visit Hungary, National Assembly.
99
Action 2.1 of the Action Plan. The monitoring table indicates that the Ministry of Justice held
consultations during which it has been established that Government Decree 477/2024 of 31 December
2024 on the procedure to be followed in relation to protocol gifts is sufficient for the fulfilment of
Action 2.1.
100
2023 Rule of Law Report, Hungary, pp. 18-20. See also GRECO (2023a), p. 56.
101
The 2024 Rule of Law Report recommended to Hungary to ‘further improve the system of asset
declarations, providing for effective oversight and enforcement’.
102
The Action Plan mandates the Ministry of Justice to create the possibility to submit asset declarations
electronically, to consider extending the personal scope and to introduce an effective, proportionate,
and dissuasive administrative and criminal sanctions’ regime by April 2024.
16
asset declarations has not yet been effectively transferred to the Integrity Authority103
.
The Government did not provide an official reply to the Integrity Authority’s special
report on the asset declaration system104
. Publicity requirements do not apply to most
persons entrusted with senior political functions and information about follow-up is not
public either. Stakeholders highlight the narrow scope of the declarations, which provide
for opportunities to potentially hide assets105
. A recent amendment to the anti-money
laundering legislation, aiming to increase transparency of ultimate beneficial owners of
previously established private equity funds, will not enter into force until July 2026106
.
Concerns persist regarding the effective and regular monitoring and verification asset
declarations of members of Parliament107
. In 2024, no procedure against a member of
Parliament was initiated, and six members of Parliament rectified their asset declarations
after errors were revealed by the public108
. A recent amendment introduced minor
changes to the procedure for declaring assets, without modifying the substantive rules109
.
In 2025, the National Assembly adopted new rules for Hungarian members of the
European Parliament which foresee that non-compliance with asset declaration
obligations could lead to the termination of their mandate by the Electoral
Commission110
. Against this background, no progress has therefore been made towards
implementing the recommendation made in the 2024 Rule of Law Report111
.
Guides and awareness-raising measures on conflicts of interests are implemented in
certain sectors, but legislative fragmentation and systemic weaknesses remain.
Based on the Action Plan of the National Anti-Corruption Strategy 2024-2025, the
Government plans to regulate conflicts of interest in the upcoming codes of conduct for
103
2024 Rule of Law Report, Hungary, p. 22.
104
Integrity Authority (2023b). In the context of the case report on asset declarations, the Authority has
submitted to the Ministry of Justice concrete proposals for amendments to the law. The
recommendations include the creation of a dedicated electronic platform for submission of asset
declarations, introduction of an adequate sanctions regime, streamlining the verification process and
automatic comparison of asset declarations with external databases. See the Government’s position on
the findings presented in the Integrity Authority’s 2023 Annual Analytical Integrity Report.
105
Country visit Hungary, CSOs and the Integrity Authority. 2024 Rule of Law Report, Hungary, p. 22.
Private equity funds, fiduciary asset management arrangements and non-taxable revenues are not
included in the declarations, which means they are not subject to general oversight and access by the
Integrity Authority. Moreover, the registration of beneficial ownership information for private equity
funds is not required by law. An infringement procedure (INFR(2023)2098) against Hungary was
launched in July 2024 for non-compliance with the 5th Anti-Money Laundering Directive.
106
The Commission sent another letter of formal notice to Hungary in this regard on 7 May 2025.
107
There is no obligation to regularly monitor, check the correctness or the completeness of the
declarations. Verification of asset declarations is only triggered by notification of suspicions. Any
possible follow-up is at the discretion of the public official’s employer or, in case of members of
Parliament and other high-ranking officials, of the Immunity Committee. GRECO also found that the
verification of declarations was clearly insufficient (GRECO (2023), p. 4, para. 3). Members of
Parliament continued largely to submit their asset declarations on paper. In 2025, 63 used electronic
submission, while 134 completed the declaration on paper. Country visit Hungary, National Assembly.
108
Country visit Hungary, National Assembly.
109
Act LXXV of 2024 applies to declarations of assets and conflict of interest and introduces time limits
for all procedural acts. The substantive examination remains with the Committee on Immunity.
110
Act XX of 2025. Asset declarations to be submitted by MEPs are identical in format and detail to those
required of national members of Parliament.
111
Important weaknesses, risks and shortcomings remain as regards elements of the asset declaration
system which create possible loopholes undermining the effectiveness of the measure were also
identified by the Communication on the application of Regulation (EU, Euratom) 2020/2092 (15
January 2024). Council Implementing Decision (EU) 2022/2506 of 15 December 2022, recital 41.
17
persons in top executive functions and members of Parliament112
. A new code of ethics
and conduct for parliamentary civil servants was adopted in October 2024 but is not
publicly available113
. Changes were made to the ethics framework for local and law
enforement authorities, covering also conflicts of interest114
. In 2024, the National
Assembly terminated the mandate of one of its members due to a conflict of interest115
.
However, there were no developments to address the systemic weaknesses reported in
2023 and 2024. These include the fragmentation of the regulatory framework on conflict
of interests, including as regards public interest trusts, the lack of a general definition of
conflicts of interest and the absence of a central supervisory body116
. A recent audit of
the Hungarian National Bank, its own trusts and a related public interest trust
maintaining a university led the State Audit Office to file a criminal report against the
public interest trust concerned due to conflicts of interest117
.
The framework for the protection of whistleblowers is in place, however
whistleblowing plays a limited role in the detection of corruption crimes. The Office
of the Commissioner for Fundamental Rights provides training to civil servants and the
preparation of an information campaign on the functioning of whistleblowing platforms
and whistleblower protection regimes is still ongoing118
. According to stakeholders and
as illustrated by survey data, whistleblowing is still not a sufficiently widespread
practice119
. Reports can be submitted on the whistleblowing channel for reports on EU
fraud, to the Integrity Authority, as well as to the Public Procurement Authority, the
National Development Centre and the Competition Authority120
. However, the
prosecution service reports that whistleblower reports do not play a role in the detection
of corruption crimes121
. Civil society organisations continue to raise concerns regarding
112
Hungarian Government (2025), written input, p. 11. This will be part of the upcoming codes of
conduct.
113
Country visit, National Assembly. It contains guidance for the proper management of conflicts of
interest.
114
Hungarian Government (2025), written input, pp. 16-17. This includes a draft methodological guide
for local authorities and revised code of ethics and rules of ethical procedure for law enforcement
officials.
115
Country visit Hungary, National Assembly.
116
2023 Rule of Law Report, Hungary, pp. 21-23.
117
State Audit Office (2025). The State Audit Office found that nearly EUR 1.3 billion were affected by
opaque and overpriced real estate and art acquisitions, complex and risky investment structures, and
significant financial benefits directed towards companies linked to the son of the National Bank’s then
governor. It also found that the decision of the public interest trust to invest in bonds issued by the
fund manager of the National Bank’s own trusts violated the conflict of interest provision of the deed
of foundation.
118
Information concerning guidance on the functioning of the protected electronic submission system, the
complaint process, whistleblower protections, and the availability of state support measures is
available on the website of the Office. Hungarian Government, written input, p. 18. See Actions 4.3,
4.4 and 4.5 of the Action Plan to the National Anti-Corruption Strategy.
119
See also the Special Eurobarometer 584 on Corruption (2024) on the level of corruption reporting. See
also Hungarian Helsinki Committee (2025c).
120
The anti-lop.hu whistleblowing channel for reports on EU fraud received only 19 reports between July
2024 and March 2025, with investigations ongoing in 11 cases. The Integrity Authority received 172
reports in 2024, of which 90 fell in its remit. In 48 cases the information did not give rise to the
opening of an investigation. Country visit Hungary, Integrity Authority.
121
Country visit Hungary, prosecution service.
18
differences in protection levels for whistleblowers who report breaches of national rules
which do not fall within the national legislation transposing Directive 2019/1937122
.
Key shortcomings with regard to the transparency of the financing of political
parties and electoral campaigns remain. No steps were taken in the reporting period to
address long-standing recommendations to strengthen the transparency of political party
and campaign financing123
. While some measures have previously been taken to ensure
that political party financial registries are transparent and up-to-date, deficiencies remain
regarding the transparency and supervision of the accounts of foundations or third-party
entities directly or indirectly related to or under the control of political parties124
.
Furthermore, the applicable legislation does not require the disclosure of campaign
donations, nor does it prohibit the use of state resources for campaigning during a pre-
election period125
. The possibility for circumvention of campaign spending limits via the
use of third-parties and intermediaries, as reported during the 2022 elections126
, also
remains unaddressed. In February 2024, the State Audit Office had imposed fines on six
opposition political parties for alleged illegal foreign funding during the 2022 election
campaign127
. On 17 June 2025, in expedited procedure, the National Assembly passed a
law that removes the cap on political campaign expenses128
.
Competition in public procurement has been improved, and different levels of
control remain for national and EU-funds related procurements. Corruption risk
sectors remain largely the same compared to previous years, with high risks in public
procurement, construction, health, IT, and communication services129
. Corruption
prevention carried out by the National Protective Service reportedly continues to play a
major role in reducing corruption pressure on the health sector130
. Businesses’ attitudes
towards corruption in the EU show that 36% of companies in Hungary (EU average
25%) think that corruption has prevented them from winning a public tender or a public
procurement contract in practice in the last three years131
. Only 28% of businesses
perceive the level of independence of the public procurement review body (Public
122
See also 2024 Rule of Law Report, Hungary, p. 24. Hungarian legislation includes specific safeguards
for certain whistleblowing categories. Section 174 of the Criminal Procedure Code and Section 155 of
the Media Act provide legal protections for media informants.
123
See OSCE ODIHR and Venice Commission (2020), para. 194. As reported last year, the National
Anti-corruption Strategy mandates the Government to examine the enforcement of political party
finance rules and the operational practices of political organisations, with an exclusive focus on
preventing foreign influence.
124
See GRECO (2019).
125
See OSCE ODIHR (2022), p. 22. State Audit Office audit findings cannot be challenged before an
administrative court.
126
As regards political advertising on the social media platform Facebook, financed by third parties and
intermediaries, including the social media incubator Megafon Centre training pro-government
influencers and promoting their posts as one of the largest spenders on political ads on Facebook in the
election campaign, see 2023 Rule of Law Report, Hungary, pp. 24-25; on the level of spending, see
Lakmusz (2024); and Telex (2024).
127
See 2024 Rule of Law Report, Hungary, p. 24.
128
Act LXVIII of 2025. The Committee of Ministers of the Council of Europe has recommended to states
to prevent excessive funding needs of political parties, such as establishing limits on expenditure on
electoral campaigns. Council of Europe Committee of Ministers (2003).
129
Hungarian Government (2025), written input, pp. 22-23; Amnesty International et al (2025), pp. 47-
48; Corruption Research Center Budapest (2024).
130
Hungarian Government (2025), written input, p. 19.
131
Flash Eurobarometer 557 on Businesses’ attitudes towards corruption in the EU (2025). This is 11
percentage points above the EU average.
19
Procurement Arbitration Board) as very or fairly good132
. The competition in public
procurement procedures is improving and the Single Market and Competitiveness
Scoreboard on access to public procurement in Hungary reports 32% of single bids for
2023 (EU average 29%) and 23% for 2024133
. While the share of public procurement
procedures with single bids decreased for both EU-financed and national procurements,
the target committed to by Hungary for domestically financed public procurements was
not met in 2023 (29% vs the target of 24%) and 2024 (22.3% vs the target of 15%)134
.
Some studies point to an increase in corruption risks for such procurements where
different levels of control and oversight apply135
. In addition, focussing solely on the
share of single bids can hide the root causes of lack of competition136
. The Government’s
action plan to improve competition in public procurement contains several measures
aiming to foster competition137
. According to stakeholders, the action plan lacks ambition
and does not sufficiently reflect relevant recommendations of the Integrity Authority138
.
Stakeholders report increased corruption risks due to an excessive use of concession
contracts and an report that many framework agreements were concluded with a single
bidder139
. Framework agreements concluded by central purchasing bodies have allowed
certain economic operators to become market leaders or to acquire a dominant position at
the expense of their competitors140
. Concerns remain regarding favouritism in tender
processes and selective awarding to political affiliates, which increase corruption risks141
.
132
Figure 59, 2025 EU Justice Scoreboard.
133
SWD(2025) 217 final. The 2024 data on single bids is provisional and subject to revision.
134
Based on data from Public Procurement Data Space the share of single-bid procedures within
nationally financed public procurement showed a significant decrease of 6.7 percentage points in 2024
compared to the previous year.
135
Corruption Research Center Budapest (2023). On government communications contracts, see Szabad
Európa (2024). Regarding EU-related procurement, see Integrity Authority (2024a) and (2023c), with
recommendations for the Government. Hungary has committed to reduce to 15% the high share of
calls for tenders that result in a single bid under the RRP, while the share of single bids is reportedly
significantly higher for high-value, non-EU fund-related public procurements.
136
These include supporting bids, collusion or a high ratio of invalid tenders. Integrity Authority (2023d).
137
According to the government, these measures are based on the analysis carried out in the framework of
the Public Procurement Performance Measurement Framework, reflect international best practices or
address recommendations of the Integrity Authority and the Anti-Corruption Task Force.
138
Amnesty International Hungary et al (2025). For most of the recommendations of the Integrity
Authority, the government did not see a need to take any action and/or did not commit to any action.
139
Stakeholders report extreme market concentration in sectors such as communications and IT and
excessively long concession contracts, such as the 35-year concessions of waste management and
motorway. The share of framework agreements with a single bidder has been rising steadily since
2019, reaching around 70% in 2023 and 2024 (Integrity Authority (2024c), p. 54)). While Government
Decree 63/2022 of 28 February 2022 increased the effectiveness of some of these provisions
subsequently Government Decree 53/2024 of 4 March 2024 exempted a number of procedures from
their application. According to the Government, the use of concession contracts and framework
agreements is in line with similar practices in other Member States.
140
In April 2024, the Commission opened an infringement procedure against Hungary (INFR(2024)4006)
for awarding the 35-year motorway concession contract in breach of EU rules on concessions.
140
2024 Rule of Law Report, Hungary, p. 4.
141
2024 Rule of Law Report, Hungary, p. 4. On 18 June 2025, the Commission opened an infringement
procedure against Hungary (INFR(2025)2051) for failing to award a high-value exploitation contract
for sand and gravel mining sites in an open and transparent tender procedure.
20
III. MEDIA PLURALISM AND MEDIA FREEDOM
There has been no progress to strengthen the functional independence of the
Hungarian media regulator142. While the Media Act provides for formal independence
of the National Media and Infocommunications Authority (NMHH), government
influence remains significant due to the composition of the decision-making body of the
Authority, the Media Council, which remains composed of members all nominated by
Parliament. The Council has undertaken investigations into private media considered to
be pro-government for potentially racist and anti-immigrant content and into public
service media for airing disguised political advertising during the election period.
Nevertheless, in the light of the unresolved concerns with regard to the authority, the
2025 Media Pluralism Monitor (MPM) once more assesses the independence and
effectiveness of the Media Authority as an area presenting high risk, referring to the
authority’s composition, lack of transparency of its decision-making process and certain
‘politically motivated’ decisions143
. Given that no measures have been adopted or are
planned to strengthen the regulator’s functional independence, there has been no progress
as regards the recommendations made in previous years.
There has been no progress to increase transparency and fairness in the distribution
of state advertising144. The general rules and procedures regulating public procurement
govern these expenditures and no specific rules ensuring transparency and fairness
regulating distribution exist. Public sector communications are carried out under one
framework contract with the National Communications Office (NKOH)145
. The State
remains, by far, the most important player in the media advertising market channeling
significant state resources to pro-government media and increasing its spending146
. State
advertising accounts for over 30% of the total advertising market, while the Central
European Press and Media Foundation (KESMA), a conglomeration of pro-government
media outlets, receives up to 75-80% of its total revenue from state advertising147
. The
2025 MPM points out that ‘it is still the case that the state advertises almost exclusively
in pro-government media outlets and that the majority of advertising revenues for several
media products, typically pro-government, are generated by state advertising’ concluding
that this remains an area presenting medium-high risk148
. Given that no legislative or
other measures have been adopted or are planned by the Government on the fair
distribution of state advertising, there has been no progress as regards the
recommendations made in previous years.
Transparency in the ownership structure of media companies is not regulated by
any specific provisions. Section 41 of the Media Act mandates the NMHH to maintain
registers on media service providers, but these registers do not, however, contain
information on ownership or beneficial ownership of these companies. Direct ownership
information is available via the business register. This leads the 2025 MPM to once more
142
The 2024 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’.
143
Media Pluralism Monitor (2025), p.16.
144
The 2024 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’.
145
On the operation of the National Communications Agency in this field see Corruption Research Center
Budapest (2024).
146
Amnesty International Hungary et al (2025).
147
International Press Institute (2025), p. 21.
148
Media Pluralism Monitor (2025), p. 29.
21
consider this a high-risk area149
. There has been no change to the system of review of
market concentration in the media market150
.
There has been no progress to enhance the independence of public service media151.
Reports acknowledge that both the Media Act and the Public Service Code enshrine the
principle that public service media shall be independent of both government and
economic actors and that financing has steadily increased152
. However, no legislative or
policy changes have been adopted or are planned to address the concerns expressed in
relation to the governance of public service media, in particular in relation to government
influence. Reports suggest that the organisation and funding structure remain unchanged,
maintaining its opacity and complexity153
. As a consequence, the 2025 MPM has
maintained its very high-risk score for this area based on its findings, among others, that
‘Hungarian public service media is financially dependent on the governing majority in
Parliament, is controlled by political interests, and is seen as extremely biased in its
reporting’154
. There has thus been no progress on the recommendations made in previous
years.
While the accelerated treatment of court cases related to access to information
continues, the scope of access to information remains limited especially as regards
public funding. The short procedural deadlines introduced in 2023 have continued to
prompt accelerated litigation in cases of access to information of public interest.
Restrictions to freedom of information introduced in 2023 and 2024 remain in place155
.
The National Assembly has still not implemented a 2020 decision of the Constitutional
Court requiring legislative amendments to establish effective judicial protection in case
of freedom of information requests related to public funds, addressed to the recipients of
such funds156
. The enforcement of court orders granting access to documents remains a
challenge157
. At the same time, public access to anonymised official documents of a file
in administrative proceedings has been removed by a precedent decision of the Kúria158
.
As regards proactive disclosure, in December 2024, an omnibus law broadened the scope
of entities that are required to publish data in the Central Public Data Information
149
Media Pluralism Monitor (2025), p. 19.
150
See 2020, 2021 and 2022 Rule of Law Reports, Hungary. An overview of the media market, including
main players and trends, can be found in the Media Market Reports prepared by the National Media
and Infocommunications Authority.
151
The 2024 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’.
152
International Press Institute (2025), p. 18.
153
See Civil Liberties Union for Europe (2025), p. 445.
154
Media Pluralism Monitor (2025), p. 30.
155
2024 Rule of Law Report, Hungary, pp. 28-29.
156
Decision 7/2020 (V. 13.) AB of the Constitutional Court found that the right to freedom of information
extends to all public data and judicial remedies must exist to fulfil this fundamental right vis-à-vis all
persons handling public data.
157
See Rule of Law Report 2024, Hungary. Also, on 5 December 2024, in the context of the enhanced
supervision of execution of the judgment of the European Court of Human Rights in the Kenedi v
Hungary case, the Committee of Ministers of the Council of Europe called on the Hungarian
authorities to adopt additional targeted general measures to address the recurring reluctance of state
authorities to comply with domestic courts’ orders granting access to documents, and to ensure that
effective and genuinely coercive enforcement tools are available for the implementation of such orders
(CM/Del/Dec(2024)1514/H46-41).
158
Judgment Pfv.IV.20.384/2024/5. The restriction does not affect access to the decision concluding the
administrative procedure.
22
Register159
. While this is a step forward, entities managing significant amounts of public
funding, such as state-owned companies160
, public interest trusts and the Hungarian
National Bank and its trusts are not required to publish data in the Register. In addition,
many public interest trusts fail to comply with the Freedom of Information Act as they do
not operate a website, their founding documents are not publicly available, and they do
not publicly disclose data related to their activities. The Media Pluralism Monitor
considers this to be an area presenting very high risk161
. Hungary has ratified the Council
of Europe Convention on Access to Official Documents162
.
Pressure on journalists and other media professionals has increased, as they
continue to encounter numerous and serious challenges to their work. While
stakeholders point out that physical attacks against journalists are very rare in Hungary,
they draw attention to the prevalence of smear campaigns and derogatory statements
against journalists163
. Some stakeholders report that access to public interest events and
government press conferences continues to be denied on a selective basis and that
inquiries from the press often go unanswered164
. With the investigative activities carried
out by the Sovereignty Protection Office into alleged ‘foreign funding’, pressure on
independent journalists and media outlets has increased165
. The 2025 MPM continues to
consider the safety of journalists to be an area presenting medium risk166
. The Council of
Europe’s Platform to promote the protection of journalism and safety of journalists
registered five new alerts relating to, respectively, an investigative outlet accused on
engaging in foreign influence and espionage by the Sovereignty Protection Office; two
journalists seeking to interview the PM who were obstructed, detained and charged;
alerts relating to the Act on Transparency in the Public Sphere and a report claiming that
intelligence reports had been drawn up on media outlets and CSOs167
. The Mapping
Media Freedom monitoring report has flagged thirty-seven alerts, eight of which concern
derogatory statements and smear campaigns targeting journalists; seven of which relate
159
An online repository where certain public entities upload metadata on their contracts (not the contracts
themselves). As of 1 January 2025, Section 37/C of the Freedom of Information Act – amended by the
Legal Competitiveness Act – refers, instead of public entities having a budgetary status, to public
entities registered by the Hungarian State Treasury, as defined in the Public Finances Act, thereby
extending the scope to public bodies, municipalities, national minority self-governments, municipal
associations, territorial development councils and other entities assimilated by law to public entities
having a budgetary status.
160
E.g. Hungarian National Asset Management Inc., Hungarian Tourism Agency, Bethlen Gábor Fund
Management Inc. These obliged to publish data in accordance with the ‘general disclosure list’ (Annex
1 to the Freedom of Information Act) but non-compliance is not sanctioned. The Fundamental Law
limits the definition of public funds to revenues, expenditures and claims of the State. The Kúria’s
case law (Pfv.IV.20.904/2021/5), confirmed by Decision 3258/2022 (VI. 3.) of the Constitutional
Court, limits transparency by relieving subcontractors from the obligation to give access to
information related to the use of public funds. This is aggravated by the fact that government entities
outsource several tasks (e.g. drafting policy documents, running government communication) to
private companies through intermediaries.
161
Media Pluralism Monitor (2025), pp. 13-14.
162
The Council of Europe Convention on Access to Official Documents (CETS No. 205), also known as
the Tromsø Convention, entered into force on 1 December 2020.
163
See, among others, the numerous alerts registered by the Media Freedom Rapid Response mechanism.
164
See Civil Liberties Union for Europe (2025), p. 449. See also Media Freedom Rapid Response
Mechanism and the Council of Europe Platform on safety of journalists which have received several
alerts of this nature.
165
Amnesty International Hungary et al (2025), p. 68; Civil Liberties Union for Europe (2025), p. 449.
Stakeholders also cite a case where journalists were subjected to polygraph tests by the Constitution
Protection Office in relation to news items that later turned out to be false.
166
Media Pluralism Monitor (2025), pp. 14-15.
167
Council of Europe Platform to promote the protection of journalism and safety of journalists (2025).
23
to refusal of accreditation, information or access to political events and six of which are
linked to the operation of the Sovereignty Protection Office168
.
IV. OTHER INSTITUTIONAL ISSUES RELATED TO CHECKS AND BALANCES
The Government continues to use its emergency powers extensively, undermining
legal certainty and affecting the operation of businesses in the single market. The
Government further extended until 14 November 2025 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’169
. In this way, the Government can
override Acts of Parliament. Several emergency measures adopted in the reporting period
have an impact on the business environment and do not seem to be related to the ‘state of
danger’170
. The Constitutional Court examined various emergency measures in 14 cases
in 2024171
. Stakeholders reported that the extensive and prolonged use of the
Government’s emergency powers has undermined legal certainty172
. The Fifteenth
Amendment to the Fundamental Law changes the constitutional rules on the ‘state of
danger’ as of 1 January 2026. As a result, setting aside any law through a government
decree will require prior parliamentary authorisation. The constitutional rules (introduced
in 2022), according to which the initial length of the ‘state of danger’ is 30 days and an
extension by the Government requires parliamentary authorisation, remain unchanged.
An amendment173
adopted on 14 April 2025 clarifies that the parliamentary authorisation
to extend the ‘state of danger’ or to set aside any law through a government decree
cannot be requested for a period longer than six months.
The law-making process remains a serious source of concern, with certain
important legislative processes not being linked to public consultation requirements.
Almost 90% of the draft laws were adopted at the initiative of the Government, the vast
majority of which (90-92%) were submitted to Parliament after public consultation.
Nevertheless, public consultation requirements do not apply with certain important
legislative drafts introduced directly by individual members of Parliament or
168
European Centre for Press and Media Freedom (2025).
169
Government Decrees 167/2023 of 11 May 2023, 515/2023 of 22 November 2023, 86/2024 of 17 April
2024, 330/2024 of 14 November 2024 and 97/2025 of 12 May 2025 amended Government Decree
424/2022 of 28 October 2022 by extending the ‘state of danger’ until 26 November 2023, 24 May, 19
November 2024, 19 May 2025, respectively. 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 XI of 2023, Act LXXII of 2023, Act VIII of 2024, Act LIV
of 2024 and Act XXVI of 2025. In parallel, Hungary has been under a ‘crisis situation caused by mass
immigration’ since 10 March 2016.
170
E.g. Government Decree 5/2025 of 25 January 2025 amended the rules on exemption from VAT at
source; Government Decree 25/2025 of 27 February 2025 limited the personal scope of public
procurement rules; Government Decree 42/2025 of 11 March 2025 introduced profit-margin caps
limiting commercial mark-up on 30 basic foodstuffs to 10% of the wholesale price. Certain emergency
measures have been incorporated into Acts of Parliament (e.g. excise duty rules, tax rules, social
contribution and other types of tax relief).
171
In constitutional complaint procedures where emergency measures were under constitutional review,
the average handling time in 2024 was 257 days, far below the deadlines established by the Rules of
Procedure. 40% of the petitions aiming at the constitutional review of emergency measures, were
decided on the merits. The Constitutional Court also established violation of the Fundamental Law in
two decisions (Decisions 9/2024 (IV. 30.) AB and 3323/2024 (VII. 29.) AB).
172
Stakeholders also consider that the Constitutional Court cannot ensure the effective and timely review
of emergency measures. Amnesty International Hungary et al (2025), p. 75; Hungarian Helsinki
Committee (2025), p. 32. See also 2024 Rule of Law Report, Hungary, p. 31.
173
Act V of 2025 amending Act XCIII of 2021.
24
parliamentary committees174
. Examples include amendments to the Fundamental Law175
or legislation with impact on fundamental rights and EU law176
. The Government has
continued its practice to include only technical amendments in draft laws and then
introduce new and substantive amendments in the bill at a very late stage in the
legislative process, through the Committee on Legislation, just before the final vote in
Parliament177
. In this way, a regular parliamentary debate and public consultation are
avoided. Also, frequent changes of key laws continue to weaken legal certainty and
negatively affect the business environment. For instance, last year, the National
Assembly and – through emergency measures – the Government, amended 37 times
Hungary’s central budget for 2024.
Less than half of the companies surveyed in Hungary express high levels of
confidence in the effectiveness of investment protection. 46% of companies are very
or fairly confident that investments are protected by law and courts178
. The main reasons
among companies for their lack of confidence are the frequent changes in legislation or
concerns about quality of the law-making process (32%)179
. 37% of companies perceive
the level of independence of the national competition authority (Competition Authority)
as very or fairly good180
. A limited number of judicial mechanisms are in place at the
level of the Kúria to ensure the implementation of administrative court judgments, which
include the possibility to quash administrative decisions for continued non-compliance
with the court’s instructions. However, these mechanisms do not include disciplinary
actions against the responsible officials or the possibility to award direct or consequential
damages or compensation181
.
Foreign companies, including from other EU Member States, operating in strategic
sectors face intensified regulatory pressure from state action. Stakeholders report the
continued existence of visible patterns in legislation that cumulatively and significantly
damage the financial base for certain foreign investors, including from other EU Member
States, leading to de-investment. This is done through tailor-made special taxes (e.g. in
the financial, energy and building materials sectors182
), unpredictable and excessive
174
The number of bills proposed by individual members was 14 out of 121 laws passed in 2023 and 11
out of 92 in 2024.
175
E.g. the Thirteenth Amendment to the Fundamental Law (which concerned several constitutional
provisions, including the movement of military troops and borrowing by the EU) and the Fourteenth
Amendment to the Fundamental Law.
176
E.g. the Protection of National Sovereignty Law.
177
In 2024, the Committee on Legislation proposed 8 overreaching amendments, 7 of which were
adopted by the National Assembly (information received from the National Assembly). An example
where this technique was used was laws affecting the functioning of the justice system, with no prior
consultation or plenary debate.
178
Figure 54, 2025 EU Justice Scoreboard.
179
Figure 55, 2025 EU Justice Scoreboard. 26% of the surveyed investors perceive the quality, efficiency
or independence of justice as a reason for the lack of confidence in investment protection.
180
Figure 60, 2025 EU Justice Scoreboard.
181
Figure 49, 2025 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.
182
In 2021, the Government approved two decrees which established an official price below the market
price for basic construction materials such as sand, gravel and cement. The undertakings that extract
those materials – almost all of which are controlled by companies established in other Member States
– must also pay an additional mining fee set at 90% of the difference between the official price and the
sales price exceeding that official price. In addition, the permits to mine depend on maintaining a
minimum level of extraction set by the Government. Since those government decrees were approved
for a transitional period – originally only for the duration of the COVID-19 outbreak – the National
25
administrative fines, restrictions on companies’ expansion strategies, export
restrictions183
and the nationalisation of typical company assets/logistics184
. In the retail
sector, specific building regulations continue to restrict access to the Hungarian market
and special taxes are combined with measures directly or indirectly imposing product
price restrictions with the effect that foreign companies are de facto discriminated
against185
. On 12 September 2024, the Court of Justice found that measures requiring
fixed prices and sales obligations for certain agricultural products by a government
decree introduced under the ‘state of danger’ imposed significant restrictions which were
not justified or proportionate, and therefore were incompatible with EU law186
. Despite
that ruling, Hungary has not yet amended the legal framework and discriminatory
product price restrictions affecting foreign companies continue to be applied187
. On 3
October 2024, the Commission opened infringement proceedings against Hungary for
failing to bring its retail tax regime in line with the freedom of establishment guaranteed
by EU law considering that the regime disproportionally burdens larger foreign
companies188
.
The possibility for the Government to interfere with the application of merger
control rules continues to create legal uncertainty. The Government can still declare
certain mergers and acquisitions to be of ‘strategic importance for the national
economy’189
. 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 review190
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.
Institutional checks and balances remain weak. The Constitutional Court, composed
of members elected by the National Assembly without the involvement of the judiciary,
still reviews the merits of final rulings of ordinary courts in politically sensitive cases191
.
Assembly also amended the Mining Law at the same time and authorised the president of the
competent supervisory authority to adopt similar measures. On 23 February 2024, the Commission
referred Hungary to the Court of Justice; the case is pending (C-144/24).
183
In 2021, the Government adopted a decree requiring the prior notification of the export of certain
construction materials and products considered of strategic importance and granting a pre-emption
right to the State on the notified goods. According to the Government, this was necessary because due
to its high energy exposure and proximity to the war zone, Hungary has experienced inflation rates
well above the EU average. On 4 August 2023, the Commission referred Hungary to the Court of
Justice (C-499/23) on this matter.
184
Ost-Ausschuss – German Eastern Business Association (2025), WKÖ – Austrian Federal Economic
Chamber (2025).
185
Government Decree 6/2022 of 14 January 2022 imposing fixed prices (from 2022 to 2023) and
162/2023 of 5 May 2023 requiring mandatory discounts (from 2023 to 2024).
186
Judgment of the CJEU, case C-557/23, SPAR Magyarország concerning Government Decree 6/2022.
187
E.g. Government Decrees 42/2025 of 11 March 2025 and 93/2025 of 8 May 2025 introducing price
margin restrictions (as of March and May 2025, respectively). On 18 June 2025, the Commission
opened infringement procedures against Hungary (INFR(2025)2052 and INFR(2025)2102) for
imposing price margin restrictions on non-Hungarian companies. The first procedure concerns
restrictions on the sale of certain food products by food retailers. The second procedure covers similar
restrictions for the sale of certain non-food products by drugstores.
188
INFR(2024)4022. On 18 June 2025, the Commission sent a reasoned opinion.
189
Section 24/A of the Competition Act.
190
The Constitutional Court could review the constitutionality of such individual measures (see Decision
16/2020. (VII. 8.) AB, para 33).
191
2024 Rule of Law Report, Hungary, p. 35. On 13 June 2024, the Constitutional Court quashed the
decision of the Kúria that dismissed the complaint – filed by a candidate supported by the governing
parties – regarding an opposition candidate’s campaign activity during the municipal elections
26
On 20 May 2025, the National Assembly elected its Deputy Speaker and the Prosecutor
General to the Constitutional Court192
. The Constitutional Court does not have a case
allocation scheme and is not bound by procedural deadlines when hearing constitutional
complaints193
. Concerns regarding the independence and effective functioning of the
Commissioner for Fundamental Rights remain194
. Stakeholders have also expressed
concerns about the impartiality of the State Audit Office, which has imposed severe fines
on opposition parties because of campaign financing practices and not investigating
similar practices of the governing parties195
. Similar concerns have also been expressed
in relation to the Competition Authority and the Public Procurement Authority which are
seen as selectively applying the rules196
.
Concerns related to the absence of procedural safeguards and effective oversight in
case of secret surveillance measures outside criminal proceedings have not been
addressed197. The execution of relevant judgments of the European Court of Human
(Decision 3210/2024. (VI. 13.) AB). On 17 December 2024, the Constitutional Court quashed the
Kúria decision which allowed a referendum on the organisation of Olympic games in Budapest
(Decision 24/2024. (XII. 30.) AB).
192
The proposal is made by a parliamentary committee. According to the Constitutional Court Act, as
amended by Act LXVII of 2024 as of 1 January 2025, while it is still required that candidates for the
office of a member of the Constitutional Court have a law degree and be either academics with
‘outstanding theoretical knowledge’ (meaning, according to the law, university professors or doctors
of the Hungarian Academy of Sciences) or have at least twenty years of professional experience in the
field of law, it is no longer necessary that such professional experience ‘in the field of law’ be acquired
in a position for which there is a statutory requirement to have a law degree. On 16 June 2025, the
Venice Commission recommended clarifying what kind of experience ‘in the field of law’ (acquired in
a position for which a law degree is not needed by law) would qualify a candidate to be appointed. See
Venice Commission (2025), paras 56 and 62.
193
2024 Rule of Law Report, Hungary, pp. 31 and 35. According to the Government, the case allocation
scheme of the Constitutional Court has customary nature. When allocating the case, its President takes
the specific knowledge (specialisation) and the workload of members, as well as the pending cases that
are interrelated, into consideration when assigning the cases to members. Although there is no
statutory deadline for the final decision to be taken in a constitutional complaint procedure, the
Internal Rules of Procedure (‘Ügyrend’) establish internal deadlines that ensure the closure of cases
within reasonable time.
194
2024 Rule of Law Report, Hungary, p. 33 and Háttér Society et al (2025). According to the
Government, in 2024 the Commissioner received 8 853 individual complaints and inquiries, and public
authorities demonstrated a high rate of compliance (approximately 90%) with the recommendations set
out in the Office’s publicly available and transparent reports. According to the Government, this shows
both the Commissioner’s functional independence and his impact in safeguarding fundamental rights.
195
The State Audit Office imposed large fines on opposition parties on several occasions (HUF 660
million, c. EUR 1.7 million in 2017, HUF 520 million, c. EUR 1.3 million in 2024). These decisions
were confirmed by the Budapest Regional Court (judgments 104.K.701.004/2024/43,
104.K.701.005/2024/40 and 104.K.701.006/2024/37 of 18 March 2025). At the same time, it did not
impose fines on the ruling party, despite evidence of similar practices in campaign financing (e.g.
buying services at reduced prices, sharing campaign costs with related organisations, etc.) (see OSCE
ODIHR (2022), p. 3, Transparency International Hungary (2022) and Transparency International
Hungary (2023)).
196
Amnesty International Hungary et al (2025), p. 52. For instance, the Competition Authority unduly
singled out a foreign-owned retailer by enforcing various rules in an apparent attempt to dissuade it
from challenging government-imposed price regulations. Also, the Competition Authority imposed a
HUF 11 billion (EUR 26.7 million) cartel fine on a chemical company whose owner openly supported
the opposition; on 3 October 2024, the Budapest Regional Court quashed the Authority’s decision as
ill-founded (judgment 105.K.706.686/2021/138). The Public Procurement Authority failed to
investigate the award of two public contracts from a contracting authority primarily owned by the
same Government-affiliated businessman as the winner of the tenders.
197
See 2024 Rule of Law Report, Hungary, p. 34.
27
Rights is still pending198
. On 12 June 2025, the Committee of Ministers of the Council of
Europe urged the Hungarian authorities to adopt measures required to bring the domestic
legislation on secret surveillance for national security purposes fully and effectively in
line with the Convention requirements199
. In a new judgment of 28 November 2024
related to the wiretapping of a journalist, the European Court of Human Rights found that
there had been no adequate procedural safeguards in place for the applicant to challenge
the alleged use of secret surveillance against her with a view to discovering her
journalistic sources200
. In previous cases of journalists allegedly targeted by the Pegasus
spyware, the National Data Protection and Freedom of Information Authority found no
proof that the bodies authorised to conduct secret surveillance would have used the
spyware for any purpose other than the discharge of the duties specified by law and those
specified by the company providing the spyware (prevention and detection of criminal
acts and acts of terrorism)201
.
On 1 January 2025, Hungary had 47 leading judgments of the European Court of
Human Rights pending implementation, an increase of 2 compared to the previous
year202. At that time, Hungary’s rate of leading judgments from the past 10 years that had
been implemented was at 26% (compared to 24% in 2024; 74% remained pending), and
the average time that the judgments had been pending implementation was 6 years and 6
months (compared to 6 years and 2 months in 2024)203
. The oldest leading judgment,
pending implementation for more than 15 years, concerns the violation of the right to
freedom of assembly204
. As regards the respect of payment deadlines, on 31 December
2024 there were 32 cases in total awaiting confirmation of payments (compared to 47 in
2023)205
. On 16 June 2025, the number of leading judgments pending implementation
had increased to 52206
.
A deteriorating environment for civil society organisations and legal uncertainty
further obstruct civic space207. The space for civil society continues to be rated as
‘obstructed’208
. A new law209
moves the register of civil society organisations (CSOs)
from the courts to a central administrative authority as of 1 January 2027. Stakeholders
198
Judgments of the ECtHR, 37138/14, Szabó and Vissy v Hungary and 58032/16, Hüttl v Hungary.
199
CM/Del/Dec(2025)1531/H46-22.
200
Judgment of the ECtHR, case 31091/16, Klaudia Csikós v Hungary.
201
National Data Protection and Freedom of Information Authority (2022). According to the
Government, Hungarian legislation does not differentiate between professions and professional
activities (e.g. ‘journalist, human rights activist, opposition politician, lawyer and businessman’) with
regard to secret surveillance when it does not restrict in that respect national security services in
carrying out the activities under Section 56 of National Security Act.
202
For an explanation of the supervision process, see the website of the Council of Europe.
203
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 2025. EIN (2025), written
input, p. 5.
204
Judgment of the ECtHR, 5529/05, Patyi and Others v Hungary, pending implementation since 2009.
According to the Government, the length of this process is often due to the working methods of the
Committee of Ministers, involving constant monitoring of the development of domestic jurisprudence
and grouping together cases concerning remotely similar issues.
205
Council of Europe (2025), p. 156.
206
Data according to the online database of the Council of Europe (HUDOC).
207
The 2024 Rule of Law Report recommended that Hungary ‘[r]emove obstacles affecting civil society
organisations and foster a safe and enabling civic space, including by repealing legislation that
hampers their capacity of working, in particular the immigration tax’.
208
CIVICUS (2025). In 2023, approximately 61 076 CSOs were active according to the Hungarian
Central Statistical Office; no forced dissolutions of CSOs were reported.
209
Act LIX of 2025.
28
report that government attacks on independent CSOs have continued210
. On 3 October
2024, the Commission decided to refer Hungary to the Court of Justice over the
Protection of National Sovereignty Law211
. The Sovereignty Protection Office started
several investigations concerning various civil society organisations, notably anti-
corruption CSOs212
, including those receiving EU funds. In some of these reports, the
Office labelled the activities of several Commission intermediaries tasked with the
disbursement of the EU’s Citizens Equality Rights and Values (CERV) programme as
carrying ‘a serious sovereignty risk’213
. On 13 May 2025, a draft law ‘on transparency in
public life’ was tabled in the National Assembly. On 4 June 2025, it was announced that
the parliamentary work on this draft law would be postponed to the autumn session. The
draft law increases the powers of the Sovereignty Protection Office, introducing
significant consequences for the activities of civil society organisations, media outlets
and other entities within its scope, and considerably restricts their access to funding. In
particular, the investigations of the Office would serve as the basis for a government
decree listing entities whose activities are qualified as endangering ‘Hungary’s
sovereignty through influence on public life’214
. The draft law sparked protest from
independent media outlets and civil society organisations, which deem it serves to restrict
critical voices in Hungary215
. The Commission has voiced its serious concerns about this
draft law with the Hungarian authorities216
. Recent amendments to legislation and the
Constitution, as well as their application in practice resulted in legal uncertainty for the
organisers and participants of public assemblies aimed at promoting equality and
diversity. Stakeholders note that the distribution of public funding continues to be
uneven217
, untransparent, privileging government-aligned organisations against CSOs
210
Amnesty International Hungary et al (2025), p. 88.
211
The case is pending before the Court of Justice (C-829/24). The Commission considers that the
Protection of National Sovereignty Law breaches several fundamental freedoms and secondary
legislation in the internal market, several fundamental rights enshrined in the EU Charter of
Fundamental Rights and EU Data protection legislation. The European Parliament, fourteen Member
States and Norway have intervened in the case in support of the Commission’s position.
212
The law has had a deterring effect on CSOs that are members of monitoring committees of EU funded
programmes. Also, during the 5 December 2024 meeting of the Partnership Agreement monitoring
committee they expressed concerns that the Sovereignty Protection Office can target them for their
work.
213
Sovereignty Protection Office (2024), Sovereignty Protection Office (2025). Until March 2025,
Hungarian entities were granted more than EUR 26.5 million in total for the implementation of CERV-
funded projects. Most of the beneficiaries are private non-profit organisations and most of the grants
are running. See the Financial Transparency System and the EU Funding and Tenders portal for
details.
214
According to the draft law, once an entity is listed, it may not receive foreign support without prior
authorisation from the tax administration. The potential duration of the authorisation procedure can
last 180 days, even where the support is ultimately qualified as not being granted to influence public
opinion. Listed entities would be required to request from their donors a written declaration that the
support provided to it has not been received from a foreign source. In addition to the restriction on
foreign support, entities will be excluded from a state subsidy scheme whereby an entity can be
nominated by individual tax-payers to receive an amount corresponding to one per cent of their
personal income tax. Senior officers, founders of a listed entity and members of its supervisory
committee would be subject to enhanced customer due diligence by financial institutions and would be
obliged to make a public declaration of assets.
215
European Centre for Press and Media Freedom (2025), Hungarian Helsinki Committee (2025b),
International Federation of Journalists (2025).
216
On 23 May 2025, the Commission sent a letter to the Hungarian authorities expressing concerns about
the draft law.
217
The total income of associations and foundations in 2023 was HUF 1 345 billion (EUR 3.36 billion),
more than the year before (HUF 1 270 billion; EUR 3.2 billion). Of this, some 40% came from public
funding, 22% from private sources, with the rest originating from business and other income.
29
critical of government policies, which are not able to secure public funding in
Hungary218
. Overall, no progress has been made on the recommendation and the situation
has instead further deteriorated.
Crowdsourcing remained an important source of income for many CSOs. The majority of CSOs work
on a small annual budget (less than HUF 5 million or EUR 12 500) on a mostly voluntary basis, which
seriously limits their capacities. This is visible especially in the countryside.
218
Amnesty International Hungary et al (2025), p. 90. According to the Hungarian Central Statistical
Office, funding provided through the National Cooperation Fund increased from EUR 8.5 million
(HUF 3.4 billion) in 2012 to EUR 32.6 million (HUF 13 billion) in 2025. Also, the State provides free
professional assistance to CSOs across the country through Civil Community Service Centres (‘Civil
Közösségi Szolgáltató Központok’).
30
Annex I: List of sources in alphabetical order*
* The list of contributions received in the context of the consultation for the 2025 Rule of Law
Report can be found at https://commission.europa.eu/publications/2025-rule-law-report-
targeted-stakeholder-consultation_en.
24.hu (2024), Scandal in court: security guards led out the main accused of corruption in the
Ministry of Finance (Botrány a bíróságon: biztonsági őrök vezették ki a pénzügyminisztériumi
korrupció fővádlottját), https://24.hu/belfold/2024/10/21/varga-mihaly-penzugyminiszterium-
korrupcio-vesztegetes-volt-helyettes-allamtitkar-karsai-tamas-palkovics-laszlo-barta-eke-gyula-
eu-palyazat-kenopenz-miniszterelnokseg-birosag-elokeszito-ules/
Amnesty International Hungary, Hungarian Civil Liberties Union, Hungarian Helsinki
Committee, K-Monitor, Mérték Media Monitor, Ökotárs – Hungarian Environmental Partnership
Foundation, Political Capital, Transparency International Hungary (2024), Contribution for the
2024 Rule of Law Report, https://www.amnesty.hu/hungarian-csos-contribute-to-the-european-
commissions-2024-rule-of-law-report/.
Amnesty International Hungary, Hungarian Civil Liberties Union, Hungarian Helsinki
Committee, K-Monitor, Mérték Media Monitor, Ökotárs – Hungarian Environmental Partnership
Foundation, Political Capital, Transparency International Hungary (2025), Contribution for the
2025 Rule of Law Report, https://transparency.hu/wp-
content/uploads/2025/01/HUN_CSO_contribution_EC_RoL_Report_2025.pdf.
Anti-Corruption Task Force (2025), Minutes of the Anti-Corruption Task Force Meeting
(Jegyzőkönyv), https://kemcs.hu/wp-
content/uploads/2025/04/KEMCS_jegyzokonyv_20250312.pdf.
Átlátszó (2024), Investigative Outlet Átlátszó Accused of Foreign Influence and Espionage,
https://fom.coe.int/en/alerte/detail/107641772.
Átlátszó (2025), The Anti-Corruption Task Force has not adopted an annual report. (Nincs
elfogadott éves jelentése a Korrupcióellenes Munkacsoportnak), https://atlatszo.hu/wp-
content/uploads/2025/05/KEMCS_civil_sajtokozlemeny_20250502.pdf.
Bertelsmann Stiftung (2024), Transformation Index: Hungary Country Report, https://bti-
project.org/fileadmin/api/content/en/downloads/reports/country_report_2024_HUN.pdf.
Budapest Regional Court (2025), Two former Deputy State Secretaries sentenced to prison for
accepting bribes (Vesztegetés elfogadása miatt börtönbüntetésre ítéltek két volt helyettes
államtitkárt), https://birosag.hu/aktualis-kozlemenyek/fovarosi-torvenyszek-vesztegetes-
elfogadasa-miatt-bortonbuntetesre-iteltek-ket-volt-helyettes
CCBE (2025), Contribution for the 2025 Rule of Law Report.
https://ccbe.eu/fileadmin/speciality_distribution/public/documents/ROL/EN_ROL_20250227_C
CBE-Contribution-for-the-2025-Rule-of-Law-Report.pdf.
Centre for Media Pluralism and Media Freedom (2025), Media Pluralism Monitor 2025, Country
report for Hungary, https://cmpf.eui.eu/projects/media-pluralism-monitor/.
Civil Liberties Union for Europe (2025), Rule of Law Report, Hungary,
https://www.liberties.eu/f/vdxw3e.
Court of Justice, judgment of 6 March 2025, C-155/23, Commission v Hungary (Directive
lanceurs d’alerte), EU:C:2025:151.
31
Court of Justice, judgment 6 March 2025 in joined cases C-647/21, C-648/21, D. K.
(Dessaisissement d’un juge), EU:C:2025:143.
Court of Justice, judgment of 25 February 2025, C-146/23 and C-374/23, Sąd Rejonowy w
Białymstoku, EU:C:2025:109.
Court of Justice, judgment of 12 September 2024, C-557/23, SPAR Magyarország,
EU:C:2024:737.
Court of Justice, judgment of 11 January 2024, C-537/22, Global Ink Trade, EU:C:2024:6.
Corruption Research Center Budapest (2023), Fourteen Graphs and Two Tables on the New
Trends of Corruption in the Hungarian Public Procurement 2005-2022,
https://www.crcb.eu/?p=3400.
Corruption Research Center Budapest (2023), The new trends of corruption risks in Hungarian
public procurement, https://www.crcb.eu/?p=3450#:~:text=Lord%20Kelvin-
,The%20New%20Trends%20of%20Corruption%20Risk%20in%20Hungarian%20Public,January
%201998%20to%20July%202023&text=In%202023%2C%20corruption%20risk%20increased,c
ompanies%20with%20no%20political%20ties.
Corruption Research Center Budapest (2023), White Elephants in Hungary – Lessons of some EU
funded projects, https://papers.ssrn.com/sol3/papers.cfm?abstract_id=4403151.
Corruption Research Center Budapest (2024), Two Communication Companies in the Hungarian
Public Procurement Market 2012-2023, https://www.crcb.eu/?p=3530.
Council Implementing Decision (EU) 2022/2506 of 15 December 2022, OJ L 325, 20.12.2022, p.
94–109.
Council of Europe (2003), Recommendation Rec(2003)4 of the Committee of Ministers to
member states on common rules against corruption in the funding of political parties and
electoral campaigns, 8 April 2003, https://rm.coe.int/16806cc1f1.
Council of Europe (2023), Hungary: anti-corruption group calls for measures to prevent
corruption in central government and law enforcement, https://www.coe.int/en/web/portal/-
/hungary-anti-corruption-group-calls-for-measures-to-prevent-corruption-in-central-government-
and-law-enforcement.
Council of Europe Platform to promote the protection of journalism and safety of journalists
(2025), https://fom.coe.int/en/accueil.
Council of Europe (2020), Convention on Access to Official Documents (CETS No. 205),
https://www.coe.int/en/web/conventions/full-list?module=treaty-detail&treatynum=205.
De Tijd (2024), From searched hotel rooms to chased fraud detectives: Hungary spies on EU
institutions (Van doorzochte hotelkamers tot achtervolgde fraudespeurders: Hongarije
bespioneert EU-instellingen), https://www.tijd.be/politiek-economie/europa/algemeen/van-
doorzochte-hotelkamers-tot-achtervolgde-fraudespeurders-hongarije-bespioneert-eu-
instellingen/10577507.html
Direkt36 (2024), EU Investigators Probing Orbán’s Son-in-Law Surveilled, Sparking
Intelligence Agency Infighting, https://www.direkt36.hu/en/english-eu-investigators-probing-
orbans-son-in-law-surveilled-sparking-intelligence-agency-infighting/.
Direkt36 (2025), The State Audit Office found huge asset losses and other serious problems at the
Hungarian National Bank’s foundation, according to a leaked draft report,
32
https://www.direkt36.hu/en/hatalmas-vagyonvesztest-es-mas-sulyos-problemakat-talalt-az-asz-
matolcsyek-alapitvanyanal-a-kiszivargott-jelentestervezet-szerint/.
European Network of Councils for the Judiciary (ENCJ) (2025), The situation in Hungary
https://pgwrk-websitemedia.s3.eu-west-1.amazonaws.com/production/pwk-web-encj2017-
p/Final%20statement%20Hungary%2021%2002%202025.pdf.
European Centre for Press and Media Freedom (2025), Media Freedom Rapid Response –
Hungary, https://www.mfrr.eu/.
European Centre for Press and Media Freedom (2025), Hungary: Foreign funding bill poses most
serious threat to independent media in years, https://www.ecpmf.eu/hungary-foreign-funding-
bill-poses-most-serious-threat-to-independent-media-in-years/.
European Commission, Decision C(2024) 9140 final of 16 December 2024,
https://commission.europa.eu/document/download/8003e1ad-8e79-4238-bf76-
af1fcd2b5efe_en?filename=20241216%20Decision%20on%20PITs%20notification%20-
%20EN.pdf.
European Court of Human Rights, judgment of 28 November 2024, application no. 31091/16,
Klaudia Csikós v Hungary.
European Court of Human Rights, judgment of 29 September 2022, application no. 58032/16,
Hüttl v Hungary.
European Court of Human Rights, judgment of 23 June 2016, application no. 20261/12, Baka v
Hungary.
European Court of Human Rights, judgment of 12 January 2016, application no. 37138/14, Szabó
and Vissy v Hungary.
European Court of Human Rights, judgment of 16 July 2015, application no. 48322/12, Gazsó v
Hungary.
European Court of Human Rights, judgment of 26 May 2009, application no. 31475/05, Kenedi v
Hungary.
European Court of Human Rights, judgment of 7 October 2008, application no. 5529/05, Patyi
and Others v Hungary.
G7.hu (2024), The state has spent HUF 1360 billion on Rogán’s communication since 2015
(1360 milliárdot költött az állam a Rogán-féle kommunikációra 2015 óta),
https://g7.hu/kozelet/20240219/1360-milliardot-koltott-az-allam-a-rogan-fele-kommunikaciora-
2015-ota/.
General Court of the European Union, judgment of 27 June 2019, Hungary v Commission, case
T-138/25, EU:T:2019:448.
GRECO (2019), Third Evaluation Round – Second Addendum to the Second Compliance Report
on Hungary on incriminations and transparency of party funding (1 August 2019),
https://rm.coe.int/third-evaluation-round-second-addendum-to-the-second-compliance-
report/168096947e.
GRECO (2022), Fourth Evaluation Round – Third Interim Compliance Report, (8 September
2022), https://rm.coe.int/fourth-evaluation-round-corruption-prevention-in-respect-of-members-
of/1680a7f171.
33
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 (9 June 2023), https://rm.coe.int/fifth-evaluation-round-preventing-
corruption-and-promoting-integrity-i/1680ab87f5.
GRECO (2023b), Fourth Evaluation Round – Fourth Interim Compliance Report on Hungary on
corruption prevention in respect of members of parliament, judges and prosecutors (9 June
2023), https://rm.coe.int/fourth-evaluation-round-corruption-prevention-in-respect-of-members-
of/1680ab87f1.
Háttér Society, Amnesty International Hungary, Hungarian Helsinki Committee, Polgár
Foundation, Street Lawyer, Hungarian Civil Liberties Union (2025), Persisting failure to step up
for human rights - Background paper on Hungary’s national human rights institution,
https://helsinki.hu/en/wp-content/uploads/sites/2/2025/06/HU_NHRI_assessment_June2025.pdf.
Hungarian Association of Judges (MABIE) (2025), Contribution for the 2025 Rule of Law
Report.
Hungarian Civil Liberties Union (2025), Contribution for the 2025 Rule of Law Report.
Hungarian Government (2024), Government Decision 1025/2024 of 14 February 2024 on the
adoption of the medium-term National Anti-Corruption Strategy for 2024-2025,
https://korrupciomegelozes.kormany.hu/strategiai-dokumentumok1.
Hungarian Helsinki Committee (2025a), Contribution for the 2025 Rule of Law Report.
Hungarian Helsinki Committee (2025b), Operation Starve and Strangle: Hungary’s proposed
“Transparency” Law threatens core European democratic values and attacks independent civil
society and media organisations, https://helsinki.hu/en/operation-starve-and-strangle-2025/.
Hungarian Helsinki Committee (2025c), He was fired because he stood up for the public interest,
but he won’t let himself go (Kirúgták, mert kiállt a közérdekért, de nem hagyja magát), 13
January 2025, https://helsinki.hu/kirugtak-kiallt-a-kozerdekert-batonyi-peter/.
Hungarian Helsinki Committee (2025d), The Kúria President broke the law when he overstepped
his authority (Törvényt sértett a Kúria elnöke, amikor túllépett hatáskörén),
https://helsinki.hu/torvenyt-sertett-a-kuria-elnoke-amikor-tullepett-
hataskoren/https://helsinki.hu/torvenyt-sertett-a-kuria-elnoke-amikor-tullepett-hataskoren/.
Hungary Today (2025), Government Challenges European Commission Decision on Universities
in EU Court, https://hungarytoday.hu/government-challenges-european-commission-decision-on-
universities-in-eu-court/.
HVG.HU (2025), We did not get special treatment for free - the Kúria President’s New Year’s
message was telling (A kiemelt bánásmódot nem ingyen kaptuk – sokatmondó volt a Kúria-elnök
újévi köszöntője), https://hvg.hu/itthon/20250104_kuria-birok-kiemelt-banasmod-fizetesemeles-
Varga-Zs-Andras-ujevi-koszonto-ebx.
Institut für Europäische Politik (2024), German Companies in Hungary. To adapt, endure, or
engage?, https://iep-berlin.de/site/assets/files/3853/iep_study_germancompaniesinhungary-1.pdf.
Integrity Authority (2023a), The position of the Integrity Authority regarding the Government’s
answer (Az Integritás Hatóság álláspontja a Kormány válaszaival kapcsolatban),
https://integritashatosag.hu/wp-
content/uploads/2023/12/Integritas_Hatosag_osszegzes_Kormanyvalaszokra_20231206.pdf.
34
Integrity Authority (2023b), Ad-hoc report on asset declarations (Vagyonnyilatkozatokról szóló
eseti jelentés), https://integritashatosag.hu/wp-
content/uploads/2023/12/Integritas_Hatosag_Vagyonnyilatkozatok_Eseti_Jelentes_2023-1.pdf.
Integrity Authority (2023c), 2022 Annual Analytical Report, https://integritashatosag.hu/wp-
content/uploads/2023/06/Integritas_Hatosag_Eves_Elemzo_Integritasjelentes_20220629.pdf
https://integritashatosag.hu/wp-content/uploads/2023/10/Annual-Analytical-Integrity-Report-
2022-ENG.pdf.
Integrity Autjority (2023d), Integrity Risk Assessment Report of the Hungarian Public
Procurement System, https://integritashatosag.hu/wp-content/uploads/2024/04/integrity-
authority-integrity-risk-assessment-report-310323.pdf.
Integrity Authority (2024a), Conclusion of inquiry III_86_2023 – modernisation of cattle farm
(III_86_2023. sz. vizsgálat lezárása – szarvasmarhatelep korszerűsítése),
https://integritashatosag.hu/case/iii_86_2023-sz-vizsgalat-lezarasa-szarvasmarhatelep-
korszerusitese/.
Integrity Authority (2024b), Annual Report to the Hungarian National Assembly 2023 ,
https://integritashatosag.hu/wp-content/uploads/2024/03/integrity-authority-annual-report-
2023.pdf.
Integrity Authority (2024c), Annual Analytical Report 2023, https://integritashatosag.hu/wp-
content/uploads/2025/02/Integritas_Hatosag_Eves_Elemzo_Integritasjelentes_2023_0612_angol.
pdf.
Integrity Authority (2024d), Closing of investigation no. VIZSG_27_2023 – abuse involving
funds for fishponds in Nógrád County, https://integritashatosag.hu/en/case/closing-of-
investigation-no-vizsg_27_2023-abuse-involving-funds-for-fishponds-in-nograd-county/.
Integrity Authority (2024e), Closing of investigation no. VIZSG/3/2023 – overpricing of the
Operational Programme for Supporting Socially Disadvantaged Persons (RSZTOP),
https://integritashatosag.hu/en/case/closing-of-investigation-no-vizsg-3-2023-overpricing-of-the-
operational-programme-for-supporting-socially-disadvantaged-persons-rsztop/.
Integrity Authority (2025a), 2024 Annual Report to the Hungarian Parliament,
https://integritashatosag.hu/wp-content/uploads/2025/05/integrity-authority-hungary-2024-
annual-report-to-the-hungarian-parliament-1.pdf.
Integrity Authority (2025b), Closing of investigation no. VIZSG_11_2024 – cases of misuse in six
Somlószőlős projects, https://integritashatosag.hu/en/case/closing-of-investigation-no-
vizsg_11_2024-cases-of-misuse-in-six-somloszolos-projects/.
Integrity Authority (2025c), Integrity risk assessment report of the Hungarian public
procurement system, https://integritashatosag.hu/wp-content/uploads/2025/02/Integrity-Risk-
Assessment-Report-of-the-Hungarian-Public-Procurement-System-2023.pdf.
International Federation of Journalists (2025), Hungary: Foreign Agent bill targets independent
media and NGOs https://www.ifj.org/media-centre/news/detail/category/europe/article/hungary-
foreign-agent-bill-targets-independent-media-and-ngos.
International Press Institute (IPI) (2025): Media Capture Monitoring Report, Media Capture
Monitoring Report: Hungary – ipi.media.
K-Monitor (2023), Hungarian MP’s Assets: Less Declared and Still not Monitored,
https://k.blog.hu/2023/02/15/hungarian_mp_s_assets_less_declared_and_still_not_monitored.
35
K-Monitor and Transparency International Hungary (2024), Special report on the 2023 Anti-
Corruption Task Force Report: Current issues in the fight against corruption in Hungary,
https://transparency.hu/wp-
content/uploads/2024/03/KEMCS_2023_civil_kulonjelentes_final.pdf.
Kúria (2025a), The appointment of the Vice-Presidents of the Kúria fully complied with the law
(A Kúria elnökhelyetteseinek kinevezése maradéktalanul megfelelt a törvény előírásainak)
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torveny-eloirasainak.
Kúria (2025b), The Kúria President’s letter in reply to the press release of the National Judicial
Council and the President of the National Office for the Judiciary (A Kúria elnökének
válaszlevele az Országos Bírói Tanács és az Országos Bírósági Hivatal elnökének közleményére),
https://kuria-birosag.hu/hu/sajto/kuria-elnokenek-valaszlevele-az-orszagos-biroi-tanacs-es-az-
orszagos-birosagi-hivatal.
Kúria (2025c), Contribution for the 2025 Rule of Law Report.
Lakmusz (2024), How does anyone who is not a friend of Fidesz become a ‘leftist’?,
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Magyar Nemzet (2025), Pressman’s Favorite Judge Releases Drug Lab Suspects,
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MEDEL (2025), Contribution for the 2025 Rule of Law Report.
Media1 (2024), ‘Hacked’ public procurement: The Integrity Authority has taken legal action in
the case involving New Land Media, https://integritashatosag.hu/en/hacked-public-procurement-
the-integrity-authority-has-taken-legal-action-in-the-case-involving-new-land-media-interview-
with-ferenc-pal-biro-president-of-the-integrity-au/.
Ministry of Interior (2025), Monitoring Support Matrix serving as the basis for the monitoring
activity of monitoring committee of the National Anti-Corruption Strategy for 2024-2025 (A
2024-2025 közötti időszakra szóló Nemzeti Korrupcióellenes Stratégia Monitoring Bizottság
monitoring tevékenysége alapját képező Monitoring Támogató Mátrix),
https://korrupciomegelozes.kormany.hu/strategiai-dokumentumok1.
National Data Protection and Freedom of Information Authority (2022), Findings of the
investigation of the Nemzeti Adatvédelmi és Információszabadság Hatóság launched ex officio
concerning the application of the ‘Pegasus’ spyware in Hungary, https://www.naih.hu/data-
protection/data-protection-reports/file/492-findings-of-the-investigation-of-the-nemzeti-
adatvedelmi-es-informacioszabadsag-hatosag-hungarian-national-authority-for-data-protection-
and-freedom-of-information-launched-ex-officio-concerning-the-application-of-the-pegasus-
spyware-in-hungary.
National Judicial Council (2024), Statement of 19 December 2024, https://obt-jud.hu/hu/birosagi-
szervezetrendszer-reformjaval-kapcsolatos-jogalkotasi-folyamatrol.
National Judicial Council (2024), Verbatim minutes of the 11 December 2024 meeting,
https://obt-jud.hu/sites/default/files/ulesek/Jegyzokonyv_2024.12.11.pdf.
National Judicial Council (2025a), The NJC President’s letter to the European Commission,
dated 23 May 2025 https://obt-jud.hu/sites/default/files/sajtokozlemenyek-mellekletek/Letter-to-
Mr-McGrath.pdf
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National Judicial Council (2025b), Comments on the proposal to amend justice-related laws
(Észrevételek az igazságügyi tárgyú törvények módosításáról szóló javaslathoz) https://obt-
jud.hu/sites/default/files/sajtokozlemenyek-mellekletek/Eszrevetelek-OBT-20250422.pdf
OECD (2021), Implementing the OECD Anti-Bribery Convention, Phase 4 Two-Year Follow-Up
Report: Hungary https://www.oecd.org/daf/anti-bribery/hungary-phase-4-follow-up-report.pdf.
OECD (2023a), A strategic approach to public integrity in Hungary: The 2023-2025 National
Anti-Corruption Strategy and Action Plan, https://www.oecd-ilibrary.org/docserver/a5461405-
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9123CD88C99C24.
OECD (2023b), Implementing the OECD Anti-Bribery Convention, Phase 4 Evaluation of
Hungary: additional written follow-up report,
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OECD (2023c), Government at a Glance 2023: Hungary,
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en/hungary_dacc7f00-en.html.
OECD (2023d), OECD Working Group on Bribery public statement on Hungary,
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31-01-2023.htm.
OECD (2024a), OECD Working Group on Bribery cancels High-Level Mission to Hungary,
https://www.oecd.org/en/about/news/speech-statements/2024/10/oecd-working-group-on-
bribery-cancels-high-level-mission-to-hungary.html.
OECD (2024b), OECD Economic Surveys: Hungary 2024,
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OSCE ODIHR (2022), Hungary Parliamentary Elections and Referendum - 3 April 2022 -
ODIHR Election Observation Mission Final Report
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OSCE ODIHR and Venice Commission (2020), Guidelines on Political Party Regulation,
Second Edition https://www.osce.org/files/f/documents/8/1/538473.pdf.
Ost-Ausschuss der Deutschen Wirtschaft – German Eastern Business Association (2025),
Contribution for the 2025 Rule of Law Report.
Prosecutor’s office (2024), Indictment in a case related to tender grants obtained through
corruption – with video – press release of the Central Chief Investigating Prosecution Office
(Vádemelés a korrupció útján szerzett pályázati támogatások ügyében- videóval - a Központi
Nyomozó Főügyészség sajtóközleménye), https://ugyeszseg.hu/vademeles-a-korrupcio-utjan-
szerzett-palyazati-tamogatasok-ugyeben-videoval-a-kozponti-nyomozo-fougyeszseg-
sajtokozlemenye/.
Res Iudicata - Judges for Social Awareness Association (2025), Contribution for the 2025 Rule of
Law Report.
Reuters (2024), Hungary prosecutors probe graft case tape leaked by former government insider,
https://www.reuters.com/world/europe/hungary-prosecutors-probe-graft-case-tape-leaked-by-
former-government-insider-2024-03-28/.
37
Reuters (2025), Hungary's opposition rallies as Orban pledges crackdown on media, NGOs,
https://www.reuters.com/world/europe/hungarys-orban-vows-fast-crackdown-media-ngos-over-
foreign-funding-2025-03-15/.
SELDI (2023), Bridges to nowhere – State Capture and Corruption Risks in Fiscal Transfers and
Public Procurement at the Local Level in Southeast Europe,
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fiscal-transfers-and-public-procurement-at-the-local-level-in-southeast-europe/.
Service courts (2025), Statement of 14 January 2025,
https://mabie.hu/images/A%20SZOLGALATI%20BIROSAGOK%20KOZLEMENYE.docx.pdf.
Sovereignty Protection Office (2024), The impact of the activities of Ökotárs on Hungarian
sovereignty, https://szuverenitasvedelmihivatal.hu/dokumentumok/The-impact-of-the-activities-
of-%C3%96kot%C3%A1rs-on-Hungarian-sovereignty.pdf.
Sovereignty Protection Office (2025), The European Commission’s CERV Programme – This is
how Brussels turned on the money tap to fund the Soros network (Az Európai Bizottság CERV
Programja - Így nyitotta meg Brüsszel a pénzcsapot a Soros-hálózat finanszírozására)
https://szuverenitasvedelmihivatal.hu/dokumentumok/Az-Europai-Bizottsag-CERV-programja-
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State Audit Office (2025), 25036 - SUMMARY of the Audit Report of the Neumann János
University Foundation, https://www.asz.hu/files/NJE_summary_EN.pdf.
State Audit Office (2025), 25038 - SUMMARY of the Audit Report of the National Bank of
Hungary, https://www.asz.hu/files/MNB_summary_EN.pdf.
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their judgments (Újra a bírók ellen hangol a Fidesz, személyükben és ítéletek miatt támadja őket)
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38
Transparency International Hungary (2022), Orban’s Fidesz to overspend in Hungary’s election
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kampany-asz-nyilt-level/.
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Report.
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National legislation:
Act XLVIII of 1993 on mining (‘the Mining Law’)
Act on XXXIV of 1994 on Police (‘the Police Act’)
Act CXXV of 1995 on national security services (‘the National Security Act’)
Act LVII of 1996 on the prohibition of unfair trading practices and unfair competition (‘the
Competition Act’)
Act CLXXXV of 2010 on media services and on the mass media (‘the Media Act’)
Act CXCV of 2011 on public finances (‘the Public Finances 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 CLXIV of 2011 on the status of the prosecutor general, prosecutors and other prosecution
employees and the prosecution career of Hungary (‘the Legal Status of Prosecutors Act’)
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 LV of 2018 on freedom of assembly (‘the Freedom of Assembly Act’)
Act XCIII of 2021 on the coordination of defence and security activities
Act LV of 2023 on Hungary’s central budget for the year 2024
Act LXXXVIII of 2023 on the protection of national sovereignty (‘the Protection of National
Sovereignty Law’)
Act LXXXV of 2024 amending certain laws for deregulation in the interests of legal
competitiveness (‘the Legal Competitiveness Act’)
Act V 2025 amending certain rules in relation to the Fifteenth Amendment
Act XX of 2025 amending certain laws in relation to the obligation of members of the European
Parliament to submit asset declarations
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Annex II: Country visit to Hungary
The Commission services held virtual meetings in February 2025 with:
• Amnesty International Hungary
• Átlátszó
• Bea Bodrogi lawyer, media expert
• Buda Central District Court
• Corruption Research Center Budapest
• ELTE Media Department
• Hungarian Association of Journalists (MÚOSZ)
• Hungarian Association of Judges (MABIE)
• Hungarian Bar Association (MÜK)
• Hungarian Civil Liberties Union (TASZ)
• Hungarian Helsinki Committee
• IntegrityAuthority
• K-Monitor
• Kúria (Supreme Court)
• 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:
• Amnesty International
• Araminta
• Civil Liberties Union for Europe
• Civil Society Europe
• European Civic Forum
• European Partnership for Democracy
• European Youth Forum,
• International Commission of Jurists
• International Federation for Human Rights (FIDH)
• JEF Europe
41
• Philea – Philanthropy Europe Association.
• Transparency International