Hungary strengthens transparency and anti-corruption in bid for EU funds
The Hungarian Parliament has passed Act XVIII of 2026 “On the amendment of certain laws necessary for access to European Union funds” (“Act”), which creates a framework for strengthening transparency in areas affected by public funds and for tackling systematic corruption. The Act has been published on 26 June 2026. The Act’s provisions will take effect on various dates: the third day after publication as a general rule and some provisions going into force on the 61st day after publication, 15 July 2026 and 20 August 2026.
Asset declarations
The Act overhauls Hungary's asset declaration regime by extending mandatory declarations to a wider range of officials (including political senior leaders, and board members of public foundations performing functions of public interest), requiring a new detailed template covering a wider scope of assets (with household members' declarations attached). Asset declarations must be filed electronically via an authenticated digital platform, making declarations publicly accessible on official websites. The retention period for former officials' declarations is extended from one to three years and a new criminal offence of "violation of the asset declaration obligation" is introduced, carrying up to one year of imprisonment for wilful omission and up to two years for concealment.
Integrity Authority’s powers to be extended
The Integrity Authority becomes a key institution for the newly enacted anti-corruption regime, which will have the following powers:
- An examination procedure for asset declaration covering approximately 20 categories of public officials;
- Authority to conduct regular, ex officio reviews based on an integrity risk assessment methodology;
- Access public registers, tax secrets, bank secrets and business secrets for investigative purposes;
- Impose administrative fines of HUF 100,000 to HUF 5 million for minor, non-intentional declaration irregularities; and
- Initiate proceedings before the Public Procurement Arbitration Board and to bring actions for failure to act against that body.
Dissolution of public foundations performing functions of public interest
In line with the Sixteenth Amendment to the Fundamental Law of Hungary, the Act dissolves public foundations performing functions of public interest (közfeladatot ellátó közérdekű vagyonkezelő alapítványok) and return assets granted to these dissolved foundations to the Hungarian state. Based on various estimates, the value of the assets to be received by the Hungarian state amounts to approximately HUF 3 trillion.
The assets of non-state actors will be repatriated to their original owners.
Non-higher-education foundations must be dissolved by 31 August 2026 while higher education foundations must be dissolved by 1 August 2027 with further legislation to follow.
Until the dissolutions are completed, full founder's rights revert to the Hungarian government. Board members face a four-year term limit (renewable once), appointment via open competition, and are subject to independent vetting by the State Audit Office.
Public procurement
The Act introduces wide-ranging measures with far-reaching consequences, such as fines on bidders which you may read about in detail in this CMS law article.
Transparency of public funds
The Act significantly expands the scope of entities required to list data in the Central Information Public Data Registry (e.g. state-owned companies, public-interest asset management foundations, and HUN-REN) with a bi-monthly machine-readable publication accessible for at least ten years. It also broadens the definition of "excluded public officials" for subsidy eligibility and introduces a new "responsible person" concept covering persons with executive decision-making authority in legal entities.
Anti-money laundering and beneficial ownership
The Act substantially expands the definition of beneficial owner (particularly for closed-end investment funds), introduces additional triggering events, strengthens due diligence obligations and broadens third-party access to the beneficial ownership registry, which you may read about in detail in this CMS law article.
For more information on this Act, contact your CMS client partner or the CMS experts who contributed to this article.
The article was co-authored by Anna Rideg.