Ettepanek - SWD(2026) 171, COM(2026) 316

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EUROPEAN COMMISSION

Brussels, 19.6.2026

COM(2026) 316 final

2026/0175 (NLE)

Proposal for a

COUNCIL IMPLEMENTING DECISION

amending the Implementing Decision of 15 December 2022 on the approval of the

assessment of the recovery and resilience plan for Hungary

{SWD(2026) 171 final}

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2026/0175 (NLE)

Proposal for a

COUNCIL IMPLEMENTING DECISION

amending the Implementing Decision of 15 December 2022 on the approval of the

assessment of the recovery and resilience plan for Hungary

THE COUNCIL OF THE EUROPEAN UNION,

Having regard to the Treaty on the Functioning of the European Union,

Having regard to Regulation (EU) 2021/241 of the European Parliament and of the Council of

12 February 2021 establishing the Recovery and Resilience Facility1 and in particular Article

20 thereof,

Having regard to the proposal from the European Commission,

Whereas:

(1) Following the submission of the national recovery and resilience plan (‘RRP’) by

Hungary on 11 May 2021, the Commission has proposed its positive assessment to the

Council. The Council approved the positive assessment by means of the Council

Implementing Decision of 15 December 20222.

(2) On 31 August 2023, Hungary submitted a modified national RRP, including a

REPowerEU chapter in accordance with Article 21c of Regulation (EU) 2021/241, to

the Commission. The Council approved the positive assessment by means of the

Council Implementing Decision of 8 December 20233.

(3) On 10 June 2026, Hungary made a reasoned request to the Commission to make a

proposal to amend the Council Implementing Decision of 15 December 2022 in

accordance with Article 21(1) of Regulation (EU) 2021/241 on the grounds that the

RRP is totally no longer achievable because of objective circumstances due to cost

increases stemming from energy price volatility, unexpected shifts in geopolitical

circumstances, unforeseen implementation challenges, delays resulting from time

constraints or scheduling pressures, and other legal or regulatory developments. To

that end, Hungary has submitted a new national RRP (‘new RRP’).

(4) The Commission considers that the reasons put forward by Hungary justify the request

to amend Council Implementing Decision of 15 December 2022 pursuant to Article

21(1) of Regulation (EU) 2021/241, and therefore, the Council Implementing Decision

should be amended.

1 OJ L 57, 18.2.2021, p. 17, ELI: https://eur-lex.europa.eu/eli/reg/2021/241/oj. 2 See documents: ST 15447/22 INIT; ST 15447/22 ADD 1. 3 See documents: ST 15964/23 REV 1; ST 15964/23 REV 2(bg); ST 15964/23 ADD 1.

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(5) On 8 July 2025, the Council addressed recommendations to Hungary in the context of

the European Semester. In particular, the Council recommended Hungary to pursue

effective coordination of macroeconomic policies, phase out price and interest-rate

caps, strengthen the medium-term budgetary framework, improve the long-term

sustainability of the pension system, improve the business environment, stimulate the

development of capital markets, strengthen innovation framework, accelerate

diversification of fossil fuel supply, phase out fossil fuel subsidies, improve flexibility

and competition in the electricity sector, improve water resilience, improve circularity,

improve education outcomes and increase participation of disadvantaged groups in

quality mainstream education, increase access to labour market measures, ensure

effective social dialogue, improve adequacy of social assistance and ensure access to

essential services as well as target housing support measures and increase housing

supply. Having assessed progress in the implementation of these country-specific

recommendations at the time of submission of the new RRP, the Commission finds

that Hungary has not fully implemented or achieved substantial progress with respect

to any of the recommendations.

(6) On 21 May 2026, the Commission published an in-depth review under Article 5 of

Regulation (EU) No 1176/2011 of the European Parliament and of the Council4 for

Hungary. The Commission’s analysis led it to conclude that Hungary is experiencing

macroeconomic imbalances, as vulnerabilities related to competitiveness, a high

government deficit and financing needs, house prices, and government interventions in

the financial market persist.

(7) The RRPs should pursue the general objectives of the Recovery and Resilience

Facility established by Regulation (EU) 2021/241 (the 'Facility') and of the European

Union Recovery Instrument set up by Council Regulation (EU) 2020/2094 in order to

support the recovery in the aftermath of the COVID-19 crisis. They should promote

the Union's economic, social and territorial cohesion by contributing to the six pillars

referred to in Article 3 of Regulation (EU) 2021/241.

(8) The implementation of the Member States' RRPs should constitute a coordinated effort

involving reforms and investments across the Union. Through coordinated and

simultaneous implementation and the implementation of cross-border and multi-

country projects, such reforms and investments should mutually reinforce each other

and generate positive spillovers across the Union.

Balanced response contributing to the six pillars

(9) In accordance with Article 19(3), point (a), of and Annex V, criterion 2.1, to

Regulation (EU) 2021/241, the new RRP represents to a large extent (Rating A) a

comprehensive and adequately balanced response to the economic and social situation,

thereby contributing appropriately to all of the six pillars referred to in Article 3 of that

Regulation, taking the specific challenges faced by and the financial allocation for the

Member State concerned into account.

(10) The new RRP includes measures that contribute to all of the six pillars, with a number

of components addressing multiple pillars simultaneously. The new RRP includes a

broad range of measures, with a particular focus on the green transition, digital

transformation, building economic, social and institutional resilience, and on policies

4 Regulation (EU) No 1176/2011 of the European Parliament and of the Council of 16 November 2011

on the prevention and correction of macroeconomic imbalances (OJ L 306, 23.11.2011, p. 25).

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for the next generation. The new RRP also includes measures to support smart,

sustainable and inclusive growth, and social and territorial cohesion, in line with the

European Industrial Strategy.

(11) The new RRP contributes significantly to the green transition and digital

transformation. The green transition is supported in particular through reforms and

investments in the field of sustainable transport, energy, water management and

circular economy. Key measures include investments in zero emission public

transport, energy grid developments and renewable energy generation. Several

components contain measures aimed at improving the energy efficiency of public and

residential buildings. The digital transformation is supported in particular through

measures to promote the digitalisation of education and the public administration, as

well as the digitalisation of the health and energy sectors, and the development of

digital innovation and digital skills.

(12) A significant number of reforms and investments in the new RRP aim to improve

healthcare and the economic, social and institutional resilience. Measures in the

healthcare sector are expected to improve efficiency and access to quality care. Key

institutional reforms are expected to improve the resilience of the economy through

strengthening the fight against corruption, the protection of the financial interests of

the Union and the independence of the judiciary. Fiscal reforms aim to simplify the

taxation system and to strengthen it against the risk of aggressive tax planning, as well

as to facilitate access to public data. Smart, sustainable and inclusive growth is

expected to be achieved in particular through various measures aiming to increase

competition and transparency in public procurement and to promote research and

innovation.

(13) A wide range of measures in the new RRP contribute to social and territorial cohesion

in particular through reforms and investments supporting development of human

capital, by enhancing digital and vocational skills, improving access to quality and

inclusive learning environments, increasing the attractiveness of the teaching

profession, and expanding the availability of early childhood education and care

services. In addition, several measures aim to address the specific challenges of the

most disadvantaged settlements and improve access to quality primary care services

and hospital care.

Addressing all or a significant subset of challenges identified in country-specific

recommendations

(14) In accordance with Article 19(3), point (b), of and Annex V, criterion 2.2, to

Regulation (EU) 2021/241, the new RRP is expected to contribute to effectively

addressing a significant subset of challenges (Rating A) identified in the relevant

country-specific recommendations addressed to Hungary, including fiscal aspects

thereof or challenges identified in other relevant documents officially adopted by the

Commission in the context of the European Semester.

(15) The new RRP includes an extensive set of mutually reinforcing reforms and

investments that contribute to effectively addressing all or a significant subset of the

economic and social challenges outlined in the country-specific recommendations

addressed to Hungary by the Council in the European Semester in 2019, 2020, 2022,

2023, 2024 and 2025, in particular regarding the green and digital transition,

education, innovation, labour market, social policy, healthcare, the anti-corruption

framework, judicial independence, competition in public procurement, the quality and

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transparency of decision-making, economic policy coordination, taxation and

aggressive tax planning, and the fiscal framework.

(16) The new RRP contains several relevant measures to address the challenges related to

the green transition. With regard to energy production and energy efficiency, the new

RRP includes reforms to improve permitting procedures for renewable energy

production, simplify the grid connection of small renewable power plants, remove

obstacles to the development of wind energy, calculate network tariffs, install smart

meters, strengthen the role of aggregators, use of dynamic pricing in electricity

purchase agreements, encourage competition in the balancing market, expand energy

communities and increase uptake of energy storage. The goal of the reforms is to

increase participation of market actors into the renewable generation and storage

markets. To do so, these reforms aim to accelerate the uptake in renewable power

generation (onshore wind in particular) and increase demand-side flexibility, as well as

competition in the balancing market. This way, these reforms are expected to address

the recommendations on improving flexibility and competition in the electricity sector,

accelerating the deployment of renewables. The new RRP also includes investments

aiming to increase the deployment of solar energy production, as well as to improve

the electricity network in order to allow for the secure integration of energy produced

from renewable sources. The new RRP further includes several investments for the

energy efficiency renovation of public buildings, in particular in the areas of

education, as well as of residential buildings which address the recommendation on

improving energy efficiency, in particular in buildings. As for sustainable transport,

the new RRP includes investments to develop the trail network, zero-emission bus

transport, tram and trolleybus system of Budapest and charging stations for electric

vehicles. Moreover, Hungary should introduce a single national tariff, ticketing and

passenger information system for bus and rail. The new RRP also comprises measures

aiming at promoting reforms on the circular economy and sustainable waste

management, as well as reform and investment in sustainable water management,

including through the promotion of nature-based water retention.

(17) The new RRP contains several relevant measures to address the challenges related to

the digital transition. The new RRP includes measures aiming to provide digital

notebooks for teachers and pupils in public education, information and

communications technology (ICT) devices for primary and secondary schools,

including vocational education and training schools, for universities and adult learning

institutions, and to increase the digitalisation of the healthcare sector. Moreover, the

new RRP includes some measures to increase the digitalisation of the public

administration, in particular through electronic reporting platforms for taxation

purposes and further development of the electronic procurement system.

(18) The new RRP includes several measures to address challenges in education. The new

RRP features reforms to improve the attractiveness of the teaching profession through

a mechanism that ensures gradual convergence of teachers’ wages to at least 80 % of

the average wage of tertiary graduates, to decrease segregation in schools as well as to

ensure access to quality school education, in particular by providing pupils and

teachers with the devices necessary to participate in modern digital education. The

new RRP also contains investments to support the integration of students with special

education needs into the mainstream education.

(19) The challenges related to research and innovation are addressed by setting up national

laboratories to improve the ecosystem for science and innovation. The support to

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establishment of and access to Artificial Intelligence Gigafactories as well as the

contribution to the EU Secure Connectivity Programme (IRIS2) also contribute to

strengthening the innovation framework for the public sector and businesses.

(20) The country-specific recommendation on the integration of the most vulnerable groups

in the labour market is addressed through the creation of additional places in crèches,

the promotion of employment opportunities for those living in the most disadvantaged

settlements.

(21) The new RRP includes various measures to address specific challenges related to

social policies by providing comprehensive support to the inhabitants of the 300 most

disadvantaged settlements. These measures aim to promote employment and skills

development according to local specificities, to achieve better learning outcomes

through community-oriented pedagogy and to establish social solar power plants.

(22) The new RRP sets out a wide-ranging set of reforms and investments to address the

most critical challenges of healthcare services. This includes in particular investments

in upgrading hospital infrastructure and equipment, and the development of primary

and preventive care by establishing communities of general practitioners providing

integrated healthcare services. This is complemented by investments in digital

healthcare, such as digitalisation programmes. Another measure supports the

eradication of gratuity payments in the healthcare system.

(23) The new RRP includes a number of measures to reinforce the anti-corruption

framework and the protection of the financial interests of the Union. These include the

legal establishment of an Integrity Authority to effectively reinforce the prevention,

detection and correction of fraud, conflicts of interest, corruption as well as other

illegalities and irregularities concerning the implementation of Union support in

Hungary, with a particular focus on public procurement and the verification of asset

declarations. According to the new RRP, the Integrity Authority should have extensive

powers to intervene in all cases where in its views competent national authorities have

not taken the necessary steps to prevent, detect and correct fraud, conflicts of interest,

corruption and other illegalities or irregularities that affect or seriously risk affecting

the sound financial management of the Union budget or the protection of the financial

interests of the Union. Furthermore, Hungary committed to submitting a notification to

the European Commission of its intention to participate in the enhanced cooperation

on the establishment of the European Public Prosecutor’s Office (‘EPPO’). Another

measure consists of the setting up of an Anti-Corruption Task Force, with significant

involvement of independent non-governmental organisations, to continuously examine

the existing anti-corruption measures and draw up proposals. In addition, the new RRP

includes measures to support a strengthened cooperation with the European Anti-

Fraud Office (OLAF), to put in place an extended personal and material scope for

asset declarations of certain high-risk officials, and to ensure the phasing out of public

interest asset management foundations performing public interest activity and ensure

the oversight and transparency of how public interest asset management foundations

performing public interest activity, and legal persons established or maintained by

them, make use of Union support as long as they still exist. The new RRP also

includes a number of reforms to strengthen the legislative, institutional and practical

arrangements to more effectively prevent, detect and correct fraud, corruption,

conflicts of interest, double funding and other illegalities in the use of Union support.

The new RRP comprises a reform to establish the possibility of a judicial review of

decisions by the prosecution service or the investigating authority to dismiss a crime

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report or terminate criminal proceedings in the case of special crimes related to the

exercise of public authority or the management of public property. Several measures

in the new RRP contribute to increasing transparency of and access to public data, also

with an aim to reinforce the anti-corruption framework by facilitating independent

oversight. Such measures include setting up and operating a searchable central register

on the use of public funds, eliminating or limiting the costs related to requests for

public information, facilitating court procedures on cases related to access to public

information, remove certain grounds to refuse granting access to public information

and ensure that regular checks on bodies carrying out public duty is introduced to

assess whether they comply with their respective requirements on providing access to

public information.

(24) The country-specific recommendation on strengthening judicial independence is

addressed by several reforms in the new RRP, which are expected to strengthen the

independence and impartiality of courts and judges established by law, thus raising the

standard of judicial protection and improving the investment climate in Hungary. The

new RRP includes measures to strengthen the relative role and powers of the National

Judicial Council in relation to the powers of the President of the National Office for

the Judiciary. The exercise of effective control over the President of the National

Office for the Judiciary by the National Judicial Council is expected to reduce the

possibility of arbitrary decisions in the central administration of courts, including in

relation to judicial appointments, and, therefore, strengthen judicial independence.

According to the new RRP, this should be achieved in particular by introducing the

requirement for a binding reasoned opinion of the National Judicial Council on

individual decisions, such as the suitability of candidates for the posts of President and

Vice-President of the National Office for the Judiciary, based on suitability criteria;

the annulment of appointment procedures for judicial and court executive positions;

the transfer of judges; and the removal of judges from the pool of judges that hear

special, including administrative, cases. The National Judicial Council should also

give a binding reasoned opinion on regulations such as the points system for judicial

posts, the conditions for the award of bonuses, the training of judges, the national

workload and the number of judicial posts. Finally, judges-members of the National

Judicial Council should have the possibility to be re-elected for the next term of office,

and the National Judicial Council should have access to all documents, legal capacity

and autonomy in disbursement of its budget, and right to seize the competent court and

the Constitutional Court to defend its prerogatives. Non-discretionary rules on

designation of ad interim court presidents and a prohibition for the reintegration of

judges to a higher court instance following their secondment should also be

introduced. Another reform is expected to strengthen the judicial independence of the

Supreme Court (Kúria), in particular by amending the rules on the election of the

Kúria president, who should have at least five years’ experience as a judge and should

not have the possibility to be re-elected. The National Judicial Council should give a

binding reasoned opinion on the suitability of candidates for President and Vice-

President of the Kúria. The reform should also remove the possibility for members of

the Constitutional Court to be appointed to the Kúria outside of the normal application

procedure, improve the case allocation scheme, and ensure stronger powers for the

judicial council of the Kúria. Further reforms are expected to remove obstacles to

references for preliminary rulings to the Court of Justice of the European Union and to

remove the possibility, introduced in 2019, for public authorities to challenge before

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the Constitutional Court final judicial decisions in order to ensure that final judgments

are taken by the competent independent courts.

(25) The new RRP also includes several measures to address challenges related to

competition in public procurement, including by reinforcing the integrity of public

procurement procedures. A reform consists of the development and continuous use of

a monitoring tool assessing the level and cause of public procurement procedures

resulting in single bids. To reinforce transparency and integrity of public procurement

procedures, a reform aims to introduce conflict of interest rules and additional

reporting and publication obligations for contracting authorities. Another reform aims

to develop a performance measurement framework to regularly assess the efficiency

and cost effectiveness of public procurements, and the reasons for limited competition

in the sectors most affected by the low level of competition. The adoption of an action

plan , on the basis of good international practices serves to increase the level of

competition in public procurement. Building on those reforms, the new RRP includes

a commitment for Hungary to reduce the share of public procurements receiving

Union support resulting in single bids to below 15%. To accompany these reforms, the

new RRP includes measures to develop the electronic public procurement system to

facilitate the independent oversight and analysis of competition in public procurement.

(26) The new RRP includes reforms to improve the quality and transparency of the

decision-making process through engagement with other stakeholders and regular

impact assessments. Related measures aim to ensure that draft legislative acts prepared

by the Government systematically undergo public consultation for a sufficient period

of time, unless there is a due justification, and that impact assessments and

explanations are consistently prepared and made available publicly for draft legislative

acts. The involvement of stakeholders in the implementation and oversight of the new

RRP itself is also envisaged through the setting up and operation of a monitoring

committee also beyond 2026, of which at least half of the members should come from

civil society organisations fully independent from public authorities. These might also

contribute to improving social dialogue.

(27) The new RRP also comprises measures regarding the business environment, in

particular on improving the tax system. The new RRP includes reforms aimed at

tackling aggressive tax planning more effectively, such as increasing the data reporting

on transfer pricing, reviewing minimum substance requirements for corporate income

tax for shell companies and extending the scope of non-deductibility rules for

outbound payments to low- or zero-tax jurisdictions. As regards tax simplification, the

new RRP includes measures to reduce the number of taxes and corporate tax benefits

and on the digital transformation of tax compliance procedures.

(28) The new RRP includes reforms to improve the sustainability of the public finances.

This includes measures on establishing a process for and carrying out spending

reviews, improvements to the domestic fiscal framework while launching a broader

review of the framework, and reforms of subsidised lending.

(29) The new RRP includes an extensive set of mutually reinforcing reforms and

investments that contribute to effectively addressing all or a significant subset of the

economic and social challenges outlined in the country-specific recommendations

addressed to Hungary by the Council in the European Semester in 2025, notably

related to economic policy coordination, fiscal framework, innovation, competition in

electricity sector, water resilience, education, labour market, social policy and

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housing. By addressing the aforementioned challenges, the new RRP is expected to

also contribute to correcting the imbalances, as identified in recommendations made

pursuant to Article 6 of Regulation (EU) No 1176/2011 in2026, that Hungary is

experiencing, in particular with regard to high government deficit and financing costs,

deteriorating cost competitiveness and exposure to energy prices, increasing house

prices, and government interventions in the financial market.

Contribution to growth potential, job creation and economic, social and institutional

resilience

(30) In accordance with Article 19(3), point (c), of and Annex V, criterion 2.3, to

Regulation (EU) 2021/241, the new RRP is expected to have a high impact (Rating A)

on strengthening the growth potential, job creation, and economic, social and

institutional resilience of Hungary, contributing to the implementation of the European

Pillar of Social Rights, including through the promotion of policies for children and

youth, and on mitigating the economic and social impact of the COVID-19 crisis,

thereby enhancing the economic, social and territorial cohesion and convergence

within the Union.

(31) At the heart of Hungary’s growth strategy lies a significant commitment to

modernising its economic infrastructure. The establishment of the Rolling Stock

Company (ROSCO) should catalyse the renewal of Hungary’s rolling stock and create

the basis for a more efficient management of railway services, thereby further

contributing to the country’s broader decarbonisation efforts. Complementing this,

investments in urban mobility, including the acquisition of new trams, buses and

trolleybuses aims at enhancing connectivity. The REPowerEU chapter places

particular emphasis on strengthening Hungary’s energy independence and accelerating

its green transition. By expanding electricity grid capacity and flexibility, the new

RRP enables the integration of renewable energy sources at scale. The onshore wind

energy deployment supported by streamlined permitting processes, should

significantly increase Hungary’s renewable energy generation. Simultaneously, the

modernisation of transmission and distribution networks ensures that this renewable

energy can be effectively integrated into the national grid. These measures are

complemented by investments in energy storage facilities and efficiency renovations

in public and residential buildings, creating a more resilient and sustainable energy

system.

(32) Hungary’s contribution to the EuroHPC Joint Undertaking aims at supporting the

establishment of an AI Gigafactory or equivalent compute infrastructure, aligning with

the European Commission’s vision for technological sovereignty. This investment

should accelerate the development of advanced computing capacity, reinforcing

Europe’s competitiveness in the global digital economy. Similarly, Hungary’s

contribution to the EU Secure Connectivity Programme (IRIS²) aims at addressing

critical security and resilience challenges by strengthening secure sovereign

communications, enhancing the resilience of critical infrastructure and public services,

and improving preparedness against cyber, hybrid and other security-related

disruptions.

(33) The new RRP places equal emphasis on job creation and social resilience, recognising

that sustainable economic growth must be inclusive. Through labour market

integration programmes targeting vulnerable groups, the new RRP aims to provide

opportunities in labour socialisation initiatives. The construction of new crèche places

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further supports working parents, particularly women, in balancing family and

professional responsibilities.

(34) The modernisation of healthcare facilities ensures equitable access to quality medical

services across the country. Additionally, the equity injection in the Hungarian

Development Bank’s (MFB) aims at facilitating the construction of affordable

housing, addressing urban-rural disparities and supporting low-income households and

students.

Do no significant harm

(35) In accordance with Article 19(3), point (d), of and Annex V, criterion 2.4, to

Regulation (EU) 2021/241, the new RRP is expected to ensure that no measure

(Rating A) for the implementation of reforms and investments projects included in the

new RRP does significant harm to environmental objectives within the meaning of

Article 17 of Regulation (EU) 2020/852 of the European Parliament and of the

Council5 (the principle of 'do no significant harm', referred to as ‘DNSH’).

(36) For measures where it is relevant, the potentially harmful environmental and climate

impact is addressed through appropriate assurances that the applicable criteria are to

be respected. Environmental risks are mitigated ex ante by the introduction of

conditions: Activities under the EU Emission Trading System (ETS) are to achieve

projected greenhouse gas emissions below the relevant benchmarks, and significantly

below the relevant benchmarks as far as possible. For all financial instruments a list

was introduced that aims to ensure that activities and assets that are not in line with the

principle of DNSH are not being supported.

(37) The new RRP introduces three measures with significant financial allocation to the

plan, for which DNSH safeguards have been put in place. In particular these

investments, notably the capital injection in a rolling stock company, the capital

injection in the Hungarian Development Bank and the grant scheme for electricity grid

development, all include dedicated eligibility criteria with a view to ensure the

compliance with the DNSH requirements already at the procurement stage. Thus, the

new RRP is expected to continue respecting the DNSH principle.

Contribution to the green transition including biodiversity

(38) In accordance with Article 19(3), point (e), of and Annex V, criterion 2.5, to

Regulation (EU) 2021/241, the new RRP contains measures that contribute to a large

extent (Rating A) to the green transition, including biodiversity, or to addressing the

challenges resulting therefrom. The measures supporting climate objectives account

for an amount which represents 52.9% of the new RRP's total allocation calculated in

accordance with the methodology set out in Annex VI of that Regulation. In

accordance with Article 17 of that Regulation, the new RRP is consistent with the

information included in the National Energy and Climate Plan 2021-2030.

(39) For the new RRP as a whole, climate-related expenditures represent 52.9%, with the

most significant contributions coming from investments in renewable energy

deployment and grid modernisation. The new RRP includes substantial support for

solar energy, with new capacity targeted in disadvantaged municipalities, alongside

expanded onshore wind deployment facilitated by streamlined permitting procedures.

5 Regulation (EU) 2020/852 of the European Parliament and of the Council of 18 June 2020 on the

establishment of a framework to facilitate sustainable investment, and amending Regulation (EU)

2019/2088 (OJ L 198, 22.6.2020, p. 13).

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Additionally, the modernisation of transmission and distribution networks, adding

extra capacity should enable greater integration of renewable energy sources and

energy storage solutions into Hungary’s electricity system. Energy efficiency

measures, such as the renovation of public buildings and the installation of smart

meters, further contribute to reducing energy consumption and emissions. In the

transport sector, the electrification of railway sections and the procurement of zero-

emission buses should significantly lower greenhouse gas emissions, supporting

Hungary’s broader decarbonisation goals. All measures in the REPowerEU chapter

contribute fully to climate objectives and the chapter therefore meet the 37% minimum

target. The installation of energy storage capacity aims at improving demand and

supply flexibility, while the expansion of onshore wind power generation and

residential solar panel installations should increase the share of renewables in

Hungary’s energy mix. The new RRP is expected to make a significant and lasting

contribution to the green transition, supporting the EU’s 2030 climate targets and the

2050 climate neutrality objective. The expanded renewable energy capacity, combined

with grid modernisation and energy efficiency improvements, aim at reducing

Hungary’s reliance on fossil fuels and lower greenhouse gas emissions. These

measures are designed to have a durable impact, as they aim at continuing to deliver

environmental benefits long after implementation.

(40) In addition to climate mitigation, the new RRP includes elements that contribute to

biodiversity and environmental protection. Water retention interventions covering

18 000 hectares aim at enhancing ecosystem resilience and support biodiversity in

agricultural areas, while the modernisation of the Kvassay pumping station should

improve the ecological status of the Danube branch. These investments align with

broader environmental objectives, complementing the new RRP’s primary focus on

climate action.

Contribution to the digital transition

(41) In accordance with Article 19(3), point (f), of and Annex V, criterion 2.6, to

Regulation (EU) 2021/241, the new RRP contains measures that contribute to a large

extent (Rating A) to the digital transition or to addressing the challenges resulting

from it. The measures supporting digital objectives account for an amount which

represents 24.1% of the new RRP’s total allocation calculated in accordance with the

methodology set out in Annex VII of that Regulation.

(42) The new RRP of Hungary meets the 20% digital expenditure target as required under

assessment criterion 2.6 of Annex V to the RRF Regulation, with key contributions

coming from investments in digital education, higher education modernisation, and the

digitalisation of public services. The new RRP includes digital tools, such as

notebooks, for schools, which aim at enhancing digital literacy and equip students with

the skills needed for the digital economy. Additionally, the modernisation of higher

education infrastructure, including the development of digital learning content and the

digitalisation of higher education facilities, should improve access to digital education

and support the transition to online and hybrid learning. The expansion of electronic

health procedures, including the rollout of a central healthcare mobile application,

aims at digitalising healthcare services, improving efficiency and accessibility.

(43) The measures in the new RRP are expected to significantly contribute to the digital

transformation of the economy. The investment in the AI Gigafactory initiative

supported by a voluntary contribution to the EuroHPC Joint Undertaking, aims at

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accelerating the development of advanced computing capacity and reinforcing

Hungary’s support for Europe’s digital sovereignty. Similarly, Hungary’s contribution

to the EU Secure Connectivity Programme (IRIS²) should enhance the country’s

secure satellite communications infrastructure, addressing critical challenges in digital

security and resilience.

Lasting impact

(44) In accordance with Article 19(3), point (g), of and Annex V, criterion 2.7, to

Regulation (EU) 2021/241, the new RRP is expected to have a lasting impact on

Hungary to a large extent (Rating A).

(45) The new RRP, including its REPowerEU chapter, is expected to have lasting positive

effect on the Hungarian economy. The new RRP increases the reform ambition, in line

with the recommendations of the European Semester, as well as transformative

investments in decarbonisation of transport, electricity grids and in SMEs. The new

RRP directs significant investment in the green transition, notably in increasing the

capacity and flexibility of the electricity grid. This corroborated by ambitious reforms

opening up the market to investments in wind energy production is expected to

reinforce the energy security of the country, curtail energy prices and contribute

towards reducing the country’s reliance on Russian fossil fuel imports, thus leading to

a lasting impact. The new RRP also includes ambitious measures supporting the roll-

out of electric vehicles as well as electrification of railway sections coupled with a

reform of the rail transport market.

(46) Investment in affordable housing, innovative SMEs and venture capital increase the

competitiveness of the Hungarian business environment.The potential impact of these

investments is reinforced by reforms improving the functioning of the National

Development Bank, phasing out certain sectoral taxes and strengthening transparent

market functioning through anti-corruption measures and rules on beneficial owners.

The new RRP is expected to make a significant contribution to strengthening the

institutional resilience of Hungary. This is expected to be achieved by reinforcing the

anti-corruption framework, strengthening judicial independence, and improving the

quality and transparency of the decision-making process. The business environment is

expected to be improved through measures on improving the tax system, regulatory

predictability, and increased competition in public procurement. The new RRP is also

expected to contribute to sound budgetary management through the introduction of

spending reviews and improvements to the fiscal framework.

(47) The lasting impact of the new RRP can also be enhanced through synergies between

the new RRP and other programmes, including those financed by cohesion policy

funds, in particular by addressing in a substantive manner the territorial challenges and

promoting a balanced development.

Monitoring and implementation

(48) In accordance with Article 19(3), point (h), of and Annex V, criterion 2.8, to

Regulation (EU) 2021/241, the arrangements proposed in the new RRP are adequate

(Rating A) to ensure effective monitoring and implementation of the new RRP,

including the envisaged timetable, milestones and targets, and the related indicators.

(49) The milestones and targets of the new RRP enable an adequate monitoring of the

plan’s implementation. The performance of the investments included in the new RRP

is to be assessed on the basis of the achievement of multiple milestones and targets

EN 12 EN

monitored by each public entity in charge of implementing the measures and capturing

the key implementation stages of each investment. The targets chosen are consistent

with the objectives, cost estimates and implementation schedule of each measure and

quantified by specific indicators reflecting the result of the works undertaken.

Milestones and targets are also relevant for measures already completed which are

eligible under Article 17(2) of Regulation (EU) 2021/241. The satisfactory fulfilment

of these milestones and targets over time is required to justify a disbursement request.

(50) Each of the new reforms and investments introduced includes at least one target and/or

milestone that contains the key elements of the measure and allows for the assessment

of the achievement of its objectives. The distribution of milestones and targets features

a high concentration at the end of the implementation period of the plan.

(51) Member States are to ensure that financial support under the Facility is communicated

and acknowledged in line with Article 34 of Regulation (EU) 2021/241.

Costing

(52) In accordance with Article 19(3), point (i), of and Annex V, criterion 2.9, to

Regulation (EU) 2021/241, the justification provided in the new RRP on the amount of

the estimated total costs of the new RRP is to a medium extent (Rating B) reasonable

and plausible, is in line with the principle of cost efficiency and is commensurate to

the expected national economic and social impact.

(53) Hungary has provided cost estimates for all the investments of its new RRP and

sufficient information to consider that costs are overall reasonable and plausible.

Measures have been estimated amongst others based on market prices or prices of

similar units in past investments, contracts signed or on indicative offers. For other

measures, a top-down approach is used where the overall cost of the project is based

on similar projects from the past. Based on the assessment of the cost estimates and

related supporting documents, the cost estimates for most of the measures in the plan

are deemed reasonable and plausible. The amount of the estimated total costs of the

new RRP is in line with the nature and type of the envisaged reforms and investments.

Hungary has submitted sufficient costing evidence underpinning the claims presented

in the plan. In the new RRP, for the costs of new measures, including those in the

REPowerEU chapter, the estimates have been deemed, to a medium extent, as

plausible.

(54) Hungary provided sufficient information and evidence that the amount of the

estimated cost of the reforms and investments of the new RRP to be financed under

the Facility is not covered by existing or planned Union financing. This would warrant

a rating of B under criterion 2.9 of Annex V to Regulation (EU) 2021/241. Finally, the

estimated total cost of the new RRP is in line with the principle of cost-efficiency and

is commensurate to the expected national economic and social impact.

Protection of the financial interests of the Union

(55) In accordance with Article 19(3), point (j), of and Annex V, criterion 2.10, to

Regulation (EU) 2021/241, the arrangements proposed in the new RRP are adequate

(Rating A) to prevent, detect and correct corruption, fraud and conflicts of interests

when using the funds provided under that Regulation, and the arrangements are

expected to effectively avoid double funding under that Regulation and other Union

programmes. This is without prejudice to the application of other instruments and

tools to promote and enforce compliance with Union law, including for preventing,

EN 13 EN

detecting and correcting corruption, fraud and conflicts of interest, and for protecting

the Union budget in line with Regulation (EU, Euratom) 2020/2092 of the European

Parliament and of the Council6.

(56) In accordance with Article 20(5), point (e), of Regulation (EU) 2021/241, milestones

linked to the protection of the financial interests of the Union should be set out in

order to ensure compliance with Article 22 of that Regulation, through the

establishment of an adequate control system. The satisfactory fulfilment of those

milestones is expected to guarantee the adequacy of the internal control system, in

accordance with Article 19(3), point (j), of Regulation (EU) 2021/241. The control

system and arrangements proposed in the new RRP are based on robust processes and

structures, clearly identifying the roles and responsibilities of different bodies involved

in the implementation, monitoring, control and audit of the plan, as well as for their

interactions. These provide for a clear segregation of the implementation, control and

audit functions and responsibilities. The National Authority is responsible for the

overall coordination of the new RRP, for monitoring progress on milestones and

targets, for performing controls on implementing bodies, sub-granting bodies, the

body implementing financial instruments, financial intermediaries and final recipients,

and for the preparation and submission to the Commission of payment requests and

related management declarations based on verified data from the monitoring system.

The role of audit authority of the new RRP is assigned to the Directorate General for

the Audit of European Funds (EUTAF), which has the necessary administrative

experience and capacity to carry out the related audit tasks in line with internationally

accepted audit standards. EUTAF is responsible for performing system audits and

substantive testing of the implemented milestones and targets which serve as a basis

for the summary of audits submitted to the Commission with the payment requests.

The audit framework is further reinforced through dedicated milestones ensuring the

functional and budgetary independence of EUTAF, the adoption of a multi-annual

audit strategy covering system audits, risk-based sampling and on-the-spot

verifications, as well as requirements ensuring sufficient audit coverage of

implementing bodies and control systems and the issuance of an audit opinion on the

functioning of the repository system for monitoring the implementation of the new

RRP. This is ensured in particular through the following milestones: 75, 81, 83 and 84.

(57) The administrative capacity of the bodies charged with the implementation,

coordination, monitoring and control of the new RRP is expected to be adequate to

perform their envisaged roles and tasks. The National Authority may be supported by

implementing bodies, sub-granting bodies and the Hungarian Development Bank,

which have been entrusted with specific implementation tasks on the basis of their

expertise and administrative capacity. The increased implementation role of the

Hungarian Development Bank is accompanied by a dedicated reform to strengthen its

operational capacity, governance, transparency, internal control systems and oversight

arrangements. The National Authority is expected to supervise the work of the bodies

involved in implementation on a regular basis. In addition, regular controls related to

conflicts of interest are carried out by the Directorate of Internal Audit and Integrity

independently from the other control bodies, including reinforced rules on conflict-of-

interest prevention, detection and correction across all implementing entities and

6 Regulation (EU, Euratom) 2020/2092 of the European Parliament and of the Council of

16 December 2020 on a general regime of conditionality for the protection of the Union budget (OJ L

433 I, 22.12.2020, p. 1).

EN 14 EN

beneficiaries, and systematic verification of declarations and risk-based ex post

controls of operations. Further milestones are included to ensure the continued

application of the legal and institutional framework governing the management,

control and audit of the new RRP throughout the implementation period of the plan

and beyond 2026 including the establishment and maintenance of the legal framework

governing management, control and audit functions, ensuring continuity of safeguards,

and the reinforcement of oversight over implementing bodies and financial

intermediaries. Additional reforms strengthen the protection of the Union’s financial

interests, such as the establishment of an Integrity Authority and including through

enhanced transparency and access to beneficial ownership information for

management, control and audit purposes, the regular review of the anti-fraud, anti-

corruption strategy for the implementation, audit and control of Union support,

legislative measures ensuring the effective conduct of OLAF investigations and on-

the-spot checks and investigations, including the provision of national assistance and

effective sanctions in case of non-cooperation, together with reinforced operational

cooperation with OLAF through mandatory assistance obligations for competent

national authorities and improved follow-up of investigative findings, and Hungary’s

participation in the enhanced cooperation on the establishment of the European Public

Prosecutor’s Office (EPPO).The effectiveness of the anti-fraud and anti-corruption

framework is further reinforced through the systematic use of risk analysis and data-

mining tools, including mandatory data uploads, structured follow-up of identified

risks, and integration of risk-scoring outputs into decision-making processes,

supported by audit checks on the completeness and reliability of underlying data.

These institutional safeguards also include the establishment of an independent

internal audit and integrity function with investigative powers over conflicts of interest

and irregularities, complemented by whistleblowing channels and systematic

verification of declarations, as well as reinforced guarantees of the functional and

budgetary independence of the audit authority, ensuring multi-annual audit planning,

methodological autonomy and compliance with internationally accepted auditing

standards. This is ensured in particular through the following milestones:76, 77, 78,

79, 80, 82. Additionally, seven milestones are set to ensure in particular the

strengthening of the anti-corruption framework, the transparency of the use of and

oversight over public funds, including Union support (this is ensured through

milestones 54, 55, 57, 58, 59, 62 and 63). Three milestones are set to ensure the

increased transparency and competition in public procurement (this is ensured through

milestones 66, 68 and 69). Four milestones are set to strengthen judicial independence

which is a prerequisite for the functioning of an internal control system (this is ensured

through milestones 71, 72, 73 and 74).

(58) The Commission considers that overall, the internal control system of the new RRP is

adequate, taking also into account the 24 milestones related to the Hungarian control

system aiming at the protection of the financial interests of the Union that are a

precondition for any payment under Article 24 of Regulation (EU) 2021/241. Taking

into account that those milestones are designed to ensure the protection of the financial

interests of the Union and the establishment of an adequate control system, before any

payment under the Facility is authorised by the Commission, Hungary should fulfil all

milestones related to the control system7 before the submission of a payment request,

7 This is the case for milestones 54, 55, 57, 58, 59, 62, 63, 66, 68, 69, 71, 72, 73, 74, 75, 76, 77, 78, 79, 80, 81,

82, 83, 84.

EN 15 EN

and no payment under the Facility should be made before their fulfilment. A number

of these measures have been put forward by Hungary in the context of the procedure

under the Conditionality Regulation. The content of the related milestones and targets

is aligned with the commitments taken in that context. In addition, provisions have

been included to ensure the continued application of audit and control safeguards

beyond 2026. Furthermore, audit assurance is strengthened by the inclusion of specific

provisions related to strengthened ex post controls and audits, and the verification of

compliance with rules concerning fraud, corruption, conflicts of interest and double

funding.

Coherence of the new RRP

(59) In accordance with Article 19(3), point (k), of and Annex V, criterion 2.11, to

Regulation (EU) 2021/241, the new RRP includes to a high extent (Rating A)

measures for the implementation of reforms and public investment projects that

represent coherent actions.

(60) The new RRP is structured into 11 mutually coherent components, supporting the

strengthening of the economy, employment and social outcomes, and advancing the

green and digital transitions. The investments in Water and Circularity, Transport,

REPowerEU, and the voluntary contributions to the AI Gigafactory and IRIS²

programmes strengthen the plan’s consistency, ensuring that Hungary’s recovery

strategy remains aligned with its long-term priorities: the green and digital transitions,

energy security, and socio-economic resilience. The plan includes measures that create

multiplier effects, accelerating progress toward Hungary’s strategic goals. The

interplay between transport decarbonisation and grid development is expected to drive

systemic changes. The electrification of railway sections increases demand for clean

electricity, which is met by the modernisation of the grid which in turn supports the

expansion of Electric vehicles charging stations. The grid’s enhanced capacity and

flexibility (achieved through investments in smart grid storage facilities and

transmission upgrades) are essential to managing the additional load from the

electrified transport. The measures included further strengthen Hungary’s green and

digital transitions. Component 6 (Energy) and REPowerEU includes measures

targeting different segments of the energy system. While residential solar panel

support empowers households to generate their own renewable energy, onshore wind

development focus on large-scale renewable capacity and geothermal energy reforms

unlock potential for industrial and district heating. Grid development acts as a critical

complementary measure by ensuring that the transmission and distribution

infrastructure can accommodate the increased capacity and variability of these

renewable sources. Regarding the digital transformation the new voluntary

contributions to AI Gigafactory and IRIS² programmes strengthen high-performance

computing capabilities, while healthcare digitalisation modernises public service

delivery. Smart metering dissemination, another complementary measure, enhances

energy efficiency and grid management by providing real-time data on consumption.

This allows for better demand-side management, which is critical as Hungary’s grid

integrates more variable renewable energy sources. Together, these investments ensure

that key aspects of the digital transition, whether industrial, public, or infrastructural,

are supported.

Equality

EN 16 EN

(61) The new RRP integrates gender equality and equal opportunities as cross-cutting

priorities, aligning with Principle 2 (Gender Equality) and Principle 3 (Equal

Opportunities) of the European Pillar of Social Rights. The plan includes targeted

measures to reduce gender disparities in education, labour market participation, and

access to essential services. In early childhood education and care, the construction of

110 new crèche places (C1.I4) should support parents - particularly women - in

balancing work and family responsibilities, thereby enhancing female labour market

participation. The new RRP also promotes inclusive education through measures to

reduce school segregation (C1.R1) and support students with special educational needs

(C1.I2), ensuring equal access to quality education for all children, regardless of socio-

economic background.

Security self-assessment

(62) A security self-assessment has not been provided as it has not been considered

appropriate by Hungary, in accordance with Article 18(4), point (g), of Regulation

(EU) 2021/241. The investments in the new RRP cover the voluntary contribution to

AI Gigafactory and IRIS² programmes. The necessary security assurances should be

put in place as part of the execution of the respective programmes.

Cross-border and multi-country projects

(63) The new RRP has strong cross-border and multi-country dimension. The REPowerEU

chapter includes key reforms and investments incentivising the uptake of renewable

energy sources, strengthening flexibility markets and the resilience of the electricity

network and improving energy efficiency, thus contributing to the reduction of

reliance on fossil fuels. The electricity network development aims to support the

uptake of renewable energy and improve the consumer and producer electricity

connections. Coupled with the reforms incentivising energy storage, onshore wind

energy connection and the functioning of the flexibility market, this investment is a

critical measure fostering the resilience of the electricity network of the EU and

reducing reliance on fossil fuels. Lastly, the financial instrument supporting the energy

efficiency improvements of residential dwellings is an enabler to multiply the effect of

the aforementioned reforms and investment through reducing energy consumption of

households. The total estimated costs of these measures account for a total of

EUR 704,510,828, representing 100% of the estimated costs of the REPowerEU

chapter, exceeding the indicative target of 30%. The REPowerEU component plays a

pivotal role in addressing Hungary’s CSRs, specifically CSR 2022/5, CSR 2022/6, and

CSR 2023/4, by advancing energy efficiency, infrastructure modernisation, and cross-

border connectivity. A flagship project under this scheme is the electrification of the

Szeged–Röszke railway line, extending to Hungary’s border with Serbia, alongside the

construction of a new electrified delta track connecting railway lines 136 and 140.

These upgrades should enhance cross-border rail transport efficiency, reduce reliance

on fossil fuels, and align with the EU’s decarbonisation and sustainable mobility goals.

By modernising critical infrastructure, the project supports Hungary’s green transition,

strengthens regional economic ties, and improves logistics for both passenger and

freight services. The initiative reflects broader REPowerEU objectives, among which

accelerating energy independence, boosting renewable integration, and reinforcing

EU-wide transport resilience while addressing socio-economic disparities through

targeted energy and infrastructure investments. Hungary's contribution of

EUR 500 000 000 to the AI Gigafactory initiative has a clear cross-border dimension.

AI Gigafactories are Union-level strategic infrastructures designed to provide

EN 17 EN

European researchers, startups, and businesses across all Member States with access to

large-scale computing power and training capabilities for frontier AI models. The

benefits of the investment - in terms of shared AI capacity, open access to

supercomputing resources, and strengthening the EU's technological sovereignty – will

by design extend well beyond Hungary's borders. Finally, Hungary's contribution of

EUR 500 000 000 to the IRIS² constellation programme has an inherent cross-border

dimension. IRIS² infrastructure and benefits - including enhanced communications

resilience and reduced dependence on non-EU providers – will by design accrue

across all Member States, well beyond Hungary's borders.

Consultation process

(64) The reforms and investments included in the new RRP have undergone consultations

with stakeholders in accordance with the national legal framework. In particular

measures transferred from the previous RRP to the new RRP have been subject to

public consultation at the time of the submission of that plan. In addition, measures

and the investments transferred from other Union programmes to the new RRP have

been subject to further consultations before their respective calls were published.

Furthermore, the new measures included in Hungary’s new RRP were consulted with

stakeholders in the monitoring committee for the RRP and are in the process of further

consultations while being launched in accordance with the national framework.

Measures supporting investment operations contributing to the objectives of the Strategic

Technologies for Europe Platform (STEP)

(65) In accordance with Article 4(4) of Regulation (EU) 2024/795 of the European

Parliament and of the Council of 29 February 2024 establishing the Strategic

Technologies for Europe Platform (STEP), Hungary considered as a matter of priority

projects that have been awarded a Sovereignty Seal pursuant to Article 4(1) of

Regulation (EU) 2024/795. However, Hungary considered that no project having been

awarded a Sovereignty Seal was to be included in the new RRP because of insufficient

time to complete such project before the end date of the RRF.

Positive assessment

(66) Following the positive assessment of the Commission concerning the new RRP with

the finding that the new RRP satisfactorily complies with the criteria for assessment

set out in Regulation (EU) 2021/241, in accordance with Article 20(2) of and Annex V

to that Regulation, this Decision should set out the reforms and investment projects

necessary for the implementation of the new RRP, the relevant milestones, targets and

indicators, and the amount made available from the Union for the implementation of

the new RRP in the form of non-repayable financial and loan support.

Financial contribution

(67) The estimated total cost of the new RRP is EUR 10 000 000 000 which is equivalent

to HUF 3 553 302 225 000 on the basis of the average EUR HUF ECB reference rate

of 9 June 2026.Amounts in euros referred to in the descriptions of the measures and

the corresponding milestones and targets have been calculated on the same basis and

should be assessed taking this into account.

(68) As the new RRP satisfactorily complies with the criteria for assessment set out in

Regulation (EU) 2021/241 and, furthermore, as the amount of the estimated total costs

of the new RRP is higher than the maximum financial contribution available for

EN 18 EN

Hungary, the financial contribution allocated for Hungary's new RRP should be equal

to EUR 6 511 661 435.

(69) Furthermore, in order to support additional reforms and investments, a total loan

support of EUR 3 918 313 481 should be made available to Hungary. The amount of

the estimated total costs of the new RRP is lower than the combined financial

contribution available for Hungary and the loan support that had been made available

to Hungary. Therefore, the total loan support made available to Hungary should be

reduced to EUR 3 488 338 565. The maximum volume of the loan requested by

Hungary is less than 6.8% of its 2019 gross national income in current prices.

(70) The Council Implementing Decision of 15 December 2022 should therefore be

amended accordingly. For the sake of clarity, the Annex to the Council Implementing

Decision of 15 December 2022 should be replaced entirely.

(71) This Decision should be without prejudice to the outcome of any procedures relating

to the award of Union funds under any Union programme other than the Facility or to

procedures relating to distortions of the operation of the internal market that may be

undertaken, in particular under Articles 107 and 108 of the Treaty. It does not override

the requirement for Member States to notify instances of potential State aid to the

Commission under Article 108 of the Treaty,

HAS ADOPTED THIS DECISION:

Article 1

Approval of the assessment of the new RRP

The assessment of the new RRP of Hungary on the basis of the criteria provided for in Article

19(3) of Regulation (EU) 2021/241 is approved. The reforms and investment projects under

the new RRP, the arrangements and timetable for the monitoring and implementation of the

new RRP, including the relevant milestones and targets and the additional milestones and

targets related to the payment of the loan, the relevant indicators relating to the fulfilment of

the envisaged milestones and targets, and the arrangements for providing full access by the

Commission to the underlying relevant data are set out in the Annex to this Decision.

Article 2

The Council Implementing Decision of 15 December 2022 on the approval of the assessment

of the RRP for Hungary is amended as follows:

(1) in Article 2, paragraph 1 is replaced by the following:

“1. The Union shall make available to Hungary a financial contribution in the form of

non-repayable support amounting to EUR 6 511 661 435.”8

(2) in Article 2a, paragraph 1 is replaced by the following:

“1. The Union shall make available to Hungary a loan amounting to a maximum of

EUR 3 488 338 565.”

(3) the Annex is replaced by the text set out in the Annex to this Decision.

8 This amount corresponds to the financial allocation after deduction of Hungary’s proportional share of

the expenses referred to in Article 6(2) of Regulation (EU) 2021/241, calculated in accordance with the

methodology set out in Article 11 of that Regulation.

EN 19 EN

Article 3

Addressee

This Decision is addressed to Hungary.

Done at Brussels,

For the Council

The President

EN EN

EUROPEAN COMMISSION

Brussels, 19.6.2026

COM(2026) 316 final

ANNEX

ANNEX

to the

Proposal for a COUNCIL IMPLEMENTING DECISION

amending the Implementing Decision of 15 December 2022 on the approval of the

assessment of the recovery and resilience plan for Hungary

{SWD(2026) 171 final}

1

ANNEX

SECTION 1: REFORMS AND INVESTMENTS UNDER THE RECOVERY AND

RESILIENCE PLAN

1. Description of reforms and investments

A. COMPONENT 1: DEMOGRAPHY AND PUBLIC EDUCATION

This component of the Hungarian recovery and resilience plan addresses challenges related to the

inclusive access to quality school education, the labour market integration of vulnerable groups, and

broader demographic developments facing the Hungarian economy, public finances and society.

The main objectives of the component are to:

• improve access to quality school education by providing pupils and teachers with the devices

necessary to participate in modern digital education, and developing their digital skills;

• increase the participation of disadvantaged pupils and students with special education needs

in quality mainstream education;

• reduce the risk of segregation in schools;

• increase the attractiveness of the teaching profession and reinforce the skillset of teachers;

• improve access to early childhood education and care to reduce social inequalities and

facilitate labour market integration of vulnerable groups

The component includes measures reflecting principles of the European Pillar of Social Rights on

education, training and lifelong learning, on gender equality and on childcare and support to children.

The component also supports the digital transition by increasing the digital capacities in the public

education and by enhancing the digital skills of pupils and teachers. The focus on reducing

segregation in schools contributes to social cohesion. The component also contributes to the green

transition, as the planned infrastructure developments shall apply high standards of energy efficiency.

The component is in line with the Hungarian public education strategy prepared for the period 2021-

2030, the Hungarian National Energy and Climate Plan, the National Energy Strategy 2030 and the

National Clean Development Strategy.

The component contributes to addressing the Country Specific Recommendations on the need to

continue the labour market integration of the most vulnerable groups, in particular through upskilling

and to improve education outcomes and increase the participation of disadvantaged groups, in

particular Roma in quality mainstream education (Country Specific Recommendation 2 in 2019 and

Country Specific Recommendation 3 in 2022), contribute to women’s participation to the labour

market (County Specific Recommendation 4 in 2019), to focus investment-related economic policy

on energy and resource efficiency (Country Specific Recommendation 3 in 2019), to ensure access

to essential services and quality education for all (Country Specific Recommendation 2 in 2020), to

focus investment on the green and digital transition and digital infrastructure for schools (Country

Specific Recommendation 3 in 2019).

It is expected that no measure in this component does significant harm to environmental objectives

within the meaning of Article 17 of Regulation (EU) 2020/852, taking into account the description of

the measures and the mitigating steps set out in the recovery and resilience plan in accordance with

the DNSH Technical Guidance (2021/C58/01).

2

A.1. Description of the reforms and investments for non-repayable financial support

C1.I1: Development of competitive public education using 21st century technology

The objective of the measure is to support the digital transformation of public education by increasing

the availability of digital devices and tools in schools.

This measure consists in delivering digital devices to the school education institutions and to the

school administration centrum (Klebelsberg Központ).

C1.I2: Supporting the education of students with special education needs

The objective of the measure is to enhance the quality of specialised services for schools integrating

students with special education needs, those in long-term care, and those requiring specialised

pedagogical support.

This measure consists in providing specialised support services to public education institutions

integrating children and pupils with special education needs.

C1.R1: Reduction of segregation risk in schools

The objective of the reform is to enhance equal access to quality education and to reduce school

segregation.

The measure consists in the entry into force of legal acts(s) for the reduction of State support for

primary and lower secondary schools (grades 1 to 8) with a low proportion of disadvantaged students.

C1.R2: Increasing the attractiveness of the teaching profession

The objective of this measure is to increase the attractiveness of the teaching profession and to reduce

teacher shortages.

The measure consists in the entry into force of legal act(s) on gradually increasing teachers’ wages to

at least 80% of the average wage of tertiary graduates in 2025 and to be maintained at the same level

until at least 31 December 2031.

C1.I3: Construction of childcare facilities

The objective of the investment is to increase the availability of early childhood education services

by creating new crèche places.

This measure consists in the construction of childcare facilities.

C1.I4: Modernisation of school infrastructure

The objective of the investment is to increase capacities in the primary and secondary education by

upgrading school infrastructure and teaching equipment.

This measure consists in the construction and renovation of school facilities, and purchase and

installation of teaching equipment.

3

A.2. Milestones, targets, indicators, and timetable for monitoring and implementation for non-repayable financial support

Seq

Number

Related Measure

(Reform or

Investment)

Milestone/

Target Name

Qualitative

indicators

(for milestones)

Quantitative indicators

(for targets)

Indicative

timeline for

completion Description of each milestone and target

Unit of

measure Baseline Goal Quarter Year

1

C1.I1 Development of

competitive public

education using 21st

century technology

Milestone

Delivery of digital

notebooks and tools

Delivery of

equipment

Q2 2026

Delivery of 579 000 digital notebooks and 3 100

digital tools to the school education institutions or

to the school administration centrum (Klebelsberg

Központ).

2

C1.I2 Supporting the

education of students

with special education

needs

Milestone

Provision of support

services for the

education of children

with special education

needs

Award of

support Q2 2026

EUR 23.5 million awarded for projects in training

and knowledge sharing, school transportation

services, equipment rental, ICT and medical

equipment, adapted electric vehicles, and

payments made.

3

C1.R1 Reduction of

segregation risk in

schools

Milestone

Entry into force of legal

act(s) providing for the

reduction of State

support for primary and

lower secondary

schools with a low

proportion of

disadvantaged students

Provisions in

the legal act(s)

indicating its

entry into force

Q2 2026

Entry into force of legal act(s) for the reduction of

State support for primary and lower secondary

schools (grades 1 to 8) with a low proportion of

disadvantaged students.

The legal act(s) shall include provisions according

to which the State support for primary and lower

secondary schools is reduced by 10% if the

proportion of disadvantaged students in those

schools is more than 20 percentage points lower

than the average proportion in the settlement (at

local administrative unit level where the school is

located) as determined at the beginning of the

schoolyear 2025/2026.

4

C1.R2 Increasing the

attractiveness of the

teaching profession

Milestone

Entry into force of legal

act(s) to increase wages

of teachers in the public

education system

Provisions in

the legal act(s)

indicating its

entry into force

Q2 2026

Entry into force of legal act(s) setting out the

obligation that the average wage of teachers in the

public education system (all teachers in public

education system holding a tertiary degree as

defined in the Public Education Act, excluding

vocational education) shall reach at least 80% of

the average wage of tertiary graduates by 1

January 2025 and shall be maintained at a level of

4

Seq

Number

Related Measure

(Reform or

Investment)

Milestone/

Target Name

Qualitative

indicators

(for milestones)

Quantitative indicators

(for targets)

Indicative

timeline for

completion Description of each milestone and target

Unit of

measure Baseline Goal Quarter Year

at least 80% of the average wage of tertiary

graduates until at least 31 December 2031.

The law shall also include provisions according to

which, as of 1 January 2024 and until at least 31

December 2031, the wage of teachers in the

categories listed below shall be higher by at least

12.5 % of the wage of teachers with the same

qualification and experience not included in these

categories:

- teachers working in disadvantaged

settlements or catching up settlements as

defined by government decree;

- teachers working in schools with a

proportion of disadvantaged pupils of at

least 10% and defining special pedagogical

methods for inclusive education in their

pedagogical programmes (source:

Köznevelési Információs Rendszer).

5 C1.I3 Construction of

childcare facilities Target

Constructed childcare

facilities Number 0 110 Q2 2026

Launch of call(s)/tender(s) for the construction of

110 childcare facilities. The conditions of the

tender(s)/call(s) for applications shall ensure that

the primary energy demand of any new buildings

is at least 20% lower than the nearly zero-energy

building requirement as set out in national

legislation. Construction of 110 childcare

facilities.

6 C1.I4 Modernisation of

school infrastructure Milestone

Construction and

renovation of school

facilities

Disbursement of

funds Q2 2026

Disbursement of EUR 152 million of funds for

investments in school infrastructure and teaching

equipment.

5

B. COMPONENT 2: HIGHLY QUALIFIED, COMPETITIVE WORKFORCE

This component of the Hungarian recovery and resilience plan contributes to the modernisation of

the vocational and higher education systems. It addresses the challenges of the green and digital

transition by implementing energy efficiency renovation and digital equipment solutions in buildings

in higher and vocational education institutions. The component also addresses challenges related to

skills development and levels of research and innovation by incentivising business-academia research

projects. The measures in this component are important for the recovery of the economy and for

enhancing future crisis resilience.

The central objective of this component is to strengthen the labour force and related training

institutions in light of current and possible new crises, and to improve the socio-economic

environment of Hungary. To this end, the component aims to (i) create a competitive higher education

system; (ii) contribute to increasing the availability of skilled workers; and (iii) support an ecosystem

for science, innovation and training.

The component supports addressing the Country Specific Recommendations on promoting

investment and reform on research and innovation, and green and digital skills (Country Specific

Recommendation 5 in 2022); on focusing investment on the green and digital transitions and on the

digital infrastructure of schools (Country Specific Recommendation 2 in 2020); and on focusing

investment-related economic policy on research and innovation (Country-Specific Recommendation

3 in 2019).

It is expected that no measure in this component does significant harm to environmental objectives

within the meaning of Article 17 of Regulation (EU) 2020/852, taking into account the description of

the measures and the mitigating steps set out in the recovery and resilience plan in accordance with

the DNSH Technical Guidance (2021/C58/01).

B.1. Description of the reforms and investments for non-repayable financial support

C2.R1: Modernisation of higher education courses

The objective of this measure is to modernise higher education by including more practice-oriented

elements in the programmes.

This measure consists in the revision of higher education programmes to introduce practice-oriented

elements and the amendment of selected related regulations.

C2.I1: Institutional innovation in higher education

The objective of this measure is to develop digital learning content.

This measure consists in developing digital learning content.

C2.I2: Digitalization and modernisation of higher education infrastructure

The objective of this measure is to increase the attractiveness of higher education institutions and

support the green and digital transition through modernised infrastructure and digitalisation.

This measure consists in:

i) energy efficiency refurbishment of higher education institutions, achieving at least 30%

primary energy savings.

ii) the construction of new buildings for higher education institutions, which shall have a primary

energy demand of at least 20% below the nearly zero-energy buildings requirement.

iii) purchase and delivery of digital equipment in higher education institutions.

6

C2.I3: Vocational education and training infrastructure for the 21st century

The objective of the investment is to improve digitalisation and energy efficiency of selected

vocational training centres.

This measure consists in: (i) energy efficiency renovation and/or construction of new buildings, and

(ii) purchase and delivery of ICT equipment to selected vocational education and training centres.

C2.I4: Development of the Central Examination Centre

The objective of this measure is to develop a central examination centre in Budapest promoting high-

quality professional examinations.

This investment consists in the renovation and purchase and delivery of equipment for the Central

Examination Centre.

C2.I5: Support for research and development

The objective of the investment is to strengthen the innovation ecosystem in the country by supporting

research and development activities in the areas of safe society and environment; health; industry and

digitalisation.

The measure consists of the provision of financial support to research entities.

7

B.2. Milestones, targets, indicators, and timetable for monitoring and implementation for non-repayable financial support

Sequential

Number

Related Measure

(Reform or

Investment)

Milestone/

Target Name

Qualitative

indicators

(for milestones)

Quantitative indicators

(for targets)

Indicative

timeline for

completion Description of each milestone and target

Unit of measure Baseline Goal Quarter Year

7

C2.R1

Modernisation of

higher education

programmes

Milestone Revision of higher

education programmes Revised programmes Q2 2026

Revision of 15 higher education programmes to

introduce practice-oriented elements and amend

related regulations.

8

C2.I1 Institutional

innovation in

higher education

Milestone

Digital learning

materials accessible in

higher educations

Digital learning

materials accessible in

higher educations

Q2 2026

At least 1 000 digital learning materials (e.g.,

textbooks, research studies, and other

educational resources) are developed in higher

education institutions.

9

C2.I2

Digitalization and

modernisation of

higher education

infrastructure

Milestone

Energy efficiency

refurbishment of

building infrastructure

and construction of new

buildings in higher

education institutions

Higher education

institutions

renovated/constructed

Q2 2026

Launch of a call for projects regarding 1)

energy efficiency renovation, 2) construction of

new buildings, 3) purchase and installation of

digital equipment in higher education

institutions.

The requirements in the call documentation

shall ensure non-discrimination among

Hungarian higher education institutions,

including based on their ownership structure.

Public trust funds shall not be eligible as

recipients under the call.

Renovation and/or construction of

25 145 square meters of buildings in higher

education institutions and purchase and

delivery of 22 300 ICT equipment for higher

education institutions.

Newly constructed buildings shall have a

primary energy demand that is at least 20%

lower than nearly zero-energy building

requirement. Energy efficiency renovations

shall achieve, on average, at least a 30%

reduction of direct and indirect GhG emissions

compared to ex ante emissions.

8

Sequential

Number

Related Measure

(Reform or

Investment)

Milestone/

Target Name

Qualitative

indicators

(for milestones)

Quantitative indicators

(for targets)

Indicative

timeline for

completion Description of each milestone and target

Unit of measure Baseline Goal Quarter Year

10

C2.I3 Vocational

education and

training

infrastructure for

the 21st century

Target

Vocational education

and training centres

equipped and with

upgraded infrastructure

Number 0 18 Q2 2026

Renovation and/or construction of 57 000

square meters and purchase and delivery of

1 150 ICT equipment.

These centres shall achieve on average at least

30 % reduction of direct and indirect

greenhouse gas emissions or at least 30%

primary energy savings.

11

C2.I4 Development

of the Central

Examination

Centre

Milestone

Refurbishment of the

Central Examination

Centre

Refurbishment of the

Central Examination

Centre

Q2 2026

Renovation of the Central Examination

Centre’s building and purchase and delivery of

ICT and production simulation equipment.

The energy efficiency renovation shall reach at

least 30% primary energy savings or at least

30% reduction in greenhouse gas emissions.

12

C2.I5 Support for

research and

development

Target Support research

entities Number 0 14 Q2 2026

Signature of 14 grant agreements with research

entities.

9

C. COMPONENT 3: CATCHING UP SETTLEMENTS

This component of the Hungarian recovery and resilience plan addresses the socio-economic and

territorial challenges that have been amplified by the COVID-19 pandemic, particularly in the poorest

settlements, and tackles issues such as the lack of access to the labour market and public services, the

shortage of primary care professionals and more generally poverty.

The main objective of this component is to provide basic services for the inhabitants of the 300 most

disadvantaged settlements in Hungary (as defined by the Government Decision 1404/2019 (VII.05.)

and the Government Decision 1057/2021. (II.19.)) through an integrated social policy intervention.

The scope of measures in this component is an integral part of the wider Catching up Settlements

Programme. The component contributes to the principle 20 on access to essential services of the

European Pillar of Social Rights.

To this end, the component aims to (i) establish social solar power plants; (ii) promote employment

and skills development based on local specificities and the strengthening of the local economic

culture; and (iii) achieve better learning outcomes through community-oriented pedagogy.

The component shall contribute to addressing the Country Specific Recommendations on improving

the adequacy of social assistance and ensure access to essential services, quality education (Country

Specific Recommendations 2 in 2020 and 3 in 2022), on ensuring labour market integration of the

most vulnerable groups (Country Specific Recommendations 2 in 2019 and 3 in 2022), and on making

investments focused on the green and digital transitions (Country Specific Recommendations 3 in

2020 and 6 in 2022).

It is expected that no measure in this component does significant harm to environmental objectives

within the meaning of Article 17 of Regulation (EU) 2020/852, taking into account the description of

the measures and the mitigating steps set out in the recovery and resilience plan in accordance with

the DNSH Technical Guidance (2021/C58/01).

C.1. Description of the reforms and investments for non-repayable financial support

C3.I1: Production and use of renewable energy in disadvantaged municipalities

The objective of this measure is to reduce energy poverty in municipalities selected under the

Catching up Settlements Programme through renewable energy production.

This measure consists in the installation of photovoltaic capacity to subsidise electricity needs of

households living in municipalities selected under the Catching up Settlements Programme.

C3.I2: Promoting employment and skills development based on local specificities

The objective of this measure is to develop employability of people living in municipalities selected

under the Catching-up Settlements Programme.

This measure consists in the support of participation in labour socialisation programmes.

C3.I3: Community-oriented pedagogy

The objective of the measure is to provide pupils targeted support in municipalities selected under

the Catching up Settlements Programme.

The measure consists in the participation of public education institutions in inclusive pedagogical

development.

10

C.2. Milestones, targets, indicators, and timetable for monitoring and implementation for non-repayable financial support

Seque

ntial

Numb

er

Related Measure

(Reform or Investment)

Milestone

/Target Name

Qualitative

indicators

(for

milestones)

Quantitative indicators

(for targets)

Indicative

timeline for

completion Description of each milestone and target

Unit of

measure Baseline Goal Quarter Year

13

C3.I1 Production and use

of renewable energy in

disadvantaged

municipalities

Target

Installation of

renewable energy

production capacity

for the benefit of

households from

municipalities

selected under the

Catching up

Settlements

Programme

kWp 0 15 000 Q2 2026

Installation of photovoltaic power plants with a total

capacity of at least 15 000 kWp.

Grant awards issued for 1 500 beneficiaries from

municipalities selected under the Catching up Settlements

programme to subsidise annual electricity costs.

14

C3.I2 Promoting

employment and skills

development based on

local specificities

Target

Participation in

labour socialisation

programmes

Number 0 7 000 Q2 2026

At least 7 000 people from municipalities selected under

the Catching up Settlements Programme have participated

in labour socialisation programmes, for example

workshops, training, mentoring or labour personalised

services.

15 C3.I3 Community-

oriented pedagogy Target

Pedagogical

development of

public education or

vocational training

institutions

Number 0 60 Q2 2026

Participation of at least 60 public education or vocational

training institutions from municipalities selected under the

Catching up Settlements Programme in inclusive,

community oriented pedagogical development

programmes, for example social diagnoses for public

education institutions, extended school programmes and

career guidance methods for teachers.

11

D. COMPONENT 4: WATER MANAGEMENT AND CIRCULAR ECONOMY

This component of the Hungarian recovery and resilience plan aims at addressing the challenges that

Hungary faces with water management and with its transition to a circular economy.

Water scarcity has a detrimental effect on the status of water bodies, ecosystems and agricultural

lands. The objective of this component is to contribute to introducing solutions in the field of water

management through the establishment of an action plan and water retention measures.

The measures under circular economy contribute to a more developed waste management system in

Hungary. This requires establishing the main legislative and procedural requirements for preparing

the Hungarian economy to the transition to the circular economy, accompanied by awareness raising

activities on waste recycling. The objectives of this component are consistent with the EU Waste

Management Framework.

The component contributes to addressing the Country Specific Recommendations to focus

investment-related economic policy on sustainable water management (Country Specific

Recommendation 3 in 2020, and Country Specific Recommendation 5 in 2022). In addition, this

component contributes to addressing the Country Specific Recommendations to promote reform on

sustainable waste management and the circularity of the economy (Country Specific

Recommendation 5 in 2022).

It is expected that no measure in this component does significant harm to environmental objectives

within the meaning of Article 17 of Regulation (EU) 2020/852, taking into account the description of

the measures and the mitigating steps set out in the recovery and resilience plan in accordance with

the DNSH Technical Guidance (2021/C58/01).

D.1. Description of the reforms and investments for non-repayable financial support

C4.R1: Awareness raising - water

The objective of the reform is to set a climate-resilient and sustainable water management framework

by aligning water use with available water resources and climate change projections.

The measure consists of the adoption of an action plan on sustainable water management and the

delivery of controlled water retention interventions.

C4.I1: Nature protection

The objective of this investment is to improve the water quality and ecological status of the

(Soroksári)-Danube branch by constructing and putting into operation the new Kvassay pumping

station and its associated infrastructure and ensure reliable, climate-resilient water supply.

The measure consists of completing the Danube-side suction structure of the new pumping station,

installing four propeller pumps with their mechanical and electrical equipment, and establishing the

high-voltage power supply and control system.

C4.R2: Domestic regulation of the transition to a circular economy

The objective of this measure is to create a sound legal framework for the transition to a circular

economy.

The measure consists of the entry into force of the amendments to the legal framework with a view

to creating an enabling environment for waste management in Hungary.

C4.R3: Action plan for local awareness raising activities

The objective of the measure is to raise the awareness of the population on waste recycling.

The reform consists in the adoption of a national communication action plan which informs the

general public regarding the higher levels of waste hierarchy.

12

D.2. Milestones, targets, indicators, and timetable for monitoring and implementation for non-repayable financial support

Sequential

Number

Related

Measure

(Reform or

Investment)

Milestone

/Target Name

Qualitative

indicators

(for

milestones)

Quantitative indicators

(for targets)

Indicative

timeline for

completion Description of each milestone and target

Unit of

measure Baseline Goal Quarter Year

16

C4.R1

Awareness-

raising - water

Milestone

Adoption of an

action plan on

sustainable water

management s

The action

plan on

sustainable

water

management

is adopted

Q2 2026

An action plan on sustainable water management has been

adopted by the Government, setting out measures,

responsibilities and timelines to:

- align water use with available water resources and

climate change projections, including reducing flood

and drought impacts and ensuring long-term water

resilience.

- prioritise nature-based solutions and natural water

retention measures, including their integration into

river basin management plans and land-use planning

- increase water-use efficiency including reduction of

losses and promotion of circular water use and

sustainable urban stormwater management

- develop green skills in the water sector and related

fields through targeted training and upskilling

measures also at local level

- develop monitoring and evaluation framework for

assessing the quantitative and qualitative status of

groundwater bodies and the impact of water

retention measures.

- estimate financial needs

- prepare recommendations for future legislative

changes needed to implement the action plan, based

on structured involvement of stakeholders.

In addition to the adoption of the Action plan,

communication activities shall be delivered on sustainable

water management.

17

C4.R1

Awareness-

raising - water

Target Number of

hectares of water

Number of

hectares 0 18 000 Q2 2026 At least 18 000 ha of agricultural land have been involved

in the “Water to Landscape” programme, where controlled

13

Sequential

Number

Related

Measure

(Reform or

Investment)

Milestone

/Target Name

Qualitative

indicators

(for

milestones)

Quantitative indicators

(for targets)

Indicative

timeline for

completion Description of each milestone and target

Unit of

measure Baseline Goal Quarter Year

retention

interventions

water retention interventions shall be either carried out or

assessed feasible by the water authority.

18 C4.I1 Nature

protection Milestone

Delivery of the

Kvassay pumping

station – Phase 2

Entry into

operation of

the Kvassay

pumping

station

Q2 2026

Entry into operation of the Danube-side suction structure,

the four propeller pumps together with their mechanical

and electrical equipment, the high-voltage power supply

system, and the control system, forming the second phase

of the Kvassay pumping station project. Delivery of an

environmental screening.

19

C4.R2 Domestic

regulation of the

transition to a

circular

economy

Milestone

Entry into force of

the legal act(s)

necessary to

operationalise

waste

management

practice and

adoption a

national waste

management plan

Provision in

the legal acts

indicating the

respective

entry into

force and

adoption of a

national waste

management

plan

Q2 2026

Entry into force of legal act(s) regulating the following

elements respectively:

- The establishment of, and rules governing the

deposit system for beverage bottles;

- The reduction of environmental impact of certain

plastic products (including measures concerning

single-use plastic products);

- Rules of the extended producer responsibility;

- The removal of abandoned waste from immovable

property and of transport to waste treatment place.

Adoption of a national waste management plan

establishing a framework for transitioning to a circular

economy and preventing waste.

20

C4.R3: Action

plan for local

awareness

raising activities

Milestone

Adoption of a

national

communication

action plan

Adoption of a

national

communicatio

n action plan

Q2 2026

Adoption of the national communication action plan

providing a communication framework to inform the

general public about higher levels of waste hierarchy.

14

E. COMPONENT 5: SUSTAINABLE GREEN TRANSPORT

This component of the Hungarian recovery and resilience plan addresses the need to strengthen the

contribution of the transport sector to the reduction of greenhouse gas and pollutant emissions, to

speed up the modernisation of the transport network and rolling stock, to increase the attractiveness

of sustainable transport modes, in particular public transport, and to improve social and territorial

cohesion.

The objective of this component is to promote sustainable mobility, strengthen low-carbon public

transport, reduce negative externalities of transport (in particular congestion and emissions) and

provide accessible modes of transport, mostly through a strengthening of public transport

infrastructure and vehicles. The measures of this component are expected to lead to a reduction of

emissions due to transport by encouraging the use of environmentally friendly urban and suburban

modes of transport and more generally by strengthening alternatives to individual cars. Public

transport is expected to be made more attractive, which would lead to more users shifting from private

car to public transport. More robust railway infrastructure is also expected to facilitate modal shift of

freight. To this end, this component shall consist of reforms and investments that promote sustainable

transport through the modernisation of important railways lines, the purchase of zero emission buses

and trams for public transport, improvements to the oversight on railway market and the introduction

of legislation relating to tariffs for public transport. The component also includes the establishment

of a Rolling Stock Company (ROSCO) to catalyse the renewal of Hungary’s rolling stock and to

create the basis for a more efficient management of railway services.

The component contributes to addressing the Country Specific Recommendations on focusing

investment-related economic policy on transport infrastructure, taking into account regional

disparities, and on focusing investment on the green transition, in particular sustainable transport

(Country Specific Recommendation 3 in 2019 and 2020) and on the reduction of the dependency on

fossil fuels in transport by stepping up efforts on energy efficiency, in particular through

electrification (Country Specific Recommendation 6 in 2022).

It is expected that no measure in this component does significant harm to environmental objectives

within the meaning of Article 17 of Regulation (EU) 2020/852, taking into account the description of

the measures and the mitigating steps set out in the plan in accordance with the DNSH Technical

Guidance (2021/C58/01).

E.1. Description of the reforms and investments for non-repayable financial support

C5.I1: Development of a suburban railway line

The objective of the measure is to channel traffic towards low CO2 emission modes. The measure

consists of works on a railway section.

C5.I2: Rail network congestion switching on TEN-T corridor

The objective of the measure is to channel traffic towards low CO2 emission modes and to improve

the use of long-distance freight and passenger transport. The measure consists of works on a railway

section.

C5.I3: Development of zero-emission bus transport

The objective of the measure is to renew and decarbonise the public transport fleet in Hungary through

the provision of zero-emission buses.

The measure consists in the delivery of 187 zero-emission/electric buses.

C5.I4: Development of tram and trolleybus system

The objective of the measure is to improve the transportation infrastructure.

The measure consists in the handover or production of trams and delivery of trolleybuses.

15

C5.I5: Works on railway section

The objective of the measure is to electrify railway sections.

The measure consists in (re)construction works related to the railway section “Szeged-Rendező -

Röszke – Border of the country” and the connection of railway lines 136 and 140.

C5.I6: Boosting companies’ uptake of electric vehicles (EVs)

The objective of this measure is to increase companies’ uptake of electric vehicles by providing

financial support in the form of grants.

The measure consists in financial support to companies for the purchase of at least 10 000 electric

vehicles.

C5.I7: Setting up a financial instrument to increase the rollout of charging stations for electric

vehicles (EVs)

The measure shall consist in a public investment in a Facility, in order to incentivise private

investment and improve access to finance in Hungary’s electric mobility sector by developing the

charging infrastructure for electric vehicles. The Facility shall operate by providing combined loan

and grant support directly to the private sector, as well as to public sector entities engaged in similar

activities.

The Facility shall be managed by the Hungarian Development Bank (Magyar Fejlesztési Bank Zrt. –

MFB) as the Implementing Partner. The Facility shall include the following product line:

• Combined loan and grant support for the installation of charging stations. The share of grants

and loans shall be decided based on the following criteria:

o the regional state aid map, as included in Art. 36a of the General block exemption

regulation (GBER);

o the size of the company applying to the Facility. Namely, the smaller the company is,

the higher shall be the share of grant support;

o the heavy-duty vehicles (HDV) charging stations to be installed by final beneficiaries.

In particular, the higher is the HDV stations’ ratio, the higher shall be the share of

grant support.

In order to implement the investment into the Facility, Hungary and the MFB shall sign an

Implementing Agreement that shall include the following content:

1. Description of the decision-making process of the Facility: The initial investment decision of the

Facility shall be taken by an investment committee or other equivalent governing body and

approved by a majority of votes from members who are independent from the government. The

final investment decision of the Facility shall be limited to the approval (without modifications)

or the exercise of a veto right on an investment decision proposed by the investment committee

or equivalent governing body.

2. Key requirements of the associated investment policy,which shall include:

a. The description of the financial product and eligible final beneficiaries.

b. The requirement that all investments supported are economically viable.

c. The requirement to comply with the ‘do no significant harm’ (DNSH) principle as set out

in the DNSH Technical Guidance (2021/C58/01). In particular, the investment policy shall

exclude the following list of activities and assets from eligibility: (i) activities and assets

16

related to fossil fuels, including downstream use1, (ii) activities and assets under the EU

Emissions Trading System (ETS) achieving projected greenhouse gas emissions that are

not lower than the applicable benchmarks2, (iii) activities and assets related to waste

landfills, incinerators3 and mechanical biological treatment plants4.

d. The requirement that final beneficiaries of the Facility shall not receive support from other

Union instruments to cover the same cost.

3. The amount covered by the Implementing Agreement, the fee structure for the Implementing

Partner and the requirement to reinvest any reflows according to the investment policy of the

Facility.

4. Monitoring, audit, and control requirements, including:

1. The description of the Implementing Partner’s monitoring system to report on the

investment mobilized.

2. The description of the Implementing Partner’s procedures that will ensure the

prevention, detection and correction of fraud, corruption, and conflicts of interests.

3. The obligation to verify the eligibility of every operation in accordance with the

requirements laid out in the Implementing Agreement before committing to finance

an operation.

4. The obligation of carrying out risk-based ex-post audits in accordance with an audit

plan of the MFB. These audits shall verify i) that the control systems are effective,

including the detection of fraud, corruption, and conflict of interests; ii) compliance

with the DNSH principle, the State Aid rules, the climate target requirements; and

iii) that the requirement that final beneficiaries of the Facility have not received

support from other Union instruments to cover the same cost is respected. The audits

shall also verify the legality of the transactions and that the conditions of the applicable

Implementing Agreement are being respected.

5. Requirements for climate investments carried out by the Implementing Partner: At least

EUR 19 418 569 of the RRF investment into the Facility shall contribute to the climate change

objectives in accordance with Annex VI to the RRF Regulation.

1Except for (a) assets and activities in power and/or heat generation, as well as related transmission and distribution infrastructure,

using natural gas, that are compliant with the conditions set out in Annex III of the ‘do no significant harm’ Technical Guidance

(2021/C58/01) and (b) activities and assets under point (ii) for which the use of fossil fuels is temporary and technically unavoidable

for the timely transition towards a fossil fuel free operation. 2 Where the activity supported achieves projected greenhouse gas emissions that are not significantly lower than the relevant

benchmarks, an explanation of the reasons why this is not possible shall be provided. Benchmarks established for free allocation for

activities falling within the scope of the Emissions Trading System, as set out in the Commission Implementing Regulation (EU)

2021/447. 3 This exclusion does not apply to actions under this measure in plants exclusively dedicated to treating non-recyclable hazardous

waste, and to existing plants, where the actions under this measure are for the purpose of increasing energy efficiency, capturing exhaust

gases for storage or use or recovering materials from incineration ashes, provided such actions under this measure do not result in an

increase of the plants’ waste processing capacity or in an extension of the lifetime of the plants; for which evidence is provided at plant

level. 4This exclusion does not apply to actions under this measure in existing mechanical biological treatment plants, where the actions

under this measure are for the purpose of increasing energy efficiency or retrofitting to recycling operations of separated waste to

compost bio-waste and anaerobic digestion of bio-waste, provided such actions under this measure do not result in an increase of the

plants’ waste processing capacity or in an extension of the lifetime of the plants; for which evidence is provided at plant level.

17

C5.R1: Tariff reform

The objective of this measure is to encourage the use of public transport.

The measure consists in the entry into force of legal act(s) relating to travel discounts on public

passenger transport.

18

E.2. Milestones, targets, indicators, and timetable for monitoring and implementation for non-repayable financial support

Sequential

Number

Related Measure

(Reform or

Investment)

Milestone/

Target Name

Qualitative

indicators

(for

milestones)

Quantitative indicators (for targets)

Indicative

timeline for

completion Description of each milestone and target

Unit of

measure Baseline Goal Quarter Year

21

C5.I1

Development of a

suburban railway

line

Milestone

Works related to the

Debrecen-

Balmazújváros

railway section

Handover and

acceptance

protocol(s)

Q2 2026

Technical handover and acceptance

protocol(s) for (re)construction works on the

railway infrastructure between Debrecen and

Balmazújváros.

22

C5.I2 Rail

network

congestion

switching on TEN-

T corridor

Milestone

Works related to the

Békéscsaba-

Lőkösháza railway

section

Handover and

acceptance

protocol(s)

Q2 2026

Technical handover and acceptance

protocol(s) for (re)construction works on the

railway infrastructure between Békéscsaba

and Lőkösháza.

23

C5.I3

Development of

zero-emission bus

transport

Target

Delivery of zero

emission/electric

buses

Number 0 187 Q2 2026 Delivery of 187 zero-emission/electric buses.

24

C5.I4

Development of

tram and

trolleybus system

Milestone Trams

Technical

handover

protocol(s)/pro

duction

report(s)

Q2 2026 Technical handover protocol(s) for 41 trams

and production report(s) for 4 trams.

25

C5.I4

Development of

tram and

trolleybus system

Milestone Trolleybuses

Technical

handover

protocol(s)

Q2 2026 Technical handover protocol(s) for 48

trolleybuses.

26 C5.I5: Works on

railway section Milestone

Works related to the

Szeged-Rendező -

Röszke – Border of

the country railway

section

Technical

handover

protocol(s)

Q2 2026

Technical handover protocol(s) for

(re)construction works related to the railway

section “Szeged-Rendező - Röszke – Border

of the country” and the connection of railway

lines 136 and 140.

27

C5.I6: Boosting

the companies’

uptake of electric

vehicles (EVs)

Target

Financial support for

the purchase of

electric vehicles

Number 0 10 000 Q2 2026 Disbursement of funds to companies for the

purchase of at least 10 000 electric vehicles.

19

Sequential

Number

Related Measure

(Reform or

Investment)

Milestone/

Target Name

Qualitative

indicators

(for

milestones)

Quantitative indicators (for targets)

Indicative

timeline for

completion Description of each milestone and target

Unit of

measure Baseline Goal Quarter Year

28

C5.I7: Setting up a

financial

instrument to

increase the rollout

of charging

stations for electric

vehicles (EVs)

Milestone Implementing

Agreement

Entry into

force of the

Implementing

Agreement

Q2 2026 Entry into force of the Implementing

Agreement.

29

C5.I7: Setting up a

financial

instrument to

increase the rollout

of charging

stations for electric

vehicles (EVs)

Target

Legal agreements

signed with final

beneficiaries

% 0 100 Q2 2026

The MFB shall have entered into legal

financing agreements with final beneficiaries

for an amount necessary to use 100% of the

RRF investment into the Facility (taking into

account management fees). 100% of this

financing shall contribute to climate

objectives using the methodology in Annex VI

to the RRF Regulation.

30

C5.I7: Setting up a

financial

instrument to

increase the rollout

of charging

stations for electric

vehicles (EVs)

Milestone

Ministry has

completed the

investment

Certificate of

transfer Q2 2026

Hungary shall transfer at least

EUR 19 418 569 o the MFB for the Facility.

31 C5.R1 Tariff

reform Milestone

Entry into force of

legal act(s) related to

tariffs

Provision in

the legal act(s)

indicating

entry into

force

Q2 2026 Entry into force of legal act(s) relating to

travel discounts on public passenger transport.

20

E.3. Description of the reforms and investments for the loan

C5.I8: Equity injection into a newly created Rolling Stock Company “ROSCO”

This measure aims at supporting the growth potential of the Hungarian economy by structurally

adjusting the level of public support available to address market failures and inefficiencies within the

economy. The measure shall consist of an equity injection of EUR 1 800 000 000 into the Rolling

Stock Company (ROSCO).

The satisfactory fulfilment of milestones under this measure is subject to the satisfactory fulfilment

of the milestones of reform C5.R2.

C5.R2: Reform of railway services in Hungary

The objective of this measure is to contribute to an improvement of the railway market in Hungary.

It consists in the entry into force of legal act(s) on the establishment of the National Public Transport

Authority (NPTA) and of the Rolling Stock Company (ROSCO).

21

E.4. Milestones, targets, indicators, and timetable for monitoring and implementation for loan support

Sequential

Number

Related Measure

(Reform or

Investment)

Milestone/

Target Name

Qualitative

indicators

(for

milestones)

Quantitative indicators (for

targets)

Indicative

timeline for

completion Description of each milestone and target

Unit of

measure Baseline Goal Quarter Year

32

C5.I8: Equity

injection into a

newly created

Rolling Stock

Company

“ROSCO”

Milestone Equity injection into

the ROSCO

Certificate of

transfer Q2 2026

Hungary shall transfer EUR 1 800 000 000 to

the ROSCO to increase its equity.

33

C5.R2 Reform of

railway services in

Hungary

Milestone

Set-up of the

National Public

Transport Authority

Provision in

the legal act(s)

indicating the

establishment

and entry into

operation of

the National

Public

Transport

Authority

Q2 2026

Entry into force of legal act(s) that establishes the

National Public Transport Authority (NPTA) as a

permanent public body under the Ministry of

Transport.

The legislation shall explicitly define the NPTA's

legal status, governance structure, mandate, and

powers, and shall clearly delimit the respective

roles of the NPTA and ROSCO. In particular, the

legislation shall clarify that the NPTA manages

the public service contracts with railway

operators as well as the tendering process, while

the ROSCO manages the procurement of rolling

stock and their lease.

The legislation shall moreover specify

information-sharing obligations between the two

bodies.

The legislation shall moreover:

On tendering: empower NPTA to impose public

service obligations (PSO) and competitively

tender Public Service Contract packages in

compliance with Regulation (EC) 1370/2007.

The legislation shall mandate NPTA to divide the

network under PSO into contestable lots and to

adopt a multi-year tendering programme for these

22

Sequential

Number

Related Measure

(Reform or

Investment)

Milestone/

Target Name

Qualitative

indicators

(for

milestones)

Quantitative indicators (for

targets)

Indicative

timeline for

completion Description of each milestone and target

Unit of

measure Baseline Goal Quarter Year

lots, specifying which lots are subject to

competitive tender with priority.

On planning and passenger information:

designate the NPTA as the competent authority

for public transport planning, and passenger

information, and shall specify the functions to be

unified under its authority (including ticketing

interoperability standards and real-time

passenger information systems).

34

C5.R2 Reform of

railway services in

Hungary

Milestone Set-up up of the

ROSCO

Provision in

the legal act

indicating the

establishment

and entry into

operation of

the ROSCO

Q2 2026

1) Entry into force of legal act(s) that establishes

a new permanent wholly state-owned entity

(Rolling Stock Company – ROSCO) in the form

of a joint stock company.

The legislation shall:

i. set forth the mission, mandate, and powers of

such company so to increase competition in

the tenders and the contestability of the service

contracts. In particular, the legislation shall

ensure that rolling stock is available to

incoming PSO operators under fair equal and

non-discriminatory conditions with

standardized operative maintenance

requirements.

ii. State that the rolling stock to be procured by the

ROSCO will be the property of the ROSCO.

iii. Set forth the general principles of corporate

governance and organisational structure.

iv. Establish that the members of the board and

statutory bodies of the company shall:

a) be selected from among individuals who

meet the requirements of integrity,

professionalism, and independence;

b) have the necessary authority,

competencies and objectivity to carry out

23

Sequential

Number

Related Measure

(Reform or

Investment)

Milestone/

Target Name

Qualitative

indicators

(for

milestones)

Quantitative indicators (for

targets)

Indicative

timeline for

completion Description of each milestone and target

Unit of

measure Baseline Goal Quarter Year

their functions of strategic guidance, risk

management oversight, and monitoring of

management,

c) act with and promote integrity,

d) be held accountable for their actions,

v. set out rules on the prevention of conflicts of

interest.

2) Incorporation of the ROSCO and entry in the

commercial register.

3) Publication and approval by the Ministry of

Transport of the Corporate Charter (Statute) of

the RoSCo, which shall specify:

a) the exact scope of activities of the

company, including that it shall operate

solely as an entity on behalf of the Central

Government for the public service

contracts in the railway transport market,

b) the exact corporate governance and

organisational structure.

c) that the eligible rolling stock to be

procured by the company shall be zero

emission by means of intervention field 72

bis of Annex VI to the RRF Regulation

and compatible with ERTMS standards.

4) Approval by the Ministry of Transport, in

agreement with the Ministry of Economy and

Finance, of a business plan for the period 2026-

2032 detailing:

a) the lines of strategic and operational

development of the company, taking into

24

Sequential

Number

Related Measure

(Reform or

Investment)

Milestone/

Target Name

Qualitative

indicators

(for

milestones)

Quantitative indicators (for

targets)

Indicative

timeline for

completion Description of each milestone and target

Unit of

measure Baseline Goal Quarter Year

account its statutory mission and

objectives,

b) the characteristics of the activities to be

carried out,

c) at least with reference to each of the first

three financial years, capital adequacy

profiles, the planned tendering procedures

and investments and related financial

coverage.

25

F. COMPONENT 6: Energy – green transition

This component of the Hungarian recovery and resilience plan addresses several challenges of the

energy sector. The objective of the component is to contribute to the attainment of Hungary’s 2030

climate and energy targets, also considering the need to raise Member States’ ambition in the context

of the EU-wide 2030 objective of reducing greenhouse gas emissions by at least 55 % relative to 1990

levels. The National Energy Strategy 2030 and the National Energy and Climate Plan aim at

strengthening energy sovereignty and energy security by reducing import dependency, ensuring

affordable energy supply for the population and decarbonising energy production, including the

increase of the share of energy generation based on renewable sources.

In this context, the component aims at creating additional capacities based on renewable energy

sources and ultimately reducing greenhouse gas emissions. The amendments to the legal framework

shall establish the supportive regulatory environment to achieve this objective. With a view to

integrating the energy production capacities from renewable energy sources into the electricity

network in a secure and flexible way, the component shall support the investment related to the

network development and investments into electricity storage facilities. The investment into smart

meters is expected to contribute to the optimisation of electricity demand in the long term. The

component shall also result in creation of additional renewable energy production capacity by

supporting onshore wind power generation and the installation of residential solar panel systems.

Furthermore, in order to address air pollution and energy efficiency-related challenges, it shall also

provide support to households for the installation of electric heating systems and for windows

replacement, in addition to the solar panel systems and storage units.

The measures under this component are expected to contribute to the green transition and to the

achievement of the climate neutrality objective by 2050.

The smart network development based on innovative technical solutions is an important step towards

digitalisation. The exploitation of data through digital solutions ensures better forecast of supply-

demand balances and better regulation of energy production.

The component contributes to the strategic autonomy and security of Hungary as part of European

objectives. The upscaling of renewable energy production capacities shall lead to increased energy

sovereignty through increasing the share of domestic energy sources. The grid development shall also

contribute to improving the security of the electricity network.

The investments are also expected to contribute to job creation at local level, including for the SME

sector.

The component contributes to addressing the Country Specific Recommendations regarding the need

to focus on the green and digital transitions, in particular clean and efficient production and use of

energy (Country Specific Recommendation 3 in 2020) and to put low carbon energy and energy and

resource efficiency in the centre of investment-oriented economic policy (Country Specific

Recommendation 3 in 2019). It also contributes to addressing the Country Specific Recommendation

6 in 2022 regarding the need to reduce overall reliance on fossil fuels by accelerating the deployment

of renewables, by streamlining the permitting procedures and the upgrading of the electricity

infrastructure, as well as to addressing the Country Specific Recommendation 4 in 2025 regarding

the need to improve flexibility and competition in the electricity sector, by strengthening the

balancing market and boosting cross-border electricity trading.

It is expected that no measure in this component does significant harm to environmental objectives

within the meaning of Article 17 of Regulation (EU) 2020/852, taking into account the description of

the measures and the mitigating steps set out in the recovery and resilience plan in accordance with

the DNSH Technical Guidance (2021/C58/01).

26

F.1. Description of the reforms and investments for non-repayable financial support

C6.R1: Transformation of electricity regulations

The objective of this measure is to improve the legal framework of the Hungarian electricity market

by amending the applicable laws.

The measure consists of the introduction of separate accounting for the electricity fed into the grid

and electricity consumed from the grid.

C6.R2: Encouraging the development of onshore wind energy

The objective of the measure is to encourage the deployment of additional onshore wind power

generation capacity in Hungary.

The measure consists in simplifying the rules for the installation of onshore wind power generation

capacity.

C6.R3: Accelerate the connection of renewable energy projects to the grid

The objective of this measure is to accelerate the connection of renewable energy projects to the grid.

The measure consists of a simplification of grid connection procedures for renewable energy

installations.

C6.R4: Setting minimum energy efficiency standards

The objective of the measure is to improve energy efficiency of buildings in Hungary.

The measure consists in introducing minimum energy efficiency standards for building renovation

support schemes (co-) financed from EU funds.

C6.I1: Classic and smart grid development for transmission system operator and distribution

system operators

The objective of the measure is to accommodate the expected increase in demand for integrating

additional capacity into the grid.

The measure consists of construction and upgrade of transmission and distribution grids.

C6.I2: Support for the use of residential solar panels and heating modernisation

The objective of the measure is the upscaling of residential renewable energy production capacities,

the increase of energy efficiency as well as the reduction of air pollution stemming from outdated

heating solutions.

The measure consists in: (i) the installation of residential solar panel systems; and (ii) the installation

of residential solar panel systems combined with one or multiple of the following measures:

replacement of windows and/or doors, installation of storage capacity and installation of electric

heating.

C6.I3: Installation of grid energy storage facilities for market participants

The objective of this measure is to provide for the market players in the balancing markets access to

zero-emission flexibility services.

This measure consists in the installation of energy storage facilities.

C6.I4: Dissemination of smart metering

The objective of the measure is to support the purchase and installation of smart meters.

This measure consists of subsidising distribution system operators for the installation of smart meters.

C6.I5: Energy efficiency investments in public buildings

The objective of the measure is to improve the energy performance of public buildings.

27

This investment consists of energy efficiency renovations in public buildings.

C6.I6. Grant scheme for the development of the electricity grid

This measure shall consist of a public investment in a Grant Scheme, in order to incentivise private

investment and improve access to finance in Hungary's energy sector. The Scheme shall operate by

providing grants directly to the private sector as well as to public sector entities engaged in similar

activities.

The Scheme shall be managed by the Hungarian Development Bank (Magyar Fejlesztési Bank Zrt. –

MFB) as the implementing partner. The Scheme shall include the following product line:

• Grants for distribution and transmission grid development investments including - but not

limited to - cables, smart meters, transformers and other grid infrastructure.

In order to implement the investment into the Scheme, Hungary and the Hungarian Development

Bank shall sign an Implementing Agreement that shall include the following content:

1. Description of the decision-making process of the Scheme: The final award decision of the

Scheme shall be taken by an investment committee or other relevant equivalent governing body

and approved by a majority of votes from members who are independent from the government.

2. Key requirements of the associated grant policy,which shall include:

a. The description of the grants provided and eligible final beneficiaries5.

b. The requirement that all investments supported are economically viable.

c. The requirement to comply with the ‘Do no significant harm’ (DNSH) principle as set out

in the DNSH Technical Guidance (2021/C58/01). In particular, the grant policy shall

exclude the following list of activities and assets from eligibility: (i) activities and assets

related to fossil fuels, including downstream use6, (ii) activities and assets under the EU

Emission Trading System (ETS) achieving projected greenhouse gas emissions that are not

lower than the relevant benchmarks7, (iii) activities and assets related to waste landfills,

incinerators8and mechanical biological treatment plants9.

d. The requirement that final beneficiaries of the Scheme shall not receive support from other

Union instruments to cover the same cost.

5 Final beneficiaries associated to specific projects shall be required to provide a justification of the selected intervention field for each

project supported, together with a description of the project, for the purpose of the computation of the climate contribution. For the

purpose of the computation of the climate contribution, final beneficiaries from equity, quasi-equity, corporate bonds or equivalent

instruments not targeted to specific projects shall provide a justification for the selected intervention field(s). The implementing partner

shall also be required to provide to the Member State a semi-annual report on the implementation of each project/activity. 6 Except for (a) assets and activities in power and/or heat generation, as well as related transmission and distribution infrastructure,

using natural gas, that are compliant with the conditions set out in Annex III of the ‘Do no significant harm’ Technical Guidance

(2021/C58/01) and (b) activities and assets under point (ii) for which the use of fossil fuels is temporary and technically unavoidable

for the timely transition towards a fossil fuel free operation. 7 Where the activity supported achieves projected greenhouse gas emissions that are not significantly lower than the relevant

benchmarks, an explanation of the reasons why this is not possible shall be provided. Benchmarks established for free allocation for

activities falling within the scope of the Emissions Trading System, as set out in the Commission Implementing Regulation (EU)

2021/447. 8 This exclusion does not apply to actions under this measure in plants exclusively dedicated to treating non-recyclable hazardous

waste, and to existing plants, where the actions under this measure are for the purpose of increasing energy efficiency, capturing exhaust

gases for storage or use or recovering materials from incineration ashes, provided such actions under this measure do not result in an

increase of the plants’ waste processing capacity or in an extension of the lifetime of the plants; for which evidence is provided at plant

level. 9 This exclusion does not apply to actions under this measure in existing mechanical biological treatment plants, where the actions

under this measure are for the purpose of increasing energy efficiency or retrofitting to recycling operations of separated waste to

compost bio-waste and anaerobic digestion of bio-waste, provided such actions under this measure do not result in an increase of the

plants’ waste processing capacity or in an extension of the lifetime of the plants; for which evidence is provided at plant level.

28

3. The amount covered by the Implementing Agreement, the fee structure for the Implementing

Partner and the requirement to use any unused proceeds of the scheme, including beyond 2026,

for the same policy purposes.

4. Monitoring, audit, and control requirements, including:

1. The description of the implementing partner’s monitoring system to report on the

grants mobilized.

2. The description of the implementing partner’s procedures that will ensure the

prevention, detection and correction of fraud, corruption, and conflicts of interests.

3. The obligation to verify the eligibility of every operation in accordance with the

requirements laid out in the Implementing Agreement before awarding a grant to an

operation.

4. The obligation of carrying out risk-based ex-post audits in accordance with an audit

plan of the Hungarian Development Bank. These audits shall verify i) that the control

systems are effective, including the detection of fraud, corruption, and conflict of

interests; ii) compliance with the DNSH principle, the State Aid rules, the climate and

digital target requirements; and iii) that the requirement that final beneficiaries of the

Scheme have not received support from other Union instruments to cover the same

cost is respected. The audits shall also verify the legality of the transactions and that

the conditions of the applicable Implementing Agreement and Grant Agreements are

being respected.

5. Requirements for climate and digital investments carried out by the implementing partner: at

least EUR 856 756 163.36 of the RRF investment into the Scheme shall contribute to the

climate change objectives in accordance with Annex VI to the RRF Regulation and at least

EUR 342 702 465.34 shall contribute to the digital transition in accordance with Annex VII to

the RRF Regulation.

29

F.2. Milestones, targets, indicators, and timetable for monitoring and implementation for non-repayable financial support

Seq.

Number

Related

Measure

(Reform or

Investment)

Milestone

/Target Name

Qualitative

indicators

(for

milestones)

Quantitative indicators

(for targets)

Indicative

timeline for

completion Description of each milestone and target

Unit of

measure Baseline Goal Quarter Year

35

C6.R1

Transformation

of electricity

regulation

Milestone

Entry into force

of legal act(s)

concerning gross

metering

Provision

indicating the

entry into

force of the

legal act(s)

Q2 2026

Entry into force of legal act(s) introducing separate

accounting for electricity fed into the grid and electricity

consumed from the grid.

For users that installed a solar panel system based on a

connection request submitted after 1 January 2024, the

legal act(s) shall provide for the automatic entry into force

of the separate accounting system.

For users that installed a solar panel system based on a

connection request submitted before 31 December 2023,

the legal act(s) shall provide for the entry into force of the

separate accounting system 10 years after the installation

of the solar panel system.

36

C6.R2

Encouraging the

deployment of

onshore wind

energy

Milestone Entry into force

of legal act(s)

Provision

indicating the

entry into

force of legal

act(s)

Q2 2026

Entry into force of legal act(s) that:

(i) Increase(s) the maximum height limit for wind

turbines to 199 m and decrease the minimum

distance between wind power plants and residential

areas to 700 m across the whole territory of Hungary.

(ii) Designate(s) at least 25 priority zones for onshore

wind.

(iii) Establish(es) that in the priority zones: it is not

required to designate green areas, agricultural land or

forest land to compensate for the areas designated for

wind development; and environmental and

construction permits for onshore wind are issued

within maximum 50 days after submission of

application.

37

C6.R2

Encouraging the

deployment of

onshore wind

energy

Milestone Entry into force

of legal act(s)

Provision

indicating its

entry into

force

Q2 2026

Entry into force of legal act(s) establishing a plan of at

least annual grid connection auctions for wind

technology. The auctions shall allocate a minimum

volume of 4 GW wind energy production capacity for the

period 2026–2030. Publication of an auction tender for at

least 700 MW of wind capacity by 31 August 2026.

30

Seq.

Number

Related

Measure

(Reform or

Investment)

Milestone

/Target Name

Qualitative

indicators

(for

milestones)

Quantitative indicators

(for targets)

Indicative

timeline for

completion Description of each milestone and target

Unit of

measure Baseline Goal Quarter Year

38

C6.R3

Accelerate the

connection of

renewable

energy projects

to the grid

Milestone Entry into force

of legal act(s)

Provision

indicating the

entry into

force of legal

act(s)

Q2 2026

Entry into force of legal act(s) that:

(i) Introduce(s) a single integrated permitting procedure

for environmental and construction permits for

installing solar and on-shore wind power plants with

capacity above 0.5 MW;

(ii) set(s) out the financial penalties for authorities

involved in the integrated permitting procedure for

environmental and construction permits that do not

grant permits within the administrative procedure

deadlines established by law.

(iii) Allow(s) for the colocation of wind and solar power

plants.

39

C6.R3

Accelerate the

connection of

renewable

energy projects

to the grid

Target

Grid connection

authorisation for

renewable power

plants capacity

Total

authorised

renewable

capacity

MW 0 6 200 Q2 2026 Total installation and connection of 6 200 MW capacity

of solar and onshore wind power plants.

39bis

C6.R3

Accelerate the

connection of

renewable

energy projects

to the grid

Milestone Entry into force

of legal act(s)

Provision

indicating its

entry into

force

Q2 2026

Entry into force of legal act(s) that:

(i) Establish(es) that newly built residential PV systems

(up to 10.8 kVA) require only a notification to the

DSO to be connected to the grid;

(ii) Provide(s) that DSOs shall connect small

photovoltaic installations (with a maximum capacity

of 10.8 kVA) to the grid within maximum two

months from the notification of installation by the

owner.

40

C6.R4 Setting

minimum

energy

efficiency

standards

Milestone

Setting minimum

energy efficiency

requirements for

building

renovation

support schemes

Entry into

force of legal

act(s)

Q2 2026

Entry into force of legal act(s) that provides that for

building renovation support schemes (co-) financed by

EU funds, at least a 30% energy consumption reduction

shall be achieved.

31

Seq.

Number

Related

Measure

(Reform or

Investment)

Milestone

/Target Name

Qualitative

indicators

(for

milestones)

Quantitative indicators

(for targets)

Indicative

timeline for

completion Description of each milestone and target

Unit of

measure Baseline Goal Quarter Year

41

C6.I1 Classic

and smart grid

development of

transmission

system operator

and distribution

system

operators

Target

Cumulative

additional

capacity added to

the grid

MW 0 2 781 Q2 2026

Transmission and distribution networks are constructed or

upgraded to enable the integration of at least 2 781 MW

of additional hosting capacity. A technical report prepared

by the national regulator (MEKH) and proving the

increase in hosting capacity shall be provided.

42

C6.I2 Support

for the use of

residential solar

panels and

heating

modernisation

Target

Number of

households

supported

Number 0 20 000 Q2 2026

At least 20 000 households shall have installed solar panel

systems.

Out of this total, at least 4 313 households shall have

installed solar panel systems combined with at least one

of the following: installation of electric heating systems,

installation of a storage unit or replacement of windows

and/or doors.

43

C6.I3

Installation of

grid energy

storage facilities

for energy

market

participants

Target

Capacity of

installed energy

storage facilities

MWh 0 676 Q2 2026

Launch of call(s) supporting installation of storage

facilities with: (i) a reference to technological neutrality

towards storage facilities, and (ii) requirement for

recipients to be capable of introducing capacity into the

balancing market as certified by the transmission system

operator.

At least 676 MWh of capacity of grid energy storage

facilities are installed.

44

C6.I4

Dissemination

of smart

metering

Target Installation of

smart meters Number 0 290 680 Q2 2026

At least 290 680 smart meters installed by the distribution

system operators.

45

C6.I5. Energy

efficiency

investments in

public buildings

Target

Number of public

buildings

benefitted from

energy efficiency

renovation

Number 0 180 Q2 2026

Energy efficiency renovations in at least 180 public

buildings.

46 C6.I6. Grant

scheme for the

development of

Milestone Implementing

Agreement Entry into

force of the Q2 2026

Entry into force of the Implementing Agreement.

32

Seq.

Number

Related

Measure

(Reform or

Investment)

Milestone

/Target Name

Qualitative

indicators

(for

milestones)

Quantitative indicators

(for targets)

Indicative

timeline for

completion Description of each milestone and target

Unit of

measure Baseline Goal Quarter Year

the electricity

grid

Implementing

Agreement

47 C6.I6. Grant

scheme for the

development of

the electricity

grid

Target

Legal agreements

signed with final

beneficiaries

Percentage

(%) 0 100 Q2 2026

The MFB shall have entered into legal grant agreements

with the beneficiaries for an amount necessary to use

100% of the RRF investment into the Scheme (taking into

account management fees).

48 C6.I6. Grant

scheme for the

development of

the electricity

grid

Milestone Ministry has

completed the

investment

Q2 2026

Hungary shall transfer EUR 856 756 163.36 to the MFB

for the Facility (taking into account management fees).

33

G. COMPONENT 7: HEALTH

This component of the Hungarian recovery and resilience plan addresses several challenges that the

Hungarian health system currently faces, such as unequal access to services and the high incidence

of informal (gratuity) payments; an excessive reliance on hospitals in the provision of services and

regional shortages of workforce within the health system.

The main objective of the component is to develop a modern and efficient care system capable of

responding to the challenges of the twenty-first century and accessible to all, in line with principle 16

of the European Pillar of Social Rights. To this end, the component aims to (i) eradicate gratuity

payments in the health system; (ii) reinforce the role of general practitioners; (iii) streamline in-patient

care and upgrade its infrastructure and (iv) increase the use of information and communication

technologies (ICT) to improve the quality and efficiency of healthcare services.

The component supports addressing the Country Specific Recommendations on supporting

preventive health measures and strengthening primary healthcare (Country Specific

Recommendations 2 of 2019 and 3 in 2022), on addressing shortages of health workers and ensuring

an adequate supply of critical medical products and infrastructure (Country Specific

Recommendation 1 in 2020), and on ensuring access to essential services for all (Country Specific

Recommendation 2 in 2020). It should also contribute to the implementation of the European Pillar

of Social Rights.

It is expected that no measure in this component does significant harm to environmental objectives

within the meaning of Article 17 of Regulation (EU) 2020/852, taking into account the description of

the measures and the mitigating steps set out in the recovery and resilience plan in accordance with

the DNSH Technical Guidance (2021/C58/01).

G.1. Description of the reforms and investments for non-repayable financial support

C7.R1: Eradication of gratuity payments in the healthcare sector

The objective of the measure is to eradicate the practice of informal gratuity payments in healthcare

services while creating better financial and working conditions for doctors.

The measure consists of the entry into force of legal act(s) for: (i) introducing a new employment

contract for doctors in the interest of increasing their salaries and (ii) the criminalisation of gratuity

payments.

C7.I1: Modernisation of healthcare system in the 21st century

The objective of the measure is to enhance the quality of care by improving healthcare infrastructure

and upgrading healthcare equipment in healthcare units.

The measure consists in providing financial support for refurbishment and renovation works, as well

as for the purchase of healthcare equipment.

C7.I2: Supporting the digital transformation of health

The objective of this measure is to support the digital transformation of healthcare services by

expanding digital process and improving efficiency.

This measure consists in digitisation of new or upgraded functions and procedures of the e-health

care system.

C7.I3: Development of primary health care

The objective of the measure is to improve primary health care services through general practitioners,

local services, and to alleviate the pressure on specialized care.

The measure consists of establishing praxis communities of general practitioners, increasing the

number of doctors in these communities, and enrolling patients in the Chronic Disease Management

Programme and Prevention Programme.

34

C7.I4: Local health and social infrastructure

The objective of the measure is to enhance the quality, accessibility, and efficiency of health and

social services.

The measure consists in the refurbishment of healthcare and social care facilities, as well as the

delivery of related equipment.

35

G.2. Milestones, targets, indicators, and timetable for monitoring and implementation for non-repayable financial support

Seq.

Number

Related

Measure

(Reform or

Investment)

Milestone

/Target Name

Qualitative

indicators

(for milestones)

Quantitative indicators

(for targets)

Indicative timeline

for completion

Description of each milestone and target Unit of

measure Baseline Goal Quarter Year

49

C7.R1

Eradication of

gratuity

payments in the

healthcare sector

Milestone

Entry into force of the legal act(s)

on the eradication of the practice

of gratuity payment

Provision in the legal

act(s) indicating its

entry into force

Q2 2026

Entry into force of a legal act regulating the

employment contract of state-owned healthcare

service providers, the elimination and

criminalization of gratuity payments and the

salary for doctors under the new employment

contract.

50

C7.I1

Modernisation

of healthcare

system for

the 21st century

Milestone

Refurbishment of health facilities

and upgrading of healthcare

equipment

Disbursement of

funds Q2 2026

Disbursement of EUR 240 million of funds for

investments in healthcare infrastructure and

healthcare equipment refurbishment.

51

C7.I2

Supporting the

digital

transformation

of health

Milestone Expansion of online health

functions and procedures

Mobile application

registry list Q2 2026

New or upgraded functions and procedures are

digitised or online and accessible via the e-health

care system. At least 100 000 users are registered

for the EESZT mobile application.

52

C7.I3

Development of

primary health

care

Milestone Programmes for primary health

care

Participation of GPs

and patients in

dedicated

programmes

Q2 2026

Participation of 4 000 general practitioners in

praxis communities.

43 000 patients with chronic non-communicable

diseases, for example hypertension,

cardiovascular diseases, type II diabetes, and

chronic obstructive pulmonary disease (COPD)

are enrolled in the Chronic Disease Management

Programme.

25 000 patients enrolled in prevention program.

53

C7.I4 Local

health and social

infrastructure

Milestone Local health and social

infrastructure Number 60 Q2 2026

Refurbishment of 60 health or social services

buildings or delivery of equipment.

36

H. COMPONENT 8: GOVERNANCE AND PUBLIC ADMINISTRATION

Hungary has a number of long-standing horizontal challenges related to the robustness and

functioning of the public institutions in general, which has implications also on economic and social

processes in the country. Specific issues in this regard relate to the anti-corruption framework,

competition in public procurement, judicial independence, as well as the predictability, quality and

transparency of decision-making. Hungary ranks low in corruption perception indicators and the level

of competition in public procurements is moderate. Accountability for decisions to close

investigations remains a matter of concern as there are no effective remedies against decisions of the

prosecution service not to prosecute alleged criminal activities. Recurrent challenges in the

application of the rules on transparency and access to public information further weaken the anti-

corruption framework as well. As regards judicial independence, concerns relate in particular to the

challenges faced by the independent National Judicial Council in counter-balancing the powers of the

President of the National Office for the Judiciary, the rules on electing the President of the Supreme

Court, the possibility of discretionary decisions as regards judicial appointments and promotions, case

allocation as well as bonuses to judges and court executives, as well as the possibility for public

authorities to challenge before the Constitutional Court final judicial decisions. The quality,

predictability and transparency of decision-making and the absence of effective consultation of social

partners and stakeholders in the decision-making processes, represent recurrent challenges. The

complexity of the tax system and the risks of aggressive tax planning have also been identified as

issues to tackle; and so is the need to improve the sustainability of public finances and the budgetary

framework.

This component of the Hungarian recovery and resilience plan aims to address these challenges. It

includes measures that are expected to contribute to reinforcing the anti-corruption framework,

including by establishing an Integrity Authority and an Anti-Corruption Task Force, implementing

anti-corruption measures and strengthening the capacities of the Hungarian audit and control bodies,

in particular with regard to spending from the EU budget. It also includes measures to strengthen

prosecutorial efforts. Measures are also included to increase competition in the field of public

procurement and ensure the transparency of and public oversight over public procurements.

Measures included in the component also address issues concerning the independence of the

judiciary, to raise the standard of judicial protection and to improve the investment climate in

Hungary, by strengthening the guarantees of independence and impartiality of courts, namely by

establishing stronger powers for the National Judicial Council to counterbalance the powers of the

President of the National Office for the Judiciary, strengthening the judicial independence of the

Supreme Court, removing obstacles to references for preliminary rulings to the Court of Justice of

the European Union, and removing the possibility for public authorities to challenge before the

Constitutional Court final judicial decisions.

The measures in this component are also expected to improve the quality and transparency of

decision-making, including by a more systematic involvement of social partners and stakeholders,

and to facilitate access to public information, as well as ensuring effective oversight on how public

interest asset management foundations make use of EU support. The component also features

measures to tackle the risk of aggressive tax planning and simplify the tax system. Lastly, the

component includes measures that aim to improve the quality and sustainability of public finances.

In several instances, this component also contributes to the digital transition of public institutions by

supporting the digitalisation of public administration and services.

37

The component contributes to addressing the Country Specific Recommendations on the need to

“Reinforce the anti-corruption framework, including by improving prosecutorial efforts and access

to public information” (Country Specific Recommendation 4 of 2019, Country Specific

Recommendation 4 of 2022), “Improve competition in public procurement” (Country Specific

Recommendation 4 of 2020, Country Specific Recommendation 4 of 2022), “Strengthen judicial

independence” (Country Specific Recommendation 4 of 2019, Country Specific Recommendation 4

of 2022), “Improve the quality and transparency of the decision-making process through effective

social dialogue, engagement with other stakeholders and regular impact assessments” (Country

Specific Recommendation 4 of 2019, Country Specific Recommendation 4 of 2022), “Continue

simplifying the tax system” (Country Specific Recommendation 4 of 2019, Country Specific

Recommendation 4 of 2022), “Strengthen the tax system against the risk of aggressive tax planning”

(Country Specific Recommendation 4 of 2019, Country Specific Recommendation 5 of 2020),

“Achieve prudent medium-term fiscal positions” (Country Specific Recommendation 1 of 2022),

“Strengthen the medium-term budgetary framework, align the preparation of annual budgets with the

budgetary year and limit discretion in the implementation of annual budgets” (Country Specific

Recommendation 1 of 2024, Country Specific Recommendation 1 of 2025) and ”Phase out

remaining price and interest rate caps to reduce distortive effects and facilitate the smooth

transmission of monetary policy” (Country Specific Recommendation 1 of 2024, Country Specific

Recommendation 1 of 2025).

A number of these measures have been put forward by Hungary and discussed with the European

Commission in the context of the procedure under the Conditionality Regulation10. The content of

the related milestones and targets is aligned with the commitments taken in that context and some of

these milestones shall be implemented before the submission of a payment request under the

Recovery and Resilience Facility.

In accordance with Article 20(5)(e) of Regulation (EU) 2021/241, in order to comply with Article 22

of that Regulation, the implementation of the milestones in this component that are related to the

Hungarian control system aiming at the protection of the financial interests of the Union shall be a

precondition for any payment under Article 24 of the RRF Regulation11.

In accordance with Article 24(3) of Regulation (EU) 2021/241, any reform by Hungary shall be

undertaken without weakening this result and negatively impacting the below elements.

It is expected that no measure in this component does significant harm to environmental objectives

within the meaning of Article 17 of Regulation (EU) 2020/852, taking into account the description of

the measures and the mitigating steps set out in the recovery and resilience plan in accordance with

the DNSH Technical Guidance (2021/C58/01).

H.1. Description of the reforms and investments for non-repayable financial support

C8.R1: Entry into force of legal acts on an Integrity Authority

The objective of this reform is to reinforce the prevention, detection and correction of fraud, conflict

of interest and corruption as well as other illegalities and irregularities concerning the implementation

of Union support in Hungary, with a particular focus on public procurement, through the legal

establishment of an Integrity Authority.

10 Procedure under Article 6 of Regulation (EU, Euratom) 2020/2092 on a general regime of conditionality for the protection of the

Union budget. 11 This is the case for milestones 54, 55, 57, 58, 59, 62, 63, 66, 68, 69, 71, 72, 73, 74, 75, 76, 77, 78, 79, 80, 81, 82, 83, 84.

38

The reform consists in the entry into force of legislation providing for an independent Integrity

Authority, with competence to intervene in all cases where in its views competent national authorities

have not taken the necessary steps to prevent, detect and correct fraud, conflict of interests, corruption

and other illegalities or irregularities that have affected or seriously risk affecting the sound financial

management of the Union budget or the protection of the financial interests of the European Union.

The legislation shall also provide the competences of the Integrity Authority, such as directly

verifying asset declarations of certain categories of senior political executives (as well as those of

their relatives living in the same household) and other high-risk officials.

C8.R2: Participation in the enhanced cooperation on the establishment of the European

Public Prosecutor’s Office

The objective of this reform is to strengthen the effective protection of the Union’s financial interests

and the fight against criminal offences affecting the Union’s financial interest in Hungary with its

participation in the enhanced cooperation on the establishment of the European Public Prosecutor’s

Office (EPPO). The EPPO is an indivisible Union body operating as one single Office in the interest

of the Union as a whole with the competence to investigate, prosecute and bring to judgment

perpetrators of criminal offences committed against the financial interests of the Union.

The reform consists in the submission of the notification by Hungary to the European Commission

of its intention to participate in the enhanced cooperation on the establishment of the EPPO.

C8.R3: Entry into force of legal acts on an Anti-Corruption Task Force

The objective of this reform is to monitor and review the measures taken in Hungary to prevent,

detect, prosecute and sanction corruption by an Anti-Corruption Task Force.

This reform consists in the entry into force of legislation on the legal establishment of an Anti-

Corruption Task Force, including the specification of its main tasks. The legislation shall provide

that, inter alia, (i) non-governmental actors active in the field of anti-corruption shall make up at least

50% of the members of the Anti-Corruption Task Force (the chair excluded); (ii) the Anti-Corruption

Task Force shall meet at least twice a year, (iii) the Anti-Corruption Task Force prepares a publicly

available annual report and (iv) the Anti-Corruption Task Force shall put forward proposals aiming

to improve corruption prevention and detection and boost the flow of information between

administrative and control authorities of the state and criminal investigation authorities.

C8.R4: Introduction of a specific procedure in the case of special crimes related to the exercise

of public authority or the management of public property (‘judicial review’)

The objective of this reform is to establish a specific procedure that ensures judicial review of

decisions of investigating authorities or the prosecution service to dismiss a crime report or to

terminate proceedings in the case of special crimes related to the exercise of public authority or the

management of public property, in order to ensure that determined action is taken to prosecute

corruption and similar criminal offences. The reform consists in the entry into force of legislative

amendment(s) on judicial review and the right to file an indictment concerning certain corruption and

corruption-related practices.

C8.R5: Amendment of rules related to asset declarations

The aim of this reform is to amend the anti-corruption framework by introducing more stringent rules

related to asset declarations, along with a sanctions regime for the breach of these rules and

obligations.

The reform consists in the entry into force of legislative amendments that provide for the obligation

that senior political executives and their relatives living in the same household, as well as members

of the National Assembly and their relatives living in the same household shall submit asset

declarations upon taking up duties, annually thereafter and at the time of leaving their duties, and the

aforementioned asset declarations shall be submitted electronically.

39

C8.R6: Entry into force of legal acts on the transparency of the use of public resources by

public interest asset management foundations

The objective of this reform is to ensure oversight on how public interest asset management

foundations make use of Union support and to prevent the structural risk of conflict of interest

situations in their functioning.

The reform consists in the entry into force of legislative amendments to set out the designation of

public interest asset management foundations performing public duty and the legal persons

established or maintained by them as contracting authorities within the meaning of public

procurement rule, and in the adoption of rules to prevent and address risks of conflict of interest.

C8.R7: Enhancing the transparency of public spending

The objective of this reform is to increase the transparency of public spending by ensuring that bodies

carrying out public duties proactively publish a wide range of information.

The reform consists in the entry into force of legislation providing for an obligation for bodies

carrying out public duties to proactively publish a pre-defined set of information on the use of public

funds into a central register.

C8.R8: Rules ensuring the transparency of beneficial owners of entities and clarifying the use

of public subsidies

The objective of this reform is to increase clarity and legal certainty of rules applicable to ultimate

beneficial owners of certain entities, including private investment funds/a fiduciary asset management

entities and to ensure that bodies responsible for the audit and control of Union support in Hungary

can retroactively access that data for carrying out their tasks thereby increasing the level of protection

of the Union’s financial interests.

The reform consists in the entry into force of

i. legislative amendments providing for the revision of the definition of ultimate beneficial

owner to include special provisions on private investment funds, ensure that bodies

responsible for the management and control of Union support in Hungary have the possibility

to gather information on and verify the ultimate beneficial owners of private equity funds

from at least 1 February 2020, and

ii. legislation providing for the clarification and the extension of the scope of excluded public

officials and the scope of entities that cannot apply for or receive subsidies provided from

public funds.

C8.R9: Reducing the share of single-bid public procurement procedures

The objective of the reform is to improve competition in public procurement and to increase the

transparency and robustness of related processes by reducing the share of single-bid public

procurement procedures financed from Union funds.

This reform consists in the obligation to keep the share of public procurement tender procedures with

single bids for procurements at least partially financed from Union support below 15% as reported in

a tool developed for monitoring and reporting single bids in line with the Single Market Scoreboard

methodology.

C8.R10: Reinforcing integrity, transparency and competitiveness in the public procurement

market

The objective of the reform is to reinforce the transparency of public procurement procedures,

introduce corruption-prevention and conflict of interest rules, reporting and publication obligations

for contracting authorities and incentivise competition in the public procurement market.

The reform consists in entry into force of legal act(s) on public procurement.

40

C8.R11: Development of the Electronic Public Procurement System (EPS) to increase

transparency

The objective of this reform isto increase the transparency of public procurements and facilitate the

independent oversight and analysis of competition in public procurements.

This reform consists of making possible the structured search in and bulk export of contract award

notice data in machine-readable format, through the Electronic Public Procurement System (EPS).

C8.R12: Performance measurement framework for public procurements

The objective of this reform is to facilitate the assessment of the efficiency and cost effectiveness of

public procurements and the reasons for limited competition.

This reform consists in the publication of a performance measurement framework of public

procurements on the EPS website to assess the efficiency and cost-effectiveness of public

procurements and the possible reasons for- and effects of limited competition in public procurement

procedures, and the sectors most affected by public procurement procedures resulting in single bids.

C8.R13: Action plan for increasing the level of competition in public procurement

The objective of this reform is to increase the level of competition in public procurement in Hungary.

This reform consists in the adoption, publication and annual review of an action plan aiming to

increase the level of competition in public procurement. The action plan shall set out objectives to be

achieved, define measures to achieve the objectives, set precise deadlines for the implementation of

the measures, identify the body/ies responsible for implementing the measures and establish a

monitoring mechanism to assess progress.

C8.R14: Reinforcing the role and powers of the National Judicial Council aimed at

counterbalancing the powers of the President of the National Office for the Judiciary

The objective of the reform is to reinforce the independence and impartiality of courts and judges

established by law by establishing stronger powers for the National Judicial Council (NJC) so that it

can effectively exercise its constitutional role in supervising the central administration of courts,

while maintaining the Council’s independence based on its members being elected by judges.

This reform consists in legislative amendments establishing stronger powers for the NJC by adopting

provisions on a motivated binding opinion by the NJC for a number of matters regarding both

individual decisions and regulations.

C8.R15: Judicial independence of the Supreme Court (Kúria)

The objective of the reform is to strengthen the judicial independence of the Supreme Court (Kúria).

This reform consists in legislative amendments related to the rules on the election of the Kúria

President, the rules on the case allocation scheme of the Kúria, and the rules on the functioning of the

Kúria.

C8.R16: Removing obstacles to references for preliminary rulings to the Court of Justice of

the European Union

The objective of the reform is to remove obstacles for courts to independently refer cases for

preliminary rulings to the Court of Justice of the European Union (CJEU).

This reform consists in the entry into force of legislative amendment(s) related to preliminary

references to the Court of Justice of the European Union.

C8.R17: Reform regarding the review of final judgments by the Constitutional Court

The objective of this reform is to strengthen the independence and impartiality of courts and judges.

This reform consists in legislative amendments on the removal of the possibility for public authorities

to challenge before the Constitutional Court final judicial decisions.

41

C8.R18: Legislative amendments strengthening the management, monitoring and audit and

control mechanisms to guarantee the sound use of Union support

The objective of this reform is to protect the financial interests of the Union in the use of Union

support.

This reform consists in the entry into force of legal acts defining the roles and responsibilities of the

bodies involved in the management, monitoring, control and audit of Union support provided by

specific EU instruments and on the management, monitoring, control and audit of the funds under

Regulation (EU) 2021/1060 including by setting out specific rules to prevent, detect and correct

conflict of interest.

C8.R19: Anti-fraud and anti-corruption strategy for the implementation, audit and control of

Union support

The objective of the reform is to ensure the prevention, detection and correction of fraud and

corruption related to any Union support in Hungary by putting in place a comprehensive anti-

corruption and anti-fraud strategy including a clear timeline for implementing it.

This reform consists of an anti-fraud and anti-corruption strategy complemented by an action plan

setting out actions with clear deadlines for implementation, responsible bodies, indicators for

measuring progress for each of the actions respectively and arrangements for the regular review of

the actions.

C8.R20: The Arachne system for Union support

The objective of the reform is to reinforce the prevention, detection and correction of fraud,

corruption, conflict of interest, double funding and other irregularities related to Union support in

Hungary.

This reform consists in the adoption of rules that require authorities to upload data into the Arachne

system every two months, that they systematically follow-up on risk-scoring signalled by the Arachne

system and that they rely on the Arachne system in their risk-assessment.

C8.R21: Establishment of a Directorate of Internal Audit and Integrity to reinforce the

control of conflicts of interest when implementing Union support

The objective of this reform is to prevent, detect and correct conflict of interest in the implementation

of Union support.

This reform consists in the entry into force of legal act(s) providing for:

i) the set up of a Directorate of Internal Audit and Integrity (DIAI), including provisions on

the independence of DIAI;

ii) the selection of its staff;

iii) its competence to act in relation bodies involved in the implementation of Union support

in Hungary;

iv) the requirements related to its provision of access to conflict of interest declarations and

to files of the Integrity Authority;

v) its rules of procedure;

vi) its financial and human resources;

vii) obligations related to regular controls of conflict of interest declarations filed in relation

to the implementation of Union support in Hungary;

viii) obligations related to anonymous reporting;

ix) its investigation obligations;

42

x) its reporting obligations to the Integrity Authority.

C8.R22: Ensuring the capacity for the EUTAF to carry out its tasks

The objective of this reform is to prevent and detect fraud, corruption and other irregularities in the

implementation of Union support.

This reform consists in the entry into force of legal act(s) providing for the arrangement of the

financial and human resources for the audit authority (Directorate General for Audit of European

Funds, EUTAF) to safeguard its independence and enable it to carry out its tasks independently. The

legal act specifies that the annual budget of EUTAF is established on the basis of its initial proposal,

the renumeration of the head of EUTAF and that the functional and professional independence of the

EUTAF shall be maintained and that its staff shall continue not to seek or accept instructions

regarding its audit work.

C8.R23: Cooperation with OLAF to reinforce the detection of fraud related to the use of

Union support

The objective of this reform is to establish a legal framework for cooperation with OLAF in the

implementation of Union support.

This reform consists in the entry into force of legal acts designating the National Tax and Customs

Administration (Nemzeti Adó- és Vámhivatal, NAV) to assist OLAF when carrying out on-the-spot

checks in Hungary and when an economic operator subject to those checks refuses to cooperate. The

legal acts also provide for financial type of sanctions to be imposed in case an economic operator

refuses to cooperate with OLAF for the purposes of on-the-spot checks and inspections.

C8.R24: Audit and control of the Recovery and Resilience Plan and the protection of the

financial interests of the Union

The objective of this reform is to protect the financial interests of the Union with respect to the

Recovery and Resilience Plan of Hungary.

This reform consists in the establishment of a repository system for the collection, storage and

provision of access in relation to implementation data as required by Article 22(2)(d)(i) to (iii) of the

RRF Regulation, and the adoption and entry into force of an audit strategy for the EUTAF” providing

for the audit of the implementation of the Recovery and Resilience Plan of Hungary accomplished in

accordance with internationally accepted audit standards.

C8.R25: Reinforcing transparency and access to public information

The objective of the reform is to reinforce transparency and improve access to public information.

This reform consists in the entry into force of legislative amendments (i) facilitating access to public

information by ensuring that public data shall, as a principle, be provided free of charge and repeal

certain grounds for refusal of access to public information requests; (ii) a regular review of bodies

carrying out public duties’ compliance with access to public information rules, carried out by the

NAIH; and (iii) to introduce an exceptional procedure for court cases related to access to public

information to facilitate access to public information and limiting the duration of judicial procedures.

C8.R26: Improving the quality of law-making and effective involvement of stakeholders and

social partners in decision-making

The objective of this reform is to increase the quality and the involvement of social partners,

stakeholders and non-governmental experts in law-making and to establish a framework for the

systematic consultation of social partners and stakeholders on the implementation of the recovery and

resilience plan.

This reform consists in the entry into force of legal act(s) (i) to set out public consultation

requirements on draft legal acts and the requirement to systematically publish summary impact

assessments and explanatory memoranda; and (ii) to provide for an obligation to draw up a strategy

43

on the involvement of stakeholders and the setting up of a monitoring committee for the recovery and

resilience plan.

C8.R27: Review of minimum substance requirements for corporate income tax purposes

The objective of this reform is to ensure that companies are not established in Hungary exclusively

for tax planning purposes, and contribute to the fight against the use of letterbox and shell companies.

This reform consists of an independent international expert review on domestic anti-tax avoidance

rules.

C8.R28: Strengthening of transfer pricing regulations

The objective of this reform is to tackle tax evasion and improve the transparency of the Hungarian

tax system by transforming the data reporting obligations on related party transactions for transfer

pricing purposes.

The reform consists of the entry into force of legal act(s) setting out requirements for a new transfer

pricing data reporting.

C8.R29: Extending the scope of non-deductibility rules for outbound payments

The objective of this reform is to tackle the risk of double non-taxation of outbound payments flowing

from Hungary to zero- or low-tax jurisdictions, thus limiting opportunities for aggressive tax

planning.

This reform consists in the entry into force of legislative amendments on broadening the non-

deductibility rules for outbound payments and the commissioning of an independent evaluation of

the rules related to aggressive tax planning.

C8.R30: Digital transformation of tax compliance procedures

The objective of this reform is to streamline tax compliance procedures and reduce compliance costs

by creating new, user-friendly digital services for taxpayers and financial intermediaries.

This reform consists in the creation of digital services related to receipts and VAT and the launch of

a pilot related to digital payroll services.

C8.R31: Simplifying the tax system by reducing the number of taxes

The objective of this reform is to simplify the tax system by reducing the number of taxes and

corporate tax expenditures.

The reform consists of amending the tax code to reduce the number of tax benefits and taxes, and

conducting reviews of corporate and personal income taxation.

C8.R32: Reforming the tax on public utility pipelines

The objective of this reform is to simplify the tax system while fostering a tax environment which

stimulates investments in large utility infrastructure projects.

This reform consists in either the repeal of the legal act(s) on the tax on utility pipelines or its

amendment to introduce a tax rule allowing the owners of utilities to discharge or credit the itemised

tax payable on their lines for the amount they invest in the maintenance or upgrade of those lines.

44

C8.R33: Boosting the efficiency of public expenditure by carrying out spending reviews

The objective of this reform is to evaluate and improve the efficiency of public expenditure, with a

view to enhancing the medium-term sustainability of public finances and government debt and

boosting economic growth.

This reform consists in the introduction of reviews of expenditure in selected priority areas of public

expenditure, using international best practices, and the production of two spending reviews.

C8.R34: Improving the domestic fiscal framework

The objective of this reform is to improve fiscal governance by strengthening transparency,

accountability, and efficiency in public financial management.

The reform consists of improvements to the domestic fiscal framework.

C8.R35: Reform of subsidised lending

The objective of this reform is to strengthen market-based financing mechanisms and ensure that

public financial support is targeted at addressing genuine market failures.

The reform consists in reforming the Széchenyi Card Programme, reducing government counter-

guarantees and reviewing government guarantees on private sector lending.

45

H.2. Milestones, targets, indicators, and timetable for monitoring and implementation for non-repayable financial support

Seq.

Number

Related Measure

(Reform or

Investment)

Milestone /

Target Name

Qualitative

indicators

(for milestones)

Quantitative indicators

(for targets)

Indicative

timeline for

completion Description of each milestone and target

Unit of

measure Baseline Goal Quarter Year

54

C8.R1 Entry into

force of legislation

on an Integrity

Authority

Milestone

Entry into force of

legislation on an

Integrity Authority

Provision in the

legislation

indicating entry

into force

Q2 2026

Entry into force of legislation that provides for

the specification of rules on an Integrity

Authority aiming to reinforce the prevention,

detection and correction of fraud, conflicts of

interest and corruption as well as other

illegalities and irregularities concerning the

implementation of Union support in Hungary,

with the following elements:

The legislation shall provide that the Integrity

Authority has the competence to intervene in all

cases where in its views the competent national

authorities have not taken the necessary steps to

prevent, detect and correct fraud, conflicts of

interests, corruption and other illegalities or

irregularities that may affect or seriously risk

affecting the sound financial management of the

European Union budget or the protection of the

financial interests of the European Union.

The legislation shall provide for the

independence of the Integrity Authority by

stipulating that:

- the Integrity Authority, including its staff,

shall neither seek nor take instructions

from any other person or institution.

- the Integrity Authority is responsible for

managing its own budget and that its

budget cannot be reduced without the

consent of the Integrity Authority. The

Authority shall be able to determine the

amount of resources it requires to carry

out its tasks as well as the number of staff.

- the Integrity Authority shall be managed

by a board composed of a president and

vice-presidents appointed by the President

of Hungary following an open call and

46

Seq.

Number

Related Measure

(Reform or

Investment)

Milestone /

Target Name

Qualitative

indicators

(for milestones)

Quantitative indicators

(for targets)

Indicative

timeline for

completion Description of each milestone and target

Unit of

measure Baseline Goal Quarter Year

selection process, for a non-renewable six-

year term.

- the selection criteria for members of the

board shall be based on their professional

qualities and qualifications. The

legislation shall include criteria for

incompatibility with political mandates or

membership and with ownership share in

a company.

- the members of the board shall be selected

following an open call on the basis of the

binding opinion on the fulfilment of the

eligibility of the candidates by an

Eligibility Committee set up for this

purpose. That the Eligibility Committee

shall be convened by the Director General

of the EUTAF following an open call. It

shall be composed of three independent

persons with a background from

recognised international institutions who

shall have a sufficiently long, verifiable

and relevant experience in the area of

public procurement and/or anti-corruption

activity. Members of the Eligibility

Committee shall not have in the last five

years: held elected political position or a

political position in the Government, been

employed by a political party or political

foundation, or carried out voluntary or

remunerated activity for such entities.

Conflict of interests rules in line with the

principles set out in Article 61 of

Regulation (EU, Euratom) 2024/2509

shall apply to members of the eligibility

committee for five years after the issuance

of the binding opinion. The members of

the Eligibility Committee shall publish

their asset declarations and declare their

absence of conflict of interest prior to

47

Seq.

Number

Related Measure

(Reform or

Investment)

Milestone /

Target Name

Qualitative

indicators

(for milestones)

Quantitative indicators

(for targets)

Indicative

timeline for

completion Description of each milestone and target

Unit of

measure Baseline Goal Quarter Year

starting their work in the Eligibility

Committee.

- a member of the board shall only be

dismissed in case of a conflict of interest

following their appointment or in case a

final criminal judgment is issued against

them for issues that relate to the work of

the Integrity Authority or affect the

independence and impartiality of the

member concerned.

The legislation shall provide that the Integrity

Authority has the competence:

(i) to instruct contracting authorities to suspend

a procurement procedure;

(ii) to request administrative investigative

bodies to carry out investigations on its behalf;

(iii) to recommend the exclusion of specific

economic operators from Union funding for a

certain period of time;

(iv) to instruct the national authorities or bodies

to initiate procedures to verify conflicts of

interest declarations and suspicions in relation

to the management of Union funds;

(v) to request access to all public procurement

files;

(vi) to recommend contracting authorities to

use a specific procedure in a specific public

procurement or in a category of public

procurement procedures;

(vii) to initiate procedures before the national

authorities or bodies with the aim of

establishing suspected irregularities;

(viii) to request the judicial review of all

decisions of authorities concerning public

48

Seq.

Number

Related Measure

(Reform or

Investment)

Milestone /

Target Name

Qualitative

indicators

(for milestones)

Quantitative indicators

(for targets)

Indicative

timeline for

completion Description of each milestone and target

Unit of

measure Baseline Goal Quarter Year

procurement procedures that involve Union

support;

(ix) to initiate the proceedings of the Public

Procurement Arbitration Board and if the

Authority proposes the suspension of the public

procurement procedure, the Public

Procurement Arbitration Board shall order such

suspension;

(x) to challenge the inaction of an authority

concerned in court.

The legislation shall provide:

- that the Integrity Authority is entitled to

access relevant data pertaining to its

proceedings and that the authorities

concerned by a data request of the Integrity

Authority be obliged to provide access to

the data or provide the data within a time

period not exceeding 30 calendar days and

that the Integrity Authority may initiate an

administrative non-compliance action if its

request has not been complied with.

- that the Integrity Authority shall act either

on its own initiative or on the basis of

complaints or reports it receives.

- the legal basis and obligation for the

Integrity Authority to establish a whistle-

blower interface for where anonymous

and confidential communication may be

conducted.

- the legal basis and obligation for the

Integrity Authority to set up, update and

operate a register of economic operators

concerned by a final judgment of the court

or a final administrative decision

excluding those economic operators from

public procurement procedures, where the

49

Seq.

Number

Related Measure

(Reform or

Investment)

Milestone /

Target Name

Qualitative

indicators

(for milestones)

Quantitative indicators

(for targets)

Indicative

timeline for

completion Description of each milestone and target

Unit of

measure Baseline Goal Quarter Year

Integrity Authority shall report suspected

cases of any irregularities to the national

authorities and, where applicable, to

OLAF.

- that the Integrity Authority shall have the

power to continue to exercise its

competence even in cases where a

measure, procedure or project planned to

receive, in part or in whole, financial

support from the European Union was

subsequently removed from European

Union financing.

55

C8.R1 Entry into

force of legislation

on an Integrity

Authority

Milestone

Legislative

amendments on the

powers and

competences on the

verification of asset

declarations by the

Integrity Authority

Provision in the

legislative

amendments

indicating their

entry into force

Q2 2026

Entry into force of legislation that shall endow

the Integrity Authority with:

- exclusive legal responsibility and

competence to directly verify the veracity

of asset declarations of senior political

executives who are not members of the

National Assembly (persons who fall

under the scope of Section 183 of Act

CXXV of 2018) as well as the asset

declarations of their relatives living in the

same household.

- the power to directly verify the public

asset declarations of other high-risk

officials, whose asset declarations are

required by law to be made publicly

available;

- the power to request the competent bodies

to carry out the verification of the veracity

of asset declarations of those high-risk

officials, whose asset declarations are not

required by law to be made publicly

available, and obtain the result of that

verification;

50

Seq.

Number

Related Measure

(Reform or

Investment)

Milestone /

Target Name

Qualitative

indicators

(for milestones)

Quantitative indicators

(for targets)

Indicative

timeline for

completion Description of each milestone and target

Unit of

measure Baseline Goal Quarter Year

- direct connection to databases and

registries it deems necessary to verify the

veracity of the information contained in

the asset declarations, or the possibility to

access relevant data directly or through a

data request to the authorities concerned

which shall be obliged to provide access

to the data or provide the data and that if

its request has not been complied with

within the time set, the Integrity Authority

may initiate an administrative non-

compliance action.

The legislation shall provide that such a

verification procedure may be initiated by the

Integrity Authority upon its own-initiative,

suspicion or upon complaint by anyone

submitting a formal claim indicating an alleged

incorrect item in an asset declaration.

As regards the President of the Republic; the

Members of the National Assembly, the

national minority advocates and — where that

person is not a Member of the National

Assembly — the Principal of the National

Assembly; the mayors and the Mayor of

Budapest, the local government representatives

and a national minority self-government

representatives; the members of the

Constitutional Court; the Commissioner for

Fundamental Rights and his or her Deputies;

the President and Vice-Presidents of the State

Audit Office; the President and Vice-Presidents

of the Curia; the President and Vice-Presidents

of the National Office for the Judiciary; the

judges; the Prosecutor General and his or her

Deputy; the Governor and Deputy Governors

of the Hungarian National Bank, the members

of the Monetary Council and members of the

Supervisory Board of the Hungarian National

Bank; the President of the Fiscal Council; the

51

Seq.

Number

Related Measure

(Reform or

Investment)

Milestone /

Target Name

Qualitative

indicators

(for milestones)

Quantitative indicators

(for targets)

Indicative

timeline for

completion Description of each milestone and target

Unit of

measure Baseline Goal Quarter Year

President and members of the National

Committee for Remembrance; the members of

the Media Council; the Prime Minister,

ministers, state secretaries, the Prime

Minister’s Political Director, the Prime

Minister’s Chief National Security Advisor if

they do not have a mandate as a Member of the

National Assembly; county government

commissioner, government commissioner,

Prime Minister’s commissioner, a ministerial

commissioner; the head or deputy head of an

independent regulatory organ or autonomous

state administration organ, or a member of any

of its decision-making collegiate bodies, in

case the Integrity Authority finds irregularities,

including that the persons under investigation

has intentionally falsely or untruthfully

communicated material data in his or her asset

declaration, in particular by concealing his or

her actual financial or income situation, the

Integrity Authority shall initiate a procedure

before the competent national body which shall

duly justify its position publicly if it does not

agree with the findings of the Integrity

Authority.

For the purposes of the exclusive or non-

exclusive verification powers of the Integrity

Authority, high-risks officials shall include the

following: the President, members of

Parliament, senior political executives,

political executives, persons in commissioner

status, political advisors, senior political

advisors, chiefs of staff, heads of independent

regulatory bodies and autonomous

administrative bodies, regional governors,

mayors of Budapest and cities with a county

status, judges, prosecutors, members of the

judicial and prosecutorial governance bodies,

heads of department in law enforcement

52

Seq.

Number

Related Measure

(Reform or

Investment)

Milestone /

Target Name

Qualitative

indicators

(for milestones)

Quantitative indicators

(for targets)

Indicative

timeline for

completion Description of each milestone and target

Unit of

measure Baseline Goal Quarter Year

agencies or civilian national security service

and senior executives of state-owned

enterprises.

For persons who fall under the scope of Section

183 of Act CXXV of 2018 the above powers

shall also include the following: (i) that the

Integrity Authority has the possibility to

instruct the person whose asset declaration is

under verification by the Integrity Authority to

present supporting data and documents

regarding the content of its asset declaration;

and (ii) that the Integrity Authority may

instruct a person the content of whose asset

declaration the Integrity Authority found to be

incorrect to correct its asset declaration.

56

C8.R2 Participation

in the enhanced

cooperation on the

establishment of the

European Public

Prosecutor’s Office

Milestone

Participation in

enhanced cooperation

related to the European

Public Prosecutor’s

Office

Receipt of the

notification of

intention to

participate by the

European

Commission

Q2 2026

Notification of the intention to participate in

the enhanced cooperation on the establishment

of the European Public Prosecutor’s Office

(EPPO) shall be submitted to the European

Commission. The notification shall include the

request that Regulation (EU) 2017/1939 shall

apply in Hungary with regard to offences

within the competence of the EPPO committed

before Hungary has been authorised to join the

enhanced cooperation on or after 1 June 2021.

57

C8.R3 Entry into

force of legal acts

on an Anti-

Corruption Task

Force

Milestone

Entry into force of

legal acts on an Anti-

Corruption Task Force

Provision in the

legislation

indicating entry

into force

Q2 2026

Entry into force of legislation that provides for

the legal establishment of the Anti-Corruption

Task Force.

The legislation shall provide that:

1. the Anti-Corruption Task Force has the

following tasks:

(a) examine existing anti-corruption measures

and elaborate proposals to improve them;

(b) put forward proposals to

53

Seq.

Number

Related Measure

(Reform or

Investment)

Milestone /

Target Name

Qualitative

indicators

(for milestones)

Quantitative indicators

(for targets)

Indicative

timeline for

completion Description of each milestone and target

Unit of

measure Baseline Goal Quarter Year

(i) improve corruption prevention and

detection,

(ii) boost the flow of information

between administrative and control

authorities of the state and criminal

investigation authorities;

(c) assess how its previous proposals were

followed-up and implemented;

(d) prepare a publicly available annual report .

The legislation shall require that that report

shall (i) analyse the risks and trends of

corruption and corrupt practices, (ii) propose

countermeasures and best practices for the

prevention, detection and sanctioning

corruption risks and corruption types, assessing

their applicability, and (iii) assess how its

previous proposals were followed up and

implemented.

2. the government systematically discusses the

reports and proposals of the Anti-Corruption

Task Force within two months of their

publication and provides a reasoning for its

decision on each of the proposals it decided not

to implement.

3. non-governmental actors active in the field

of anti-corruption shall make up at least 50% of

the members of the Anti-Corruption Task

Force (the chair excluded). The legislation shall

require that (i) such members are demonstrably

independent from the government, public

authorities, political parties and business

interests; (ii) they shall be selected based on an

open, transparent, non-discriminatory selection

process and objective criteria related to the

candidates’ expertise and merit; and (iii) if the

number of members from non-governmental

54

Seq.

Number

Related Measure

(Reform or

Investment)

Milestone /

Target Name

Qualitative

indicators

(for milestones)

Quantitative indicators

(for targets)

Indicative

timeline for

completion Description of each milestone and target

Unit of

measure Baseline Goal Quarter Year

actors falls below 50%, the share of their votes

shall be modulated to achieve 50% of the total

of votes (excluding the chair).

4. the president of the Integrity Authority acts

as the chair of the Anti-Corruption Task Force

and that it works independently from the

Integrity Authority.

5. the Anti-Corruption Task Force meets at

least twice a year and make decisions by a

simple majority of votes cast. The legislation

shall require that the minutes of its meetings

shall be made publicly available on the website

for the Anti-Corruption Task Force.

58

C8.R4 Introduction

of a specific

procedure in the

case of special

crimes related to the

exercise of public

authority or the

management of

public

property (‘judicial

review’)

Milestone

Legislative

amendment(s)

concerning a procedure

in the case of certain

corruption and

corruption-related

practices

Adoption and

publication of the

legal act(s) in the

official journal

Q2 2026

Legislative amendment(s) applicable also to

(non time-barred) criminal offences committed

before 1 January 2023, that shall:

- provide for the establishment of a procedure

concerning certain corruption and corruption-

related practices;

- provide for the establishment of judicial

review of the decision of the prosecution

service or the investigating authority to dismiss

a crime report or terminate the criminal

proceedings by the investigating judge of the

Buda Central District Court who shall have the

authority to order the commencement or the

continuation of criminal proceedings. If an

investigation is opened or the proceedings are

continued, the prosecution service or the

investigating authority shall continue the

proceedings on the basis of the reasoning of the

court decision and, in the case of lack of

detection, by remedying the deficiencies

identified therein.

- provide that, following the motion for

revision, if the decision to dismiss a crime

55

Seq.

Number

Related Measure

(Reform or

Investment)

Milestone /

Target Name

Qualitative

indicators

(for milestones)

Quantitative indicators

(for targets)

Indicative

timeline for

completion Description of each milestone and target

Unit of

measure Baseline Goal Quarter Year

report or terminate the criminal proceedings

was set aside by the investigating judge, in case

of a repeated termination of the procedure, it

will be possible to file an indictment to the

court of law. Under conditions specified in the

legislative act, the procedure shall open the

right to file an indictment to the competent

court which shall decide on the merits of the

case after having heard evidence. An

examination of the grounds of a motion for

prosecution shall be limited (e.g., as to whether

the person specified as accused can be

reasonably suspected of having committed the

criminal offence subject to the motion for

prosecution, and/or whether the person

specified enjoys immunity) with the aim to

avoid a substantive filtering which would risk

anticipating or preventing a ruling on the merits

without the possibility to seek and hear

evidence in the case. Natural persons and legal

persons can (subject to specified provisions)

file motions under this procedure with the

exception of public authorities, however, the

Integrity Authority shall have the right to file a

motion for revision and a repeated motion for

revision.

The provisions laid down in Chapter CV/A of

Act XC of 2017 on Criminal Procedure shall

apply and the investigating authority or the

prosecution service shall adopt a new decision

on the crime report under Section 379 also if a)

the crime report filed after 31 December 2022

concerns the same act as the act subject to a

prior crime report that was filed and dismissed

before 1 January 2023 or where the

investigation was terminated before 1 January

2023, b) Chapter CV/A would apply to the

crime report filed after 31 December 2022.

56

Seq.

Number

Related Measure

(Reform or

Investment)

Milestone /

Target Name

Qualitative

indicators

(for milestones)

Quantitative indicators

(for targets)

Indicative

timeline for

completion Description of each milestone and target

Unit of

measure Baseline Goal Quarter Year

59

C8.R5 Amendment

of rules related to

asset declarations

Milestone

Entry into force of

legislative amendments

extending the personal

and material scope of

asset declarations,

while ensuring

frequent disclosure

Provision in the

legislative

amendments

indicating entry

into force

Q2 2026

Legislative amendments shall enter into force

that provide for:

(i) senior political executives (under Sections

183 and 184 of Act CXXV of 2018 on

government administration) and their relatives

living in the same household with the persons

concerned, as well as members of the National

Assembly and their relatives living in the same

household as the members concerned shall

submit asset declarations upon taking up duties,

annually thereafter and at the time of leaving

their duties;

(ii) all individuals falling under the personal

scope in point (i) shall be obliged to declare at

least: revenues, real estate properties, other

valuable properties (which shall include but is

not limited to vehicles, vessels, valuable

antiques, work of art), savings in bank deposits

and cash, assets in stocks, securities and private

equity funds, life insurance policies, trusts, and

beneficial ownership of enterprises.

60

C8.R5 Amendment

of rules related to

asset declarations

Milestone

Entry into force of

legislative amendments

on setting up a system

for the electronic

submission of asset

declarations in digital

format and a public

database for asset

declarations

Provision in the

legislation

indicating entry

into force

Q2 2026

Entry into force of legislative amendments that

shall provide for:

- the legal basis and obligation to set up a

system to which asset declarations of

senior political executives (under Sections

183 and 184 of Act CXXV of 2018 on

government administration) and their

relatives living in the same household

with the persons concerned, as well as

members of the National Assembly and

their relatives living in the same

household as the members concerned shall

be submitted electronically and in which

they are filed electronically in a digital

format.

57

Seq.

Number

Related Measure

(Reform or

Investment)

Milestone /

Target Name

Qualitative

indicators

(for milestones)

Quantitative indicators

(for targets)

Indicative

timeline for

completion Description of each milestone and target

Unit of

measure Baseline Goal Quarter Year

- the legal basis and obligation to setup a

searchable database where asset

declarations filed by senior political

executives (under Sections 183 and 184 of

Act CXXV of 2018 on government

administration) and members of the

National Assembly, are made available to

the public free-of-charge and without

registration.

61

C8.R5 Amendment

of rules related to

asset declarations

Milestone

Introduction of

sanctions concerning

the violations of asset

declaration obligations

Provision in the

legislation

indicating entry

into force of

Q2 2026

Entry into force of a legislative amendments

establishing criminal sanctions, administrative

fines and related mandate- or legal-relationship

consequences for breaches of asset declaration

obligations.

Criminal sanctions should apply to the

following situations: a) failure to submit an

asset declaration through one’s own fault

following a call to do so by the competent

entity, b) concealing one’s financial situation in

respect of a material fact by making an asset

declaration with a false content, by withholding

a true fact or by any other means.

Where the Integrity Authority establishes a

serious breach, it shall initiate the applicable

mandate- or legal-relationship consequences

before the competent body, person, authority or

court, including, where provided for by law,

pecuniary consequences.

Administrative fines shall apply to non-

intentional, purely administrative deficiencies

not falling under such serious breaches,

including failure to remedy them following the

Authority’s recommendation or proposed

measure, unless the deficiency is minor or

negligible and has been remedied.

58

Seq.

Number

Related Measure

(Reform or

Investment)

Milestone /

Target Name

Qualitative

indicators

(for milestones)

Quantitative indicators

(for targets)

Indicative

timeline for

completion Description of each milestone and target

Unit of

measure Baseline Goal Quarter Year

62

C8.R6 Entry into

force of legal acts

on the transparency

of the use of public

resources by public

interest asset

management

foundations

Milestone

Entry into force of

legislative amendments

concerning oversight

on how public interest

asset management

foundations

performing public

interest duty and legal

persons established or

maintained by them

make use of Union

support

Provision in the

legislative

amendments

indicating entry

into force

Q2 2026

Entry into force of legislative amendments that

shall provide for the:

(i) designation of public interest asset

management foundations performing public

duty and the legal persons established or

maintained by them as contracting authorities

within the meaning of rules on public

procurement;

(ii) requirement that public interest asset

management foundations performing public

duty and legal persons established or

maintained by them shall be subject to access

to public information requirements;

(iii) the legal basis and obligation for the

phasing out of public interest asset

management foundations performing public

duty which do not maintain a higher education

institution in Hungary; and

(iv) compliance of rules applicable to all

individuals holding office or being employed

by public interest asset management

foundations performing public duty which

maintain higher education institutions in

Hungary and the legal persons established or

maintained by them with the provisions of

Article 61 of Regulation (EU, Euratom)

2024/2509 irrespective of their other activities

and functions, including in the Hungarian

government.

63

C8.R7 Enhancing

the transparency of

public spending

Milestone

Entry into force of a

legislation to enhance

the transparency of

public spending

Provision in the

legislation

indicating entry

into force

Q2 2026

Entry into force of legislation providing for an

obligation for bodies carrying out public duties

as defined in Section 37/C of Act CXII of 2011

(covering at least legal persons included in the

treasury register, publicly owned economic

operators, and foundations established by them;

asset management foundations established by

the state, public interest asset management

59

Seq.

Number

Related Measure

(Reform or

Investment)

Milestone /

Target Name

Qualitative

indicators

(for milestones)

Quantitative indicators

(for targets)

Indicative

timeline for

completion Description of each milestone and target

Unit of

measure Baseline Goal Quarter Year

foundations carrying out public duties and legal

persons established or maintained by them, the

HUN-REN Research Network) to proactively

publish a pre-defined set of information on the

use of public funds into a central register. The

information shall be made available in a central

register, which shall also provide information

on sub-contractors and include, where relevant,

unique identifiers of contracts in the Electronic

Public Procurement System (EPS)

The legislation shall provide that the minimum

set of data to be uploaded in the central register

shall include:

(i) all data for which publication is already

compulsory for transparency purposes,

including the data published in the State aid

transparency register;

(ii) the form of public spending including its

legal basis;

(iii) the recipient’s full legal name (for a legal

person) or the recipient’s first and last name

(for natural persons);

(iv) the value of the public spending;

(v) whether the recipient is a natural or a legal

person;

(vi) a unique identifier for legal persons (VAT

identification number or tax identification

number where available or another unique

identifier established at national level);

(vii) contract details relating to the spending of

public funds, including their nature and

purpose (type of contract used, type of tender

procedure used, contract value, date of

signature, duration of contract, objective to be

60

Seq.

Number

Related Measure

(Reform or

Investment)

Milestone /

Target Name

Qualitative

indicators

(for milestones)

Quantitative indicators

(for targets)

Indicative

timeline for

completion Description of each milestone and target

Unit of

measure Baseline Goal Quarter Year

achieved, deliverable to be delivered under the

contract);

(viii) tender documentation relating to the

spending of public funds, including their nature

and purpose (estimated value, type of public

procurement procedure, date of tendering,

number of offers submitted, name of

tenderers);

(ix) the name of service providers, including

the name of subcontractors, suppliers, and

capacity providers, in a free text format for

historical data, and in a format processable by

machine means for future public procurements;

(x) the intended share of subcontractors if

available, both for past and future public

procurements;

(xi) the public body responsible;

(xii) the date when the funds were disbursed.

The legislation shall provide that information

whether the public funds involve (fully or

partially) Union support is also made available

in the central register: a) for public funds above

the national public procurement threshold and

b) for procurement procedures which started

after 31 March 2023, also for procedures

involving Union support not exceeding the

national public procurement thresholds.

The legislation shall provide that data sets

published in the central register are required to

be published in an open, interoperable and

machine-readable format, which allows bulk

download and data to be sorted, searched,

extracted, compared and reused. It shall also be

ensured that access to the data is provided free

of any charge and without the need to register.

61

Seq.

Number

Related Measure

(Reform or

Investment)

Milestone /

Target Name

Qualitative

indicators

(for milestones)

Quantitative indicators

(for targets)

Indicative

timeline for

completion Description of each milestone and target

Unit of

measure Baseline Goal Quarter Year

The legislation shall provide for an obligation

that the bodies update the data in the central

register at least every two months.

The legislation shall require the control of

compliance with and enforcement of the

obligations of the above requirements.

64

C8.R8 Rules

ensuring the

transparency of

beneficial owners of

entities and

clarifying the use of

public subsidies

Milestone

Legislative

amendments ensuring

the transparency of

data of natural persons

who are the beneficial

owners and legislation

to clarify the scope of

public officials and

entities that are

excluded from

receiving public

subsidies

Provision in the

legislation

indicating entry

into force

Q2 2026

Entry into force of legislative amendments

providing for the transparency of and access to

data on beneficial owners.

Those legislative amendments shall:

- Revise the definition of beneficial owner

to include specific provisions on private

investment funds

- Include the beneficial owner of private

investment funds/a fiduciary asset

management relationship in the list of

legal entities that need to communicate

their beneficial owner;

- Include journalists and civil society

organisations in the list of natural or legal

persons deemed to have a legitimate

interest in accessing beneficial ownership

data

- Ensure that bodies responsible for the

management and control of Union support

in Hungary have the possibility to gather

information on and verify the beneficial

owners of private equity funds from at

least 1 February 2020.

Entry into force of legislation providing for the

clarification and the extension of the scope of

excluded public officials and the scope of

entities that cannot apply for or receive

subsidies provided from public funds.

62

Seq.

Number

Related Measure

(Reform or

Investment)

Milestone /

Target Name

Qualitative

indicators

(for milestones)

Quantitative indicators

(for targets)

Indicative

timeline for

completion Description of each milestone and target

Unit of

measure Baseline Goal Quarter Year

65

C8.R9 Reducing the

share of single-bid

public procurement

procedures

Milestone

The share of tender

procedures with single

bids for procurements

financed from Union

support shall not

exceed 15 %

Share of tender

procedures with

single bids for

procurements

financed from

Union

Q2 2026

The share of public procurement tender

procedures reported in the single-bid reporting

tool – covering public procurement procedures

with an estimated value both above and below

the EU public procurement thresholds – closed

between 1 January and 31 December in 2022-

2025 and 1 January and 31 March in 2026 with

single bids for procurements at least partially

financed from Union support is below 15%. An

audit report with unqualified audit opinion by

EUTAF shall confirm that the share of single

bids is below 15%.

66

C8.R9 Reducing the

share of single-bid

public procurement

procedures

Milestone

Setting up of a

monitoring and

reporting tool (‘single-

bid reporting tool’)

The monitoring

and reporting tool

is functional

Q2 2026

A tool shall be developed for monitoring and

reporting public procurement procedures

closed with single bids.

An audit report with an unqualified audit

opinion by the audit authority (EUTAF) shall

confirm that the monitoring and reporting tool

is functional, its functionalities are in

accordance with the methodology of the Single

Market Scoreboard and that data (with the

exception of geographical indications) in the

system used for the purposes of monitoring and

reporting is accurate and complete, including

for baseline values.

It shall be ensured that written reports based on

information from the single-bid reporting tool

are prepared and made publicly available on

the Electronic Public Procurement System

(EPS) website.

67

C8.R10 Reinforcing

integrity,

transparency and

competitiveness in

the public

procurement market

Milestone

Legal act(s) on public

procurement to

reinforce the

transparency of public

procurement

procedures, introduce

Provision in the

legal act(s)

indicating entry

into force

Q2 2026

Entry into force of legal act(s) on public

procurement to

- introduce the definition of ‘transparent

economic operator’;

- exclude economic operators from public

procurement procedures that do not

63

Seq.

Number

Related Measure

(Reform or

Investment)

Milestone /

Target Name

Qualitative

indicators

(for milestones)

Quantitative indicators

(for targets)

Indicative

timeline for

completion Description of each milestone and target

Unit of

measure Baseline Goal Quarter Year

corruption-prevention

rules

qualify as ‘transparent economic

operators;

- define conflict of interest provisions

regarding beneficial owners of tenderers

and relatives;

- introduce an obligation for contracting

authorities to make public procurement

documents (excluding electronic forms)

directly and unrestrictedly available, free

of charge on the public interface of the

EPS;

- introduce an obligation for contracting

authorities to publish data annually on the

performance of contracts;

- introduce an obligation in case of

concessions to record in writing and

publish in the procurement documents

upon the commencement of the procedure

the results of the preliminary market

survey, the calculations of the return on

the concessionaire’s investment and

measures taken to ensure competition;

- deem a procedure for the award of

concessions unsuccessful if only one bid

has been submitted unless the contracting

authority demonstrates that the lack of

competition is a consequence of the actual

structure of the market;

- provide for the explicit possibility for

contracting authorities to include anti-

corruption conditions relating to the

performance of a contract to strengthen

transparency, accountability and integrity;

- introduce an obligation that contracting

authorities shall stipulate as a contractual

condition that the successful tenderer shall

64

Seq.

Number

Related Measure

(Reform or

Investment)

Milestone /

Target Name

Qualitative

indicators

(for milestones)

Quantitative indicators

(for targets)

Indicative

timeline for

completion Description of each milestone and target

Unit of

measure Baseline Goal Quarter Year

cooperate to reduce the risks of corruption

offences;

- provide that the Public Procurement

Arbitration Board is required to issue a

notice setting out the principles of

imposing fines;

- extend the possibility of the Integrity

Authority to initiate ex officio review

procedure before the Public Procurement

Arbitration Board beyond public

procurement procedures relating to EU

funds;

- provide that the president of the Integrity

Authority shall also act as an ex officio

member of the Public Procurement

Council.

68

C8.R11

Development of the

Electronic Public

Procurement

System (EPS) to

increase

transparency

Milestone

The EPS upgraded

with the new

functionalities is

accessible to the public

Audit report

confirming the

functioning of the

new

functionalities of

the EPS.

Q2 2026

An audit report with unqualified audit opinion

by an independent auditor shall confirm that:

- the functions of the Electronic Public

Procurement System (EPS) allow the

structured search in contract award notice

data and bulk export of all contract award

notice data published in the EPS in a

machine-readable format (including the

names of each individual member of

consortia, the names of sub-contractors

and company identification numbers

where this was provided in the dedicated

fields of the contract award notice) is

functional.

- those functions allow for the gathering,

filtering and comparison of data across

contract award notices and related to

different public procurement subject

matters covering information from

different types of contract award notices.

65

Seq.

Number

Related Measure

(Reform or

Investment)

Milestone /

Target Name

Qualitative

indicators

(for milestones)

Quantitative indicators

(for targets)

Indicative

timeline for

completion Description of each milestone and target

Unit of

measure Baseline Goal Quarter Year

- a database is published in the EPS,

containing information on contract award

notices of public procurement procedures

published in the EPS in a structured form,

which is fit to be processed by machine

means.

- economic operators in the database,

including members of consortia, are

identifiable by a unique identifier (tax

number where this was provided in the

dedicated fields of the contract award

notice).

- the database is updated regularly, and it is

freely accessible and downloadable by

anyone from the EPS website without

registration.

69

C8.R12

Performance

measurement

framework for

public procurements

Milestone

Establishment of a

performance

measurement

framework of public

procurements

Publication on the

EPS website of a

performance

measurement

framework

Q2 2026

Publication on the EPS website of the

performance measurement framework to assess

(i) the efficiency and cost-effectiveness of

public procurements and (ii) the possible

reasons for- and effects of limited competition

in public procurement procedures, and the

sectors most affected by public procurement

procedures resulting in single bids.

The performance measurement framework

shall enable the annual analysis of:

(i) the level of unsuccessful public procurement

processes and their reasons,

(ii) the share (measured by reference to both

number and value) of contracts that are entirely

cancelled during contract execution,

(iii) the share of occurrence of delays in the

contract performance,

66

Seq.

Number

Related Measure

(Reform or

Investment)

Milestone /

Target Name

Qualitative

indicators

(for milestones)

Quantitative indicators

(for targets)

Indicative

timeline for

completion Description of each milestone and target

Unit of

measure Baseline Goal Quarter Year

(iv) the share of occurrence of cost overruns

(including their proportion and volume),

(v) the share of awarded procurement contracts

in which the whole life-cycle or life-cycle

costing is explicitly taken into consideration,

(vi) the share of successful participation of

micro- and small enterprises in public

procurements, considered across sectors and

per sector concerned (based on CPV divisions

and groups),

(vii) the proportion by value of public

procurement procedures with single bids and

the proportion by value of public procurement

procedures with single bids financed from

national resources and from Union support

separately.

70

C8.R13Action plan

for increasing the

level of competition

in public

procurement

Milestone

Adoption of an action

plan to increase the

level of competition in

public procurements

Publication of

the action plan

adopted by the

government

Q2 2026

The Government shall adopt, publish and

annually review an action plan aiming to

increase the level of competition in public

procurement.

The action plan shall: (i) set out objectives to

be achieved; (ii) define measures to achieve the

objectives; (iii) set precise deadlines for the

implementation of the measures; (iv) identify

the body/ies responsible for implementing the

measures; (v) establish a monitoring

mechanism to assess progress.

71 C8.R14 Reinforcing

the role and powers

of the National

Judicial Council

aimed at

counterbalancing

the powers of the

President of the

Milestone Entry into force of

legislative amendments

to strengthen the role

of the National Judicial

Council

Provision in the

legislative

amendments

indicating their

entry into force

Q2 2026 Legislative amendments to strengthen the role

of the National Judicial Council (NJC) shall

a) establish stronger powers for the NJC

by adopting the following provisions:

Regarding individual decisions, the

legislative amendments shall provide for

the provision of a motivated binding

67

Seq.

Number

Related Measure

(Reform or

Investment)

Milestone /

Target Name

Qualitative

indicators

(for milestones)

Quantitative indicators

(for targets)

Indicative

timeline for

completion Description of each milestone and target

Unit of

measure Baseline Goal Quarter Year

National Office for

the Judiciary

opinion by the NJC on the following

matters:

(i) the annulment, by the President

of the National Office for the

Judiciary (NOJ), of appointment

procedures for judicial and court

executive positions where there

is at least one eligible candidate

who has been supported by the

judges of the given court;

(ii) the transfer of judges, including

secondments, to another court by

the President of the NOJ referred

to in Sections 27, 27/A, 31 and

32 of Act CLXII of 2011, except

for secondments to the NOJ;

(iii) the removal, by the President of

the NOJ, of judges without their

consent from the pool of judges

that hear special cases, including

administrative cases;

(iv) the suitability of candidates for

the post of President and Vice-

President of the NOJ, that can be

proposed by the President of the

Republic or the President of the

NOJ, respectively; the suitability

criteria, including independence,

impartiality, probity and

integrity, shall be determined by

the law. The legislative

amendments shall ensure that the

candidates found unsuitable by

the NJC shall have access to an

accelerated judicial review

before the competent court.

68

Seq.

Number

Related Measure

(Reform or

Investment)

Milestone /

Target Name

Qualitative

indicators

(for milestones)

Quantitative indicators

(for targets)

Indicative

timeline for

completion Description of each milestone and target

Unit of

measure Baseline Goal Quarter Year

Regarding regulations, the legislative

amendments shall ensure that the NJC

shall give a motivated binding opinion on

the following matters:

(i) the points system for the

assessment of applications for

judicial posts within the

legislative framework;

(ii) the detailed conditions for the

award of bonuses and other

benefits to judges and court

executives;

(iii) the rules relating to the training

system for judges;

(iv) the data sheet and methods for

the assessment of the workload

of judges, as well as the

determination of the ‘national

workload for contentious and

non-contentious proceedings

broken down according to

judicial level and case types’,

(v) the number of judicial posts in

each court within the framework

determined in the annual budget,

including the Kúria, and their

departments;

b) establish the right of the NJC to have

access to all documents, information and

data related to the administration of the

courts. In addition, the legislative

amendments shall provide that the NJC

shall determine the structure of the

biannual report of the President of the

NOJ;

69

Seq.

Number

Related Measure

(Reform or

Investment)

Milestone /

Target Name

Qualitative

indicators

(for milestones)

Quantitative indicators

(for targets)

Indicative

timeline for

completion Description of each milestone and target

Unit of

measure Baseline Goal Quarter Year

c) endow the NJC with legal capacity and

autonomy in disbursement of its budget

and state that the President of the NOJ in

his capacity concerning the budget of

courts draws up a proposal for the budget

of the courts and a report on its

implementation, as defined, inter alia, by

the NJC in respect of the NJC, which the

Government shall submit to Parliament

without amendment. The legislative

amendments shall also provide that, in

order to carry out their tasks in the NJC,

judges-members shall be entitled to be

relieved from their adjudicating duties to

the extent regional court (törvényszék)

presidents are relieved from their

adjudicating duties. The legislative

amendments shall provide that judges-

members of the NJC cannot be re-elected

except for the next term of office, that

judges-members of the NJC shall elect

from among themselves the chairperson of

the NJC, and that court presidents and

vice-presidents as members of the NJC

shall not participate in the deliberation and

vote on matters relating to their

administrative activities;

d) establish the right for the NJC to seize the

competent court and the Constitutional

Court to defend its prerogatives and

enforce its rights;

e) establish an obligation to consult the NJC

on legislative proposals affecting the

justice system and the right to propose to

the Government to initiate new legislation

on the same matters;

f) establish non-discretionary rules on the

designation of ad interim court presidents

70

Seq.

Number

Related Measure

(Reform or

Investment)

Milestone /

Target Name

Qualitative

indicators

(for milestones)

Quantitative indicators

(for targets)

Indicative

timeline for

completion Description of each milestone and target

Unit of

measure Baseline Goal Quarter Year

through a pre-set order of positions within

a court as follows: (i) in the absence of a

court president, the president’s

competences are exercised by the vice-

president; (ii) in the absence of a vice-

president, the president’s competences are

exercised by the head of a department of

judges with the longest tenure as a judge;

(iii) in the absence of a head of department,

the president’s competences are exercised

by the presiding judge with the longest

tenure as a judge;

g) prohibit the reintegration, by the President

of the NOJ, of judges, following their

secondment, to a court instance higher than

the court in which they adjudicated before

their secondment.

72 C8.R15 Judicial

independence of the

Supreme Court

(Kúria)

Milestone Entry into force of

amendments on

judicial independence

of the Supreme Court

Provision in the

legislative

amendments

indicating their

entry into force

Q2 2026 a) Legislative amendments shall enter into

force amending the rules on the election of

the Kúria President in order to provide for

the following: (i) the candidates have at

least five years’ experience as a judge; (ii)

the Kúria President cannot be re-elected;

(iii) the NJC gives a motivated binding

opinion on the suitability of the candidates

for the post of Kúria President that can be

proposed by the President of the Republic.

The suitability criteria, including

independence, impartiality, probity and

integrity, shall be determined by the law.

The legislative amendments provide for the

candidates found unsuitable by the NJC to

have access to an accelerated judicial

review before the competent court;

b) legislative amendments, and other

amendments, to the rules on the case

allocation scheme of the Kúria shall enter

into force, providing for the following: (i)

71

Seq.

Number

Related Measure

(Reform or

Investment)

Milestone /

Target Name

Qualitative

indicators

(for milestones)

Quantitative indicators

(for targets)

Indicative

timeline for

completion Description of each milestone and target

Unit of

measure Baseline Goal Quarter Year

electronically filed cases be given a case

number without human intervention; (ii)

cases be allocated to chambers following

pre-established, objective criteria; (iii) the

bench hearing the case be composed

following an algorithm prescribed in

advance; (iv) the parties to proceedings be

able to verify on the basis of the case file

whether the rules on case allocation have

been duly applied; (v) the judicial council

of the Kúria and the departments of judges

(‘kollégium’) concerned give a binding

opinion on the case allocation scheme;

c) legislative amendments shall enter into

force amending the rules on the

functioning of the Kúria by

(i) establishing stronger powers for

the judicial council of the Kúria

and the departments of judges

(‘kollégium’) concerned,

ensuring, in particular, that they

shall give a binding opinion on

(a) candidates for the post of

chairs and vice-chairs of

departments of judges,

presiding judges and the

Secretary General of the

Kúria;

(b) secondments to the Kúria;

(ii) removing the possibility for

members of the Constitutional

Court to become judges and then

be appointed to the Kúria

without following the normal

application procedure,

72

Seq.

Number

Related Measure

(Reform or

Investment)

Milestone /

Target Name

Qualitative

indicators

(for milestones)

Quantitative indicators

(for targets)

Indicative

timeline for

completion Description of each milestone and target

Unit of

measure Baseline Goal Quarter Year

(iii) ensuring that the NJC gives a

motivated binding opinion on the

suitability of candidates for the

post of Vice President of the

Kúria that can be proposed by

the Kúria President. The

suitability criteria, including

independence, impartiality,

probity and integrity, shall be

determined by the law. The

legislative amendments shall

ensure that candidates found

unsuitable by the NJC shall have

access to an accelerated judicial

review before the competent

court.

(iv) ensuring that the strengthened

powers of the NJC referred to in

milestone 71 also apply in

relation to the Kúria President

when acting as appointing

authority (in line with Act CLXII

of 2011).

73 C8.R16: Removing

obstacles to

references for

preliminary rulings

to the Court of

Justice of the

European Union

Milestone Entry into force of

legislative amendments

to remove obstacles to

references for

preliminary rulings to

the Court of Justice of

the European Union

Provision in the

legislative

amendments

indicating their

entry into force

Q2 2026 Legislative amendments shall enter into force

ensuring that:

(i) Sections 666 et seq. of the Criminal

Procedure Code are amended in order to

remove the possibility for the Kúria to review

the legality of the decision of a judge to make a

preliminary reference to the Court of Justice of

the European Union, and (ii) Section 490 of the

Criminal Procedure Code on staying the

proceedings is amended in order to remove any

obstacle to a court to make a preliminary

reference in line with Article 267 TFEU.

74 C8.R17 Reform

regarding the review

Milestone Entry into force of

legislative amendments

Provision in the

legislative

Q2 2026 Legislative amendments shall enter into force

providing for the removal of the possibility,

73

Seq.

Number

Related Measure

(Reform or

Investment)

Milestone /

Target Name

Qualitative

indicators

(for milestones)

Quantitative indicators

(for targets)

Indicative

timeline for

completion Description of each milestone and target

Unit of

measure Baseline Goal Quarter Year

of final judgments

by the

Constitutional Court

to remove the

possibility for public

authorities to challenge

final decisions before

the Constitutional

Court

amendments

indicating their

entry into force

introduced in 2019 by amending Section 27 of

Act CLI of 2011, for public authorities to

challenge before the Constitutional Court final

judicial decisions.

75

C8.R18 Legislative

amendments

strengthening the

management,

monitoring, audit

and control

mechanisms to

guarantee the sound

use of Union

support

Milestone

Legal act(s) providing

for the legal mandate

for the management,

audit and control of the

recovery and resilience

plan and regulating the

management,

monitoring, control

and audit of the funds

under Regulation (EU)

2021/1060 in Hungary

Provision in the

legal act(s)

indicating its

entry into force

Q2 2026

Entry into force of legal act(s) providing for the

definition of the legal mandate for the bodies

involved in the implementation, audit and

control of the recovery and resilience plan in

Hungary also beyond 2026.

Those legislative requirements shall set out the

roles and responsibilities of those bodies

providing:

(a) for the collection and reliability of data

linked to and monitoring of the achievement of

milestones and targets;

(b) that procedures are in place for the drawing

up and reliability of management declarations,

audit summaries and payment requests;

(c) that procedures are in place to collect and

store data on final recipients, contractors,

subcontractors, and beneficial owners in

accordance with Article 22 of Regulation (EU)

2021/241 establishing the Recovery and

Resilience Facility;

(d) that clear obligations on conflict of interest

apply to all staff involved in the

implementation (including acts preparatory

thereto), control (including to internal and

external evaluators in public procurement

procedures) and audit of the recovery and

resilience plan and to final recipients,

contracting authorities, contractors, sub-

contractors, as well as consultancy firms

74

Seq.

Number

Related Measure

(Reform or

Investment)

Milestone /

Target Name

Qualitative

indicators

(for milestones)

Quantitative indicators

(for targets)

Indicative

timeline for

completion Description of each milestone and target

Unit of

measure Baseline Goal Quarter Year

involved in project preparation and

implementation;

(e) that conflict of interest rules explicitly

address situations involving family, emotional

life, political or national affinity, economic

interest or any other direct or indirect personal

interest that may be perceived as a conflict of

interest in line with Article 61 of Regulation

(EU, Euratom) 2024/2509 and the related

Commission Notice (‘Guidance on the

avoidance and management of conflicts of

interest under the Financial Regulation’ [C

121/01]);

(f) that staff involved in the decision making

concerning individual projects (in particular

decisions on eligibility, risk assessment,

selection of projects, interim and final control

procedures, irregularity management, and

audit-related decisions) shall be obliged to

issue a declaration of their absence of conflict

of interest on a case by case basis, which shall

be stored for at least 5 years;

(g) that the veracity of conflict of interest

declarations is regularly controlled and the

results of those controls are stored for at least 5

years;

(h) that those bodies engage in comprehensive

ex post controls to determine whether all

applicable rules have been respected, in

particular regarding fraud, corruption, conflict

of interest and double funding. It shall be

required that such ex post controls cover a

sufficiently high degree of the population of

financing agreements signed and public

procurement contracts awarded for measures in

the recovery and resilience plan, where the

specific agreements/contracts, including

75

Seq.

Number

Related Measure

(Reform or

Investment)

Milestone /

Target Name

Qualitative

indicators

(for milestones)

Quantitative indicators

(for targets)

Indicative

timeline for

completion Description of each milestone and target

Unit of

measure Baseline Goal Quarter Year

payments, that should be selected for ex post

controls should be selected on a risk basis. It

shall additionally be required that those ex post

controls make use of the data and information

available following the implementation of

milestone 59, 63, 64 and 78 and consider

whether the approval/award of those

agreements/contracts complies with the

obligations stemming from the legislation

referred to in milestone 62. The legal act shall

provide that those ex post controls are done in a

manner respecting the legal act referred to in

milestone 73.

(i) that procedures for the oversight of staff in

sensitive positions (such as dealing with

irregularity management, controls and risk-

assessment) are in place;

(j) that bidders shall not participate in tenders

in public procurement procedures in case

conflict of interest relevant to them in that

specific tender is established.

Legal act(s) on the management, monitoring,

control and audit of the funds under Regulation

(EU) 2021/1060 in Hungary shall provide for

points (d)-(g) and (i)-(j) above where the

provisions in point (d) shall also apply to

beneficiaries of operations.

76

C8.R18 Legislative

amendments

strengthening the

management,

monitoring, audit

and control

mechanisms to

guarantee the sound

use of Union

support

Milestone

Rules to ensure the

prevention, detection

and correction of

conflict of interest for

the staff of all bodies

involved in the

management and

control of Union

support in Hungary

Provision in the

legal act(s)

indicating its

entry into force

and adoption of

procedures

Q2 2026

Entry into force of legal act(s) providing for

(i) provisions on the prevention, detection

and correction of conflict of interest

situations in line with Article 61 of

Regulation (EU, Euratom) 2024/2509 and

the related Commission Notice

(‘Guidance on the avoidance and

management of conflicts of interest under

the Financial Regulation’ [C 121/01]).

76

Seq.

Number

Related Measure

(Reform or

Investment)

Milestone /

Target Name

Qualitative

indicators

(for milestones)

Quantitative indicators

(for targets)

Indicative

timeline for

completion Description of each milestone and target

Unit of

measure Baseline Goal Quarter Year

(ii) setting out of the tasks and obligations for

the bodies involved in the management

and control of Union support concerning

their role in the prevention, detection and

correction of conflict of interest situations.

(iii) the legal basis and obligation for those

bodies to put procedures in place to that

effect.

Those procedures shall have been adopted.

77

C8.R19 Anti-fraud

and anti-corruption

strategy for the

implementation,

audit and control of

Union support

Milestone

Adoption of an anti-

fraud and anti-

corruption strategy for

Union support and a

related action plan

Adoption of an

anti-fraud and

anti-corruption

strategy for

Union support

and the related

action plan

Q2 2026

The government shall adopt an anti-fraud and

anti-corruption strategy for all Union support

providing:

(i) the roles and responsibilities related to the

prevention, detection and correction of fraud,

conflict of interest and corruption of the

different entities involved in the

implementation of Union financial support in

Hungary;

(ii) the assessment of the main risks, factors

and practices of fraud, conflict of interest and

corruption.

An action plan linked to the above strategy

shall be adopted by the government that shall:

(i) define actions; (ii) set deadlines for the

accomplishment of each of the actions; (iii)

identify for each of the actions the body/ies

responsible for its implementation; (iv) define

indicators to measure progress in implementing

each of the actions; (v) set out arrangements for

the regular review of the actions.

78

C8.R20 The

Arachne system for

Union support

Milestone

The systematic use of

the Arachne risk-

scoring tool

Entry into force

of legislative

provisions

ensuring the

systematic use of

Q2 2026

Entry into force of legislative provisions

providing for the obligation for the use of the

functionalities of the Arachne risk-scoring tool

in the management, control and audit of the

recovery and resilience plan, as well as Union

77

Seq.

Number

Related Measure

(Reform or

Investment)

Milestone /

Target Name

Qualitative

indicators

(for milestones)

Quantitative indicators

(for targets)

Indicative

timeline for

completion Description of each milestone and target

Unit of

measure Baseline Goal Quarter Year

the Arachne risk-

scoring tool

support from funds under Regulation (EU)

2021/1060 with the exception of support under

the European territorial cooperation goal and

under Regulation (EU) 2021/2115 in Hungary.

The legislative provisions shall provide for:

(i) an obligation that authorities upload every

two months into the Arachne system all data

for the data fields set out in the applicable EU

regulations in a timely manner in accordance

with procedures to be developed;

(ii) an obligation that authorities carry out

additional checks in case the Arachne risk-

scoring tool – including for the ex-ante

verification of applicants – signals a risk, and

are bound to take into account the risk-scoring

results generated by the Arachne risk-scoring

tool in their decision-making procedures;

(iii) that the respective audit bodies in Hungary

and in the relevant Commission services and

control bodies have full access to the

functionalities of the Arachne risk-scoring tool

for the purposes of their risk-assessment and to

the data in the system; and

(iv) an obligation that the authorities prepare

procedures setting out detailed requirements for

the practical use of the Arachne risk-scoring

tool and timely and comprehensive data upload

in it.

79

C8.R20 The

Arachne system for

Union support

Milestone

The systematic use of

the Arachne risk-

scoring tool

Audit report

confirming the

adequacy of

procedures on the

systematic and

effective use of

the Arachne risk-

scoring tool and

Q2 2026

Concerning the recovery and resilience plan

and Union support from the funds under

Regulation (EU) 2021/1060 with the exception

of support under the European territorial

cooperation goal, an audit report with an

unqualified audit opinion from the audit

authority (EUTAF) shall verify that:

78

Seq.

Number

Related Measure

(Reform or

Investment)

Milestone /

Target Name

Qualitative

indicators

(for milestones)

Quantitative indicators

(for targets)

Indicative

timeline for

completion Description of each milestone and target

Unit of

measure Baseline Goal Quarter Year

the completeness

of data uploaded

to Arachne

(i) the appropriateness of the procedures set out

in milestone 78 ensure the uploading of a

complete set of information every two months;

(ii) the data set out in the applicable Union law

has actually been uploaded in its entirety in

Arachne: and

(iii) the national bodies put in place

arrangements to ensure the systematic and

regular follow-up of risk-scoring generated by

the Arachne system.

Concerning funds under Regulation

(EU) 2021/2115 in Hungary, an action plan

shall be adopted to apply the same procedures

as outlined above.

80

C8.R21:

Establishment of a

Directorate of

Internal Audit and

Integrity to

reinforce the control

of conflicts of

interest when

implementing Union

support

Milestone

Ensuring effective

prevention, detection

and correction of fraud

and corruption in the

implementation of

Union support through

the setting up and full

functioning of a new

Directorate of Internal

Audit and Integrity

(DIAI)

Provision in the

legal act

indicating its

entry into force

Q2 2026

Entry into force of legal act providing for the

establishment of a new Directorate of Internal

Audit and Integrity (DIAI). That legal act shall

provide that:

(i) the independence of the DIAI is safeguarded

by the nomination of its high-ranking staff,

duration of their mandate without a possibility

to dismiss them;

(ii) the selection of staff of the DIAI shall be

based on objective criteria;

(iii) that the DIAI has the competence to act in

relation to bodies involved in in the

implementation of Union support in Hungary;

(iv) that upon request, the DIAI shall provide

without delay full access to all conflict of

interest declarations and to all its files to the

Integrity Authority;

(v) that rules of procedures governing its

institutional setup and working methods) are in

79

Seq.

Number

Related Measure

(Reform or

Investment)

Milestone /

Target Name

Qualitative

indicators

(for milestones)

Quantitative indicators

(for targets)

Indicative

timeline for

completion Description of each milestone and target

Unit of

measure Baseline Goal Quarter Year

place and subject to oversight by the Integrity

Authority;

(vi) that sufficient financial and human

resources are allocated for the performance of

its tasks;

(vii) that the DIAI regularly controls the

veracity of conflict of interest declarations filed

in relation to the implementation of Union

support in Hungary and that information on

those controls are stored for at least 5 years;

(viii) that the anonymous reporting of any

suspicion regarding conflict of interest is made

possible;

(ix) that the DIAI shall investigate those

reported suspicions;

(x) that the DIAI shall annually report on its

work to the Integrity Authority.

81

C8.R22 Ensuring

the capacity for the

EUTAF to carry out

its tasks

Milestone

Ensuring effective

prevention, detection

and correction of fraud

and corruption in the

implementation of

Union support through

appropriate capacity

for EUTAF

Provision in the

legal act(s)

indicating its

entry into force

Q2 2026

Legal act(s) enter into force providing for the

arrangement of the necessary financial and

human resources for the EUTAF to safeguard

its independence and enable it to carry out its

tasks in an effective manner. The legislative

amendments shall provide that:

- The annual budget of the EUTAF shall be

established on the basis of an initial proposal

by the EUTAF and shall only be modified if

publicly justified and shall not undermine the

EUTAF’s capacity to carry out its tasks in an

effective and timely manner.

- The remuneration of the head of the EUTAF

shall be set at 70% of the remuneration of the

president of the State Audit Office.

- The functional and professional independence

of the EUTAF shall be maintained and the staff

80

Seq.

Number

Related Measure

(Reform or

Investment)

Milestone /

Target Name

Qualitative

indicators

(for milestones)

Quantitative indicators

(for targets)

Indicative

timeline for

completion Description of each milestone and target

Unit of

measure Baseline Goal Quarter Year

of EUTAF shall continue not to seek or accept

instructions regarding its audit work.

82

C8.R23 Cooperation

with OLAF to

reinforce the

detection of fraud

related to the use of

Union support

Milestone

Designation of a

national authority in

charge with assisting

OLAF with its on-the-

spot checks in Hungary

and the introduction of

the possibility to levy

financial sanctions on

non-cooperating

economic actors

Provision in the

legal act

indicating its

entry into force

Q2 2026

Entry into force of legal act(s) providing for:

(i) the designation of the National Tax and

Customs Administration (Nemzeti Adó- és

Vámhivatal, NAV) as the competent national

authority to assist OLAF when carrying out on-

the-spot checks in Hungary and when an

economic operator subject to those checks

refuses to cooperate. The amendment shall

include a description of the procedure to

follow. It shall also introduce the possibility of

the presence of a finance guard at the request of

OLAF. The finance guard shall enable OLAF

to carry out its on-the-spot checks and

inspections, in particular by ensuring

enforcement in order to safeguard evidence as

envisaged in Regulation (EU, Euratom) No

883/2013 and Regulation (Euratom, EC) No

2185/96. This shall include the following types

of intervention: (a) taking things away on the

spot [Section 36/L of Act CXXII of 2010 on

Nemzeti Adó- és Vámhivatal (hereinafter

NAVtv.)], (b) request information [Section 36

of NAVtv.], (c) identity checking [Section

36/A of NAVtv.], (d) entering a place that does

not qualify as a private residence [Section 36/G

of NAVtv.], (e) protection of the scene [Section

36/I (1) of NAVtv.]. The amendment shall set

out that if this assistance requires authorisation

from a judicial authority, such authorisation

shall be applied for by the national AFCOS

(national anti-fraud coordination service) at

least 72 hours in advance. Based on such

authorisation, OLAF may request the presence

of the finance guard in advance, if there is a

risk of resistance to a planned on-the-spot

check and inspection.

81

Seq.

Number

Related Measure

(Reform or

Investment)

Milestone /

Target Name

Qualitative

indicators

(for milestones)

Quantitative indicators

(for targets)

Indicative

timeline for

completion Description of each milestone and target

Unit of

measure Baseline Goal Quarter Year

(ii) amendment of Act XXIX of 2004 to

introduce a dissuasive financial type of

sanction to be imposed in case an economic

operator refuses to cooperate with OLAF for

the purposes of the on-the-spot checks and

inspections.

83

C8.R24 Audit and

control of the

Recovery and

Resilience Plan and

the protection of the

financial interests of

the Union

Milestone

Monitoring system for

the implementation of

the Hungarian

recovery and resilience

plan

EUTAF audit

opinion

confirming the

functioning of the

repository system

for the recovery

and resilience

plan

Q2 2026

An audit report with unqualified audit

opinion from the audit authority (EUTAF) shall

confirm that the repository system for

monitoring the implementation of the recovery

and resilience plan is functional.

The repository system carries out:

(a) the collection of data and monitoring of the

achievement of milestones and targets;

(b) the collection, storing and access to the data

required by Article 22(2)(d)(i) to (iii) of the

RRF Regulation.

Access to data shall be ensured for national and

European bodies for the purpose of audit and

control.

84

C8.R24 Audit and

control of the

Recovery and

Resilience Plan and

the protection of the

financial interests of

the Union

Milestone

Audit of the

implementation of the

Hungarian recovery

and resilience plan

Approval of an

audit strategy by

EUTAF for the

recovery and

resilience plan

Q2 2026

Approval of an audit strategy for the audit

authority (EUTAF), providing for the audit of

the implementation of the Recovery and

Resilience Plan of Hungary to be done in

accordance with internationally accepted audit

standards for the period until at least end-2028.

The strategy shall set out the methodology and

approach to risk assessment, the frequency and

type of audits (such as systems- and project

audits, desk-based and on-the-spot) to be

carried out in the different implementation

stages of the reforms and investments

implemented under the recovery and resilience

plan as well as the reliability of data supporting

the achievement of milestones and targets. In

addition to a high degree of substantive testing,

82

Seq.

Number

Related Measure

(Reform or

Investment)

Milestone /

Target Name

Qualitative

indicators

(for milestones)

Quantitative indicators

(for targets)

Indicative

timeline for

completion Description of each milestone and target

Unit of

measure Baseline Goal Quarter Year

the audits should ensure a sufficiently high

degree of coverage of checks on whether

implementing bodies respect the requirement

referred to in milestone 75, letter (h).

85

C8.R25 Reinforcing

transparency and

access to public

information

Milestone

Entry into force of

legal act(s) ensuring

legal predictability in

access to public

information cases in

court

Provision in the

legal act(s)

indicating the

entry into force

Q2 2026

Entry into force of legal act(s) providing for an

exceptional procedure for requests for access to

public information:

- that introduces an exceptional procedure

with the same procedural steps and similar

deadlines as applied in the case of press

rectification cases as set out in Act CXXX

of 2016 on civil procedures (Sections 495-

501).

- that require the data controller and the

data requestor to act in good faith and

cooperate with one another to facilitate

transparency in the use of public funds

and assets.

86

C8.R25 Reinforcing

transparency and

access to public

information

Milestone

Entry into force of

legislative amendments

ensuring increased

transparency of public

information

Provisions in the

legislative

amendments

indicating their

entry into force

Q2 2026

Entry into force of legislative amendments to

establish the main rule that public information

shall be provided free of charge and fees for

access to such public information may only be

applied under exceptional and clearly defined

circumstances. In this respect the amendments

shall:

(i) Abolish the possibility to charge labour

costs associated with the fulfilment of access to

public information requests;

(ii) Define publicly available unit costs related

to the costs of copying and the delivery of the

information requested;

(iii) Establish the rule that fees charged shall

not exceed the actual cost incurred by the

holder of the public information requested

when fulfilling that information request related

83

Seq.

Number

Related Measure

(Reform or

Investment)

Milestone /

Target Name

Qualitative

indicators

(for milestones)

Quantitative indicators

(for targets)

Indicative

timeline for

completion Description of each milestone and target

Unit of

measure Baseline Goal Quarter Year

to the cost categories under point (ii) and only

if those costs exceed HUF 10 000;

(iv) Introduce a reasonably low overall ceiling

of maximum HUF 190 000 for associated cost

that can be taken into account by a public body

when fulfilling an individual access to public

information request; and

(v) Repeal the provisions allowing the

possibility for a body carrying out public duties

to refuse a data request on the grounds that it

would involve the acquisition, collection, or

processing data or require the creation of new

data.

87

C8.R25 Reinforcing

transparency and

access to public

information

Milestone

Report(s) of the

National Authority for

Data Protection and

Freedom of

Information on access

to public information

Online

availability of the

report(s) of the

National

Authority for

Data Protection

and Freedom of

Information on

the compliance of

public bodies

with their

respective

obligations

regarding access

to public

information

Q2 2026

The National Authority for Data Protection and

Freedom of Information shall carry out checks

on bodies carrying out public duties ex officio

and upon complaint to assess whether they

comply with their respective requirements on

transparency of public data and providing

access to data of public interest.

The findings of the checks shall be summarised

in report(s) identifying how the shortcomings

shall be remedied and followed up as well as

recommendations how access to public data

may be improved.

88

C8.R26 Improving

the quality of law-

making and

involvement of

stakeholders and

social partners in

decision-making

Milestone

Entry into force of a

legal act(s) including

provisions on

involving stakeholders

in the implementation

and monitoring of the

recovery and resilience

plan

Provision in the

legal act(s)

indicating entry

into force

Q2 2026

Entry into force of a legal act(s) that shall

provide for:

(1) an obligation for preparing a strategy

defining tasks and responsibilities on how the

main stakeholders shall be involved in the

implementation of the measures of the recovery

and resilience plan;

84

Seq.

Number

Related Measure

(Reform or

Investment)

Milestone /

Target Name

Qualitative

indicators

(for milestones)

Quantitative indicators

(for targets)

Indicative

timeline for

completion Description of each milestone and target

Unit of

measure Baseline Goal Quarter Year

(2) the legal basis and obligation for

establishing a monitoring committee,

consisting of the stakeholders and social

partners relevant for the implementation of the

components of the recovery and resilience plan.

The monitoring committee shall be tasked to

continuously monitor the implementation of the

recovery and resilience plan also beyond 2026.

All members of the monitoring committee shall

have the same rights and obligations. At least

50% of the members of the monitoring

committee shall represent civil society

organisations independent from the

government and public bodies. Such

organisations shall be selected through an open,

transparent, and non-discriminatory selection

process based on objective criteria related to

expertise and merit from organisations which

are active in the field of one or more of the

following areas: social policy; education;

labour market; healthcare; environment; fight

against climate change; energy; sustainable

development; sustainable transport; promoting

fundamental rights, equal treatment and non-

discrimination; anti-corruption; and

transparency. Members of the monitoring

committee representing civil society.

(3) the obligation that the monitoring

committee shall meet at least twice per year

and receive information related to the

implementation of the measures in the recovery

and resilience plan, that the monitoring

committee may issue recommendations by a

simple majority of its members, and that the

National Authority shall follow-up on those

recommendations and report on the progress of

this follow-up to the monitoring committee;

89 C8.R26 Improving

the quality of law- Milestone Entry into force of

legal act(s) to enhance

Provisions in the

legal act(s) Q2 2026 Entry into force of legal act(s) with the aim of

ensuring that for all legislative acts adopted by

85

Seq.

Number

Related Measure

(Reform or

Investment)

Milestone /

Target Name

Qualitative

indicators

(for milestones)

Quantitative indicators

(for targets)

Indicative

timeline for

completion Description of each milestone and target

Unit of

measure Baseline Goal Quarter Year

making and

involvement of

stakeholders and

social partners in

decision-making

the use of public

consultations and

impact assessments in

the law-making

process

indicating their

entry into force

the Government (i.e. government decrees and

ministerial decrees) or tabled for adoption to the

Parliament by the Government (i.e. bills) public

consultation shall be carried out and impact

assessment shall be prepared and summaries

thereof shall be systematically made publicly

available by providing for:

(i) a minimum consultation period of eight days

(meaning that the draft legislative act shall be

made available for public consultation at the

same time as it is sent for intra-governmental

consultation);

(ii) a minimum period of five days following

the expiry of the public consultation period to

consider the inputs received during the public

consultation period, during which the

legislative act of the government shall not be

adopted by the government, or the draft bill

shall not be submitted to the Parliament;

(iii) that the share of legislative acts which may

fall under the exceptions in Section 5 of Act

CXXXI of 2010 shall be maximum 10%

(iv) that the use of these exceptions shall be

duly justified in writing, with a reference to the

specific exception applied;

(v) that a summary of the preliminary impact

assessment and an explanatory memorandum

that outlines the aim and main elements of the

proposal shall be made available publicly

together with the draft legislative act in all

cases;

(vi) extending the obligation to carry out public

consultation on draft legislative instruments

that related to the list(s) of given names and

removing the possibility to rely on interests

relating to nature conservation and

86

Seq.

Number

Related Measure

(Reform or

Investment)

Milestone /

Target Name

Qualitative

indicators

(for milestones)

Quantitative indicators

(for targets)

Indicative

timeline for

completion Description of each milestone and target

Unit of

measure Baseline Goal Quarter Year

environmental protection from the scope of

exemptions to public consultation

requirements.

(vii) the Government Control Office (KEHI)

shall annually check compliance with the

public consultation requirements of Act

CXXXI of 2010, including the implementation

of points (i) to (vi) in particular whether the use

of exemptions was duly justified and properly

applied. The findings of the above checks shall

be published annually by 31 January in a report

on the website of the Office.

(viii) the Government Control Office shall

consistently impose a sufficiently high fine on

the ministry led by minister responsible for the

preparations of legislation concerned in the

event of non-compliance with any of the

provisions of CXXXI of 2010. The reasons for

imposing the fine shall be made publicly

available.

90

C8.R27 Review of

minimum substance

requirements for

corporate income

tax purposes

Milestone

Independent

international expert

review of the domestic

anti-tax avoidance

rules

Publication of the

review Q2 2026

Publication of an independent review of the

domestic anti-tax avoidance rules on the

Ministry of Finance’s website.

The review shall analyse the state of play of

domestic anti-tax avoidance rules and provide

concrete proposals and recommendations to

improve the effectiveness of the tax rules in

relation to shell entities.

The review shall also make recommendations

on minimum substance requirements for

corporate income tax purposes and the tax

consequences in case of failure to meet the

minimum substance requirements.

91 C8.R28

Strengthening of Milestone Entry into force of

legal act(s) to

Provisions in the

legal act(s) Q2 2026 Entry into force of legal act(s) introducing new

transfer pricing reporting obligations. The legal

87

Seq.

Number

Related Measure

(Reform or

Investment)

Milestone /

Target Name

Qualitative

indicators

(for milestones)

Quantitative indicators

(for targets)

Indicative

timeline for

completion Description of each milestone and target

Unit of

measure Baseline Goal Quarter Year

transfer pricing

regulations

strengthen transfer

pricing rules

indicating their

entry into force

act(s) shall include detailed requirements for the

new transfer pricing data reporting.

The scope of the legal act(s) shall cover

transactions between associated enterprises with

a value of HUF 150 million or more.

92

C8.R29 Extending

the scope of non-

deductibility rules

for outbound

payments

Milestone

Entry into force of

legal act(s) to broaden

the non-deductibility

rules for outbound

payments

Provisions in the

legal act(s)

indicating their

entry into force

Q2 2026

Entry into force of legal act(s) extending the

non-deductibility rules for outbound payments

to cover all transactions of outbound royalty and

interest payments in jurisdictions that are either

listed on the EU list of non-cooperative

jurisdictions or considered to be zero-tax or low-

tax jurisdictions (which include any jurisdiction

with a statutory corporate income tax rate below

the Hungarian statutory corporate income tax

rate).

The legal act(s) shall identify criteria when a tax

consequence would be applied taking into

account the business reasons behind the

transaction and the tax treatment of the

transaction in order to cover double non-

taxation cases. It shall also identify appropriate

tax consequences to mitigate the targeted risk.

93

C8.R29 Extending

the scope of non-

deductibility rules

for outbound

payments

Milestone

Commissioning of an

independent evaluation

of the effectiveness of

the overall set of

domestic rules related

to aggressive tax

planning

Interim report of

the evaluation

Q2 2026

An interim report on the progress of an

independent evaluation, carried out by the

OECD and commissioned by Hungary, shall be

submitted to the Commission regarding the

effectiveness of the overall set of domestic rules

addressing shell companies and outbound

interest and royalty payments between

companies established in Hungary and

companies established in jurisdictions that

either included in the EU list of non-cooperative

jurisdictions or considered zero-tax or low-tax

jurisdictions. A commitment to act on the

results of the independent evaluation shall be

submitted via the publication of a formal letter

88

Seq.

Number

Related Measure

(Reform or

Investment)

Milestone /

Target Name

Qualitative

indicators

(for milestones)