Part I — Situation overview

On 23 September 2026 the European Commission proposed to the Council of the European Union that it lift the budgetary protection measures adopted against Hungary in 2022. If the Council accepts the proposal, 4.2 billion euros — roughly 1,600 billion forints at the current exchange rate — of cohesion funds will again become available for drawdown. In addition, universities maintained by public-interest asset management foundations (KEKVAs) may again take part in the Erasmus+ and Horizon Europe programmes. According to Commission President Ursula von der Leyen, the decision shows that “reforms deliver results”. According to the Commission’s assessment, Hungary has strengthened the powers and data access of the Integrity Authority, made the asset declaration system more comprehensive, tightened the conflict-of-interest rules applying to KEKVAs, extended judicial review of prosecutorial and investigative authority decisions, and joined the European Public Prosecutor’s Office. The government officially notified on 9 September that it had fulfilled the remedial measures. The Council has one month to decide, which can exceptionally be extended by two months. Unblocking requires a qualified majority: at least 55 per cent of the member states, representing at least 65 per cent of the Union’s population. On the same day Dávid Vitézy, Minister of Transport and Investment, announced that railway and urban public transport, energy, environmental and water management developments could be launched from the envelope by 2029. These include the renovation of the H5, H6 and H7 HÉV lines and the extension of metro line M3 to Rákospalota-Újpest railway station.

The background is well known. The conditionality procedure is based on the 2020 regulation protecting the EU budget: if rule-of-law deficiencies endanger the proper use of EU money, the Council may suspend payments. In December 2022 the member states froze 55 per cent of the commitments of three cohesion programmes, 6.3 billion euros. Because the government of the time did not meet the conditions, 1 billion euros each was permanently lost at the end of 2024 and of 2025; adopting the present proposal would also mean that a further 1 billion is not lost at the end of 2026. In earlier analyses MIAK has written about the structure of conditionality (on the rule-of-law condition of the EU budget), about the benchmarks for returning to the research framework programme (on rejoining Horizon), and about the project-level transparency of the entire funding package. This analysis examines two narrower questions: what this specific envelope will be spent on, and how durable the basis of the unblocking is.

MIAK’s reading is that the unblocking is good news, but for two reasons the matter is not yet closed. The first is the quality of spending: the government announced a project list before any public ranking, cost-benefit analysis or unit-price comparison had been made — and the 2029 deadline creates the same “it has to be drawn down quickly” pressure that led to overpricing in earlier cycles. The second is durability: according to Tineke Strik, rapporteur of the European Parliament (EP), the unblocking must be based on implemented reforms, not on promises, and according to Telex some of the rules applying to KEKVAs are for the time being temporary. An unblocking is worth as much as the rules behind it can withstand.

Part II — Foundations in the literature

Three sources provide the interpretive framework. According to the 2025 economic survey of the European Union and the euro area by the OECD (the international cooperation organisation of developed economies), the return on cohesion funds depends heavily on institutional quality. And meeting milestones is not the same as a measurable result — in other words, drawdown in itself is not success. Susan Rose-Ackerman (professor of law and political science at Yale University, one of the founders of the economics of corruption) warns that the greatest cost of corruption is not the bribe itself but poor project selection: the preference for oversized, overly complex, capital-intensive investments. Joseph E. Stiglitz (Nobel memorial prize-winning American economist, former chief economist of the World Bank), writing about the conditions of international lenders, shows that externally imposed conditions easily fade away at a change of government. Moreover, earmarked money also frees up other resources — which is why not a single project but the entire portfolio has to be visible. Together, the three propositions set out the logic of MIAK’s proposal: a ranking for the projects, a benchmark for the prices, and statutory entrenchment for the commitments. The detailed discussion of the literature — by author, with quotations — can be found in section 6.4 Literature in detail.

Part III — MIAK’s concrete proposal

MIAK proposes three measurable measures. The first two serve the quality of spending, the third the durability of the unblocking.

3.1 A public, ranked project list with cost-benefit analysis (within 60 days of the Council decision, before the first grant agreement)

MIAK proposes that the government publish a complete, ranked project list for the 4.2 billion euro envelope before the first grant agreement is signed. For every item the list should contain the estimated cost, the planned schedule, the expected passenger traffic or other result indicator, and a cost-benefit analysis prepared by an independent institute. Under programme point A8 this should be mandatory for every infrastructure project above 500 million forints, with the result made public. The ranking should be drawn up according to the priority matrix of programme point KO4: on the basis of passenger traffic data, the lack of alternative transport options, economic impact and the cost-benefit ratio. The government may deviate from the ranking, but under the “comply or explain” principle it must justify this in writing and publicly. The OECD survey (see 6.4.1) establishes precisely that cohesion money delivers results where selection passes through an institutional filter; some of the announced HÉV, metro and railway projects are probably in the right place on the list — but at present nobody can verify this. Because of the 2029 deadline, the list must not delay drawdown: the 60-day deadline is just enough for the data of the prepared projects to appear in a uniform format.

3.2 A unit-price benchmark for large transport investments (first edition by 31 December 2026, annually thereafter)

MIAK proposes that the Ministry of Transport and Investment publish a unit-price benchmark — that is, a reference table of how much one kilometre of HÉV renovation, metro line or railway modernisation typically costs — based on the actual costs of completed domestic projects and on public EU comparative data. If a winning bid exceeds the benchmark by a threshold fixed in advance, for example 20 per cent, the contracting authority must publish a written justification, and the transaction must be submitted to independent expert review. This is the transport application of the abnormal-pricing alert system of programme point A2. The minister himself has demonstrated the value of the method: according to Dávid Vitézy, the current concessionaire would undertake the operation of the M6 motorway between 2026 and 2037 for 44 billion forints, compared with the 149 billion forint price of the company selected earlier. Such a comparison is now a one-off political exposé — according to MIAK it should be a routine procedure. According to Rose-Ackerman’s examples (see 6.4.2), in large construction contracts the price increase caused by bribes or corruption is of the order of 10-30 per cent; the 20 per cent threshold is therefore not an arbitrary number, but falls within this range.

3.3 A public register of the conditionality commitments and statutory entrenchment of the temporary rules (the register before the Council decision, the bill to be submitted by 30 November 2026)

MIAK proposes that the government publish, before the Council decision, an itemised list of the commitments on which the Commission based its unblocking proposal. For every item it should be stated at what level of legal source it is laid down: act, government decree or temporary rule. Where the commitment exists only in a government decree or a temporary rule — according to Telex, the reforms introduced for the KEKVAs of the model-changing universities are of this kind — the government should submit by 30 November 2026 a bill for adoption by the National Assembly. The register is at the same time suitable for informing the member states and the EP delegation planned for October, which serves issue-based coalition-building under programme point KP17 to secure the qualified majority. MIAK’s earlier analysis on the reversibility of reforms examined the guarantees of the Recovery Fund; this proposal narrows the focus to the specific commitments of the conditionality procedure. According to Stiglitz’s argument (see 6.4.3), conditions imposed from outside do not survive a change of government unless they become part of the domestic legal order itself. Statutory entrenchment is precisely this step.

The common principle of the three proposals is that the unblocking should not be the end of the process, but the beginning of a measurable phase. The ranking and the unit-price benchmark ensure that the money is invested with the greatest benefit and at realistic prices. The register and the statutory entrenchment ensure that the conditions do not depend on the goodwill of one government. Rose-Ackerman’s warning applies to both: stopping a bad project is lasting only if the procedure for future approvals also changes.

Part IV — Expected effects and risks

Dimension Expected effect Risk
Economy The envelope goes to the projects with the greatest benefit; more realistic prices in large tenders Preparing the cost-benefit analyses may delay the first contracts ahead of the 2029 deadline
Transport and infrastructure The order of HÉV, metro and railway developments is based on passenger traffic data A data-based ranking may favour Budapest lines at the expense of regional lines
Transparency Unit-price deviations become routinely visible, not only as political exposés The benchmark can be circumvented if projects are tailored so as not to be comparable
Foreign policy The register of commitments strengthens the Hungarian position before the Council vote The public list also offers critics a target if an item is still only temporary
Education Statutory entrenchment of the KEKVA rules prevents the Erasmus and Horizon exclusion from returning Hasty legislation may lead to drafting errors in university governance

The main question to weigh is time. The envelope can be used until 2029, and every month of drawdown counts. If the project list and the cost-benefit analysis slip by months, the pressure pushes the decision precisely towards the worse projects that can be launched faster. This is why MIAK proposes that the list appear within 60 days, and that for projects already prepared the assessment be based on the existing planning documentation. The second question to weigh is territorial fairness: programme point KO4 itself indicates that a ranking based purely on traffic data brings the busiest lines forward. An equity correction in favour of disadvantaged regions is therefore needed. The third is the circumventability of the benchmark: the unit price works only if the units of measurement (kilometre, station, engineering structure) are uniform and are mandatorily included in the project documentation.

Part V — Measurability and summary

5.1 What is worth following? (suggested KPIs)

MIAK suggests following the performance indicators (KPIs, Key Performance Indicators) below:

  • Publication of the ranked project list: whether the list for the entire envelope, with cost-benefit analysis, is published within 60 days of the Council decision. Suggested target: 100 per cent of the 4.2 billion euro envelope has a public data sheet before the first grant agreement.
  • Share of deviations from the ranking: for how many items on the list the funding order deviates from the ranking, and for how many of these a written justification has appeared. Suggested target: a public justification for every deviation.
  • Unit-price deviations: what percentage of large transport tenders exceed the published benchmark by more than 20 per cent. It is worth checking again after 12 and 24 months whether the share is falling.
  • Legal-source level of the commitments: what percentage of the conditionality commitments are laid down in an act by 31 March 2027. Suggested target: 100 per cent of the temporary rules are raised to statutory level.
  • Drawdown and results: the committed and paid-out share of the envelope every six months, published together with the passenger traffic of the developed lines — so that results are visible alongside drawdown.

5.2 Summary

MIAK’s request to the government is simple: the 4.2 billion euros should be invested not on the basis of an announced wish list, but on the basis of a public ranking, with cost-benefit analysis and a unit-price benchmark. And it should keep an itemised register of the anti-corruption commitments, and submit whatever is temporary to the National Assembly so that it becomes law. The unblocking closes the chapter of the previous cycle’s 2 billion euro loss, but preventing the next loss depends on what happens to the money over the next three years.

Two MIAK foundational values are at stake here. Transparency, because without the project ranking and the unit-price benchmark the public sees only the announcement, not the reason for the decision — and overpricing hides precisely where there is no comparison. And accountability, because on a public list of commitments annotated with the level of legal source it can be checked at any time what has become of the promises made to Brussels, and the same scrutiny also works in front of domestic voters.

Part VI — Reasoning and further sources

6.1 Press framing by spectrum

In the economic band, Portfolio broke the topic down across four articles. The piece on Strik highlighted the political conditions of the unblocking, but added that the rapporteur has little influence over the decision. The article on the MFB presented the role of the Hungarian Development Bank (MFB) in channelling the entire EU funding package, and the article relaying Vitézy’s announcement put the project list in the headline (with “gigantic” metro and railway developments). The fourth piece analysed the funds applied for directly from Brussels. The framing is centred on drawdown and projects; the method of selecting the projects is not a question in any of the articles.

In the public-affairs band, the two 24.hu articles emphasised the procedural side: according to the Commission spokesperson, the restrictions remain in force until the decision, and no new contracts can be concluded with the universities until then — so the framing rests on the caution of “they cannot celebrate yet”. ATV published Vitézy’s project list together with the M6 concession price comparison, so in their coverage the news was paired with the lesson of earlier overpricing. 444.hu, citing Portfolio’s calculation, put the emphasis on the amounts converted into forints and on the Council timetable.

In the left-liberal band, HVG’s Eurologus section detailed the Commission’s reasoning, and specifically highlighted that the decision at the same time confirms the permanent loss of 2 billion euros; HVG’s economics section published the ministerial announcement. hvg360 interviewed Thomas Byrne, the Irish EU Presidency’s Minister of State for European Affairs, who, alongside the negotiation of the multiannual EU budget, also sees a chance of closing the Article 7 procedure. Telex put the rapporteur’s role in context: Strik is responsible not for the conditionality procedure, but for the Article 7 procedure (the procedure initiated by the EP for breach of the Union’s foundational values). The Council decides on the conditionality procedure. This clarification matters because several papers — including Világgazdaság, which belongs to Mediaworks — presented the rapporteur’s criticism as a factor influencing the decision.

In the conservative band, Magyar Nemzet approached from two directions. One article highlighted that it is not yet known “at what price” Erasmus and Horizon are coming back, and that the government had already communicated the university tender as closed in early September. The other linked the unblocking to the expulsion of Russian diplomats and emphasised the price of the foreign-policy change of direction. Mandiner’s archive material quoted the education minister’s earlier announcement on the return of Erasmus. From MIAK’s point of view, the conservative band’s question — what the country gave in return — is legitimate. The answer, however, is to be found not in foreign policy, but in the register of commitments (see 3.3).

An institutional inaccuracy appeared in several sources: according to the articles relaying the ministerial announcement, the final decision has to be taken by the “European Council”. In reality it is the Council of the European Union (the body made up of ministers of the member state governments) that decides, not the European Council, which brings together the heads of state or government.

6.2 Facts and data

Item Value Source
Cohesion envelope proposed for unblocking 4.2 billion euros (approx. 1,600 billion forints) European Commission, 23 September 2026; statement by Dávid Vitézy
Original amount frozen in 2022 6.3 billion euros (55% of the commitments of three cohesion programmes) HVG, 23 September 2026
Amount permanently lost 2 billion euros (1 billion each at the end of 2024 and of 2025) HVG; statement by Dávid Vitézy, 23 September 2026
Hungary’s total cohesion envelope 2021–2027 23.7 billion euros (the 4.2 billion is almost one fifth of this) HVG, 23 September 2026
Date of the Hungarian notification 9 September 2026 HVG; 444.hu
Deadline for the Council decision 1 month from the proposal, exceptionally extendable by +2 months 444.hu (based on Portfolio calculation), 24.hu
Launch of the conditionality procedure in the Council 25 votes in favour out of 27 Telex, 23 September 2026
Cohesion funds still withheld on other grounds approx. 3.5 billion euros (2.7 billion horizontal, 0.8 billion thematic enabling conditions) Commission spokesperson, 24.hu, 23 September 2026
Spending deadline according to the government 2029 statement by Dávid Vitézy
Total envelope of the recovery plan approx. 10 billion euros; payment request by the end of September 24.hu, 23 September 2026
Cohesion funds linked to the MFB 800 billion forints (nearly 1,980 billion together with the recovery funds) György Dercsényi (MFB), Portfolio, 23 September 2026
M6 motorway operating price 2026–2037 44 billion forints (current concessionaire) vs. 149 billion forints statement by Dávid Vitézy, ATV, 24 September 2026
Hungarian share of direct EU funds 1.03% (2025); 0.91% (2021–2025) against a population weight of 2.11% MFOI data, Portfolio, 23 September 2026

Two interpretive notes belong to the table. First, the sources give differing figures for the amount withheld outside the conditionality procedure: according to 24.hu, the Commission spokesperson mentioned some 3.5 billion euros, of which 2.7 billion was due to the horizontal enabling conditions (general payment preconditions linked to the Charter of Fundamental Rights — academic freedom, the so-called ‘child protection’ law, the right to asylum). 444.hu, by contrast, wrote of roughly 2.2 billion euros for the separate procedure linked to academic freedom. MIAK considers the official spokesperson’s statement authoritative. Second, the M6 price comparison is the minister’s statement, which Fidesz disputes, citing the differing pavement maintenance conditions of the two contracts — this too shows that without a uniform benchmark, price comparison remains a political dispute.

6.3 Policy dimensions

  • Transparency and anti-corruption policy (programme points) — a public project-level data sheet, mandatory cost-benefit analysis, flagging of abnormal pricing (programme point ID: A8, A2, A1);
  • Transport and infrastructure (programme points) — a railway development priority matrix based on passenger traffic data (programme point ID: KO4);
  • Economy (programme points) — the role of the development bank in channelling EU funds, ex ante and ex post impact assessment (programme point ID: G10, G20);
  • Foreign policy (programme points) — coalition-building for the Council qualified majority (programme point ID: KP17);
  • Education (background material) — the background of the KEKVA model and of the Erasmus and Horizon exclusion.

6.4 Literature in detail

6.4.1 OECD: Economic Surveys — EU and Euro Area 2025

The OECD survey devotes a separate chapter to why cohesion policy does not deliver the same results everywhere. According to the report, empirical research mostly measures a positive effect on regional growth, but the effect depends significantly on factors such as human capital and institutional quality. The effective use of funds requires improving the quality and administrative capacity of national and regional institutions. The survey also makes an important finding on the experience of the Recovery Fund:

“Milestones and targets […] are measures of progress towards a reform or investment, which is not the same as achieving measurable results.”

Applied to the Hungarian situation: meeting the commitments behind the unblocking is a milestone, not a result. The result will be shown by how many passengers, how much reduction in journey time and what operating costs appear after the HÉV and railway developments. This is why MIAK asks in proposal 3.1 that the result indicators be included in the project list already now, not only the costs.

📖 Source: OECD: Economic Surveys — EU and Euro Area 2025

6.4.2 Susan Rose-Ackerman: Corruption and Government

Rose-Ackerman describes large public investments as one of the main arenas of corruption. According to her analysis, corrupt decision-makers favour capital-intensive projects regardless of their economic justification, and spend less on maintenance and operation. She also gives concrete examples of the order of magnitude: in international construction contracts in Paraguay, bribes typically amounted to 10-20 per cent of the contract value, and in the case of the second terminal of Frankfurt airport, according to the prosecutor, corruption caused a price increase of 20-30 per cent. The book’s concluding lesson also applies to the present situation:

“The costs of corruption are not the bribes themselves but the costs of the inefficient actions they encourage. Even if there is no direct evidence of corruption, evidence of the improper size and design of projects should be sufficient to stop them.”

Rose-Ackerman adds that a change of course must go hand in hand with improving the procedure for future project approvals, otherwise the pattern repeats itself. For the 4.2 billion euro envelope this means that it is not enough to expose individual overpriced contracts after the fact. The ranking and the unit-price benchmark have to work before approval — this is the aim of proposals 3.1 and 3.2.

📖 Source: Susan Rose-Ackerman: Corruption and Government — Causes, Consequences, and Reform

6.4.3 Joseph E. Stiglitz: Globalization and Its Discontents

Analysing the lending conditions of the International Monetary Fund (IMF) and the World Bank, Stiglitz makes two observations that can also be applied to the present unblocking. The first is the fungibility of money: if the lender makes the financing of a specific project conditional, it thereby frees up the government’s other resources, which it can use for anything. The condition thus says little about the budget as a whole. The second is durability: in his experience, conditions imposed from outside were often reversed by a new government, because they were perceived as interference in sovereignty and did not withstand the fluctuations of the political process. According to his line of thought, good policy cannot be bought with money — the condition has to become the domestic institutions’ own rule.

Applied to the Hungarian case, both propositions are concrete. Because of fungibility, it is not enough to rank the projects within the 4.2 billion euro envelope publicly if the use of the domestic resources thereby freed up remains hidden — this is why proposal 3.1 is linked to the A1 public-money dashboard. And because of durability, the temporary rules have to be put into law (3.3), so that the condition is not Brussels’ expectation but part of the Hungarian legal order.

📖 Source: Joseph E. Stiglitz: Globalization and Its Discontents

6.5 International comparison

The closest parallel is Poland. Portfolio recalls that there, after the change of government, the withheld funds were largely released on the basis of promises — Strik’s present criticism is understandable in the light of this experience. The Polish case shows that there is a tension between the speed and the durability of unblocking. This tension can be resolved by a public register of commitments kept by level of legal source. Programme point A8 records two further models: in Estonia the digital register and strong internal control pushed the irregularity rate of EU funds below half a per cent, and in Poland, in the 2014–2020 cycle, the public procurement risk-alert system reduced the share of suspicious procedures by 15 per cent. For the project ranking, the Swiss “Bahn 2000” programme is the good example (KO4): it gave priority not to the biggest prestige investments, but to the developments needed for a clock-face timetable and hub connections. Rail passenger traffic doubled in two decades.

Transparency and anti-corruption policy

  • A8 — Cohesion policy accountability
  • A2 — Public procurement transparency
  • A1 — Public-money dashboard

Transport and infrastructure

  • KO4 — Railway development with data-based prioritisation

Economy

  • G10 — State development bank
  • G20 — Economic policy impact assessment system (Drucker audit)

Social policy

  • SZ14 — Cohesion Pillar 2.0 — maximising the use of the Hungarian allocation

Foreign policy

  • KP17 — Issue-based coalition-building in the EU

Proposed new programme point: Unit-price benchmark for large transport and construction investments — a public reference table, with mandatory justification and independent review for deviations above the threshold — for the Transport and infrastructure area.

6.7 List of sources

Press sources (MIAK press monitor, 24 September 2026 — topic 1):

Knowledge base references (literature):

  • 📖 OECD: Economic Surveys — EU and Euro Area 2025
  • 📖 Susan Rose-Ackerman: Corruption and Government — Causes, Consequences, and Reform
  • 📖 Joseph E. Stiglitz: Globalization and Its Discontents

MIAK internal materials:

  • MIAK policy area: Transparency and anti-corruption policy (programme points; programme point ID: A8, A2, A1)
  • MIAK policy area: Transport and infrastructure (programme points; programme point ID: KO4)
  • MIAK policy area: Economy (programme points; programme point ID: G10, G20)
  • MIAK policy area: Social policy (programme points; programme point ID: SZ14)
  • MIAK policy area: Foreign policy (programme points; programme point ID: KP17)
  • MIAK policy area: Education (background material)
  • MIAK press monitor, 24 September 2026 — topic 1, score: 91/100

Supplementary public data sources:

  • European Commission — communication on the conditionality procedure, 23 September 2026
  • Council of the European Union — Implementing Decision (EU) 2022/2506 and its amendments
  • European Commission — Cohesion Open Data Platform (project- and programme-level cohesion data)

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