Part I — Situation overview

The interest-rate cap on mortgage loans remains in force unchanged after 30 September 2026. The interest-rate cap is the state limitation of the interest on variable-rate household mortgage loans; in fact it caps not the full interest on the loan but its reference rate. On 14 September in the National Assembly, Nikoletta Boda, Parliamentary State Secretary of the Ministry of Finance, stated that no agreement could be reached with the banks that would guarantee that the phase-out would not cause a significant increase in the burden on customers. According to Portfolio’s background analysis of 17 September — citing the paper’s market sources — two ideas clashed. The banks asked for a fixed future date (1 February 2027 as an example), which would leave time for informing customers and for the IT changeover, and in return offered relief tailored to a narrow circle of vulnerable debtors. The government side, by contrast, wanted the interest-rate cap to remain in place for all of the more than 200 thousand people affected until reference rates fall to a level lower than today’s. The banks rejected this because it would have tied the phase-out to an event of uncertain timing. The result: since the earlier deadline of 30 June was already abolished by the outgoing government in April, the interest-rate cap now has no final date.

Meanwhile the other instrument born for crisis management, the margin cap, has come under ever broader professional pressure. The margin cap is the state limitation of the retail margin on basic foodstuffs and drugstore products: it was introduced on 17 March 2025, and it caps the margin at 10 per cent for the regulated products. The Hungarian Chamber of Commerce and Industry asked for its phase-out on 17 September, nine food-industry and agricultural organisations on 22 September, and the National Potato Association and Product Board on 24 September. In the same week, the new inflation report of the Magyar Nemzeti Bank (MNB) signalled a turn: after this year’s annual fall of 4.1 per cent, food prices could rise by 5.8 per cent in 2027 and 5.9 per cent in 2028. The favourable window for the phase-out is therefore narrowing. So far the fate of the two instruments has been decided in the same way: in the days before the deadline, through negotiating bargains, without a public yardstick.

MIAK’s reading: the common feature of the two instruments is that their burden is borne not by the budget but by the banks, the retailers and the suppliers — and precisely for this reason the fiscal pressure that forces a review of other expenditures is missing. Paradoxically, the current debate on the interest-rate cap was not about whether a threshold is needed, but about whether a final date is needed alongside the threshold. The two are not mutually exclusive: a rule announced in advance can be tied to a condition and to the calendar at the same time. Without it, today neither the debtor, nor the bank, nor the retailer can plan.

Part II — Foundations in the literature

Three sources provide the interpretative framework. According to the rule-of-law chapter of The Road to Serfdom by Friedrich August von Hayek (Austrian-born economist, recipient of the Nobel Memorial Prize in Economic Sciences in 1974), the condition of a free economy is that state action be bound by rules fixed and announced beforehand, from which actors can calculate their own situation with sufficient certainty. Intervention based on case-by-case, momentary discretion takes away precisely this predictability. Peter F. Drucker (Austrian–American management thinker, founder of the methodology of measuring organisational effectiveness), in The Effective Executive, calls the long life of temporary measures one of the most obvious facts of social and political life, and teaches that the right answer to a recurring situation is not an ad hoc decision but a rule equipped with boundary conditions and feedback. The 2024 volume of the International Monetary Fund’s (IMF) World Economic Outlook complements the picture from the implementation side: reforms are carried out and remain durable if they are accompanied by compensatory measures and independent analysis, and the predictably paced phase-out of an extraordinary instrument causes hardly any market disruption. 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 provides a common framework rule for the two instruments — and for every future general price intervention — while the second and third apply it to the interest-rate cap and the margin cap.

3.1 A common phase-out framework rule for the two instruments (to be announced by 31 October 2026)

MIAK proposes that the Government, simultaneously with the submission of the 2027 budget bill and at the latest by 31 October 2026, announce a uniform phase-out framework rule that applies to every general price intervention placing a burden on actors outside the budget. The rule should consist of five elements. One: an exit threshold fixed in advance and tied to a public data series. Two: a final expiry date — a date fixed in legislation on which the measure ends automatically unless the legislator amends it beforehand — which applies even if the threshold has not been met by then. Whichever of the two conditions occurs first triggers the phase-out. Three: a notice period of at least 90 days before the day of the phase-out. Four: an impact assessment published at least 60 days before the phase-out on whom the instrument actually protects today and who bears its cost. Five: any reintroduction should require a threshold substantially stricter than the exit threshold and its own expiry date. This last one is the non-obvious but decisive element: if the entry and exit thresholds are identical, the instrument switches off and on at every minor fluctuation, and the market again becomes unpredictable. The proposal is the ex-ante counterpart of programme point G20 — the Drucker audit, that is, the ex-post impact assessment of adopted state measures comparing expected and actual outcomes — and applies the principle of public justification of decisions under G19 and of the decision log under KI8. Drucker (see 6.4.2) prescribes exactly this: a recurring situation needs a rule, not a repeated ad hoc decision.

3.2 Phasing out the interest-rate cap with a threshold and a final date, with targeted transitional protection (final expiry no later than 30 June 2027)

In the case of the interest-rate cap, the framework rule bridges the positions of the two negotiating parties. Under MIAK’s proposal, the exit threshold should be that the three-month BUBOR — the interbank forint rate to which the interest on variable-rate loans is adjusted — falls below 5.0 per cent on average over three consecutive months; if this does not happen, the interest-rate cap ends no later than 30 June 2027. The government side thus gets an exit tied to the interest-rate environment, and the banks get a fixed latest date. Before the phase-out, targeted transitional protection should start for the roughly 19 thousand debtors classified as vulnerable by the MNB. These are the debtors for whom the phase-out would raise the monthly instalment by at least 5 thousand forints and the payment-to-income ratio would be at least 40 per cent, or who have reached retirement age since the cap was introduced. The elements of the protection: an instalment ceiling for up to 24 months, a free extension of the maturity and a free switch to a fixed-rate product. There is also a less visible source of financing. According to Portfolio’s estimate, in the second quarter the banks booked a revaluation loss of approximately 100 billion forints because the interest-rate cap remained in place, and if a date is announced they can write back a significant part of it. MIAK proposes that the banking sector commit a pre-fixed share of this write-back to the transitional protection of vulnerable debtors. The proposal builds on the SZ1 targeted-support and the G22 financial-stability programme points. Hayek’s thesis (see 6.4.1) becomes tangible here: as long as there is no announced rule, the debtor cannot decide whether early repayment is worthwhile, and the bank cannot tell them what interest rate to count on.

3.3 Automatic, targeted food-price protection instead of the margin cap (entry into force 1 January 2027)

For the margin cap, the exit threshold of the common rule is met today: according to the Hungarian Central Statistical Office (KSH), retail food prices in July were 4.4 per cent lower than a year earlier. The question is therefore not the condition of exit, but what happens if the food-price increase expected by the MNB materialises. MIAK proposes that the framework rule lay down that, in the event of a food-price increase, it is not the margin cap that returns; instead, targeted protection switches on automatically. If the annual rise in retail food prices exceeds 8 per cent in three consecutive months, households in the bottom income quintile receive a food supplement from the following quarter without any separate decision, which ends two quarters after prices fall back below the threshold. The 8 per cent threshold is deliberately higher than the 5.8 per cent path expected by the MNB for 2027: households keep up with the normal, forecast price correction through wages and the indexation of pensions, and the protection switches on only for an extraordinary shock. The pre-phase-out impact assessment should also demonstrate what the current debate merely asserts: how large the cross-subsidisation is on non-regulated products and on suppliers, and how much rural small shops have lost. The proposal links the inflation-tracking mechanism for the lower income band under SZ8 with the G5 competition-policy programme point. According to the IMF’s reform analysis (see 6.4.3), a compensatory measure is not a supplement to, but a condition of, durable reform.

The three proposals are linked by one principle: a temporary instrument remains temporary if its ending depends not on the next bargain but on a rule announced in advance. This rule does not narrow the government’s room for manoeuvre; it widens that of households, banks and retailers: all three know what to prepare for.

Part IV — Expected effects and risks

Dimension Expected effect Risk
Households Debtors under the interest-rate cap can foresee the change in their instalment and can decide on early repayment or fixing the rate in time If the targeted protection starts after the phase-out, the most vulnerable debtors may be left without protection for a few months
Banking sector The fixed latest date ends the indefinite exposure, and part of the written-back loss can be used for protection If the threshold is met quickly, the 90-day notice period may be tight for the IT changeover
Retail and suppliers With the phase-out of the margin cap the supply distortion ends, and rural small shops regain room for manoeuvre in pricing The phase-out may coincide with the expected food-price increase, and the press may conflate the two effects
Public administration One framework rule can be applied to every future price intervention, and the decision can be held to account afterwards If the government rewrites the thresholds along the way, the rule loses its credibility, and the situation becomes worse than without a rule

The main question to weigh is the level of the thresholds. With an exit threshold that is too strict, the final date becomes the only effective condition, and the rule shrinks to a simple calendar. With a reintroduction threshold that is too loose, the instrument may return at every minor price fluctuation. That is why MIAK proposes a wide band between the two thresholds. The second risk is political: the day of the phase-out and the expected food-price increase may coincide in the first half of 2027, and the public may attribute the whole thing to the phase-out. What protects against this is not postponing the phase-out — postponement would close the favourable window for good — but a public impact assessment before the phase-out that announces the expected price effect in advance. According to the MNB’s June estimate, the phase-out of the margin cap would have raised inflation temporarily by at most 0.4 percentage points (pp); if this figure is made public before the decision, the subsequent price change remains interpretable.

Part V — Measurability and summary

5.1 What is worth following? (suggested KPIs)

MIAK suggests following the performance indicators below (KPIs, Key Performance Indicators). These are suggestions, not government commitments.

  • Framework rule: whether the Government announces by 31 October 2026 a common phase-out rule for the two instruments, with an exit threshold and a final date — a yes/no indicator.
  • Ex-ante impact assessment: whether the impact assessment is public at least 60 days before the phase-out, broken down by income group.
  • Vulnerable debtors: the 90+ days past-due rate of debtors classified as vulnerable who leave the interest-rate cap, in the 12 months following the phase-out. Suggested target value: it should not rise by more than 2 percentage points relative to the average of the total mortgage portfolio.
  • Number of last-minute decisions: how many price interventions are decided in the last 14 days before expiry. Suggested target value from 2027: zero.
  • Targeted food-price protection: if the protection under 3.3 switches on, at least 75 per cent of payments should go to the bottom income quintile.

5.2 Summary

MIAK’s request to the government: by the end of October, announce a common phase-out rule for the interest-rate cap and the margin cap that lays down an exit threshold, a final date, a 90-day notice period and a pre-phase-out impact assessment. For the interest-rate cap, the rule bridges the differing positions of the government and the banks; for the margin cap, it rules out that the expected food-price increase brings back the price cap — automatic, targeted protection should step in instead. The slipping of the 30 September deadline shows that a deadline in itself is not a rule: if the deadline is not accompanied by a condition fixed in advance, the failure of negotiations means indefinite continuation.

Two MIAK foundational values are at play here. Transparency, because today not a single debtor under the interest-rate cap can say when and by how much their instalment will rise — the common rule removes this uncertainty without anyone suffering a sudden shock. And accountability, because an announced threshold and final date can be held to account: if the government departs from them, it must justify this publicly, whereas no one answers for a deadline postponed in a bargain.


Part VI — Reasoning and further sources

6.1 Press framing by spectrum

In the economic band, Portfolio provided the only detailed background picture of the interest-rate-cap debate: it presented the ideas of the two negotiating parties and the losses the banks have already booked. It also calculated that for a 3 million forint loan with five years of remaining maturity, the instalment would rise by 4,200 forints a month if the interest rate went up from 5.1 per cent to 8.1 per cent. According to the paper’s commentary, the fact that ending the interest-rate cap, the margin cap and the protected fuel price has come onto the agenda is a sign of a less spectacular but more predictable economic-policy path. On the margin cap, Portfolio carried an opinion piece by leaders of the Association of Responsible Food Producers and the position of the chamber — both emphasise the arguments of the supplier side, and the risk on the consumer side less so.

In the public-affairs band, 24.hu, Index and ATV reported factually, based on press releases, on the professional organisations’ request for a phase-out. ATV recalled that after the election the Finance Minister promised a gradual phase-out, yet in June it was already stated that the phase-out was not on the agenda — so this band also recorded the inconsistency of government communication.

In the left-liberal band, two opinion sections of Telex are the sharpest: one author of the economic blog analysed the retreat of fixed-rate home loans in light of expectations of euro adoption. In the paper’s economic opinion section, a portfolio manager criticised, as a legacy of paternalism, the fact that the new government has not touched the margin cap. Népszava put the MNB’s food-price forecast in the foreground, while HVG, in an interview with the Secretary General of the Banking Association, discussed the interest-rate cap as a revival of “Kádár-era pseudo-care”. The author of the Kiszámoló personal-finance blog showed the price of uncertainty through his own case: for weeks his bank could not tell him whether he could make a fee-free early repayment on 1 October, because it was not known whether the interest rate would change.

In the conservative band, Magyar Nemzet defends the margin cap: in its view, families would pay the price of the phase-out, and if retailers calculated with the margins from before March 2025, an average family would spend 180–360 thousand forints more a year. From MIAK’s point of view, this figure shows exactly why a public impact assessment is needed before the phase-out: the source and methodology of the estimate cannot be learned from the article, and the retail organisations claim the opposite. A jointly accepted calculation published in advance would turn the debate between the two camps into a debate about data.

6.2 Facts and data

Data Value Source
Contracts covered by the interest-rate cap 216 thousand (26% of mortgage contracts) Portfolio, 17 September 2026
Loan portfolio affected 848 billion HUF (11% of mortgage debt), average debt 3.9 million HUF Portfolio, 17 September 2026
Cost of the interest-rate cap to the banking sector 440 billion HUF by the end of 2025, above 500 billion HUF with this year’s revaluation MNB calculation (Portfolio, 17 September 2026)
Revaluation loss in Q2 approximately 100 billion HUF (estimate) Portfolio, 17 September 2026
Vulnerable debtors 19 thousand (MNB); approx. 10 thousand according to the banks’ estimate Portfolio, 17 September 2026
3-month BUBOR from 6.5% at the start of the year to near 5.5% Portfolio, 17 September 2026
Actual average rate on loans under the interest-rate cap home loans 5.4%, general-purpose mortgage loans 6.2% Portfolio, 17 September 2026
Introduction of the margin cap 17 March 2025, 10% margin limit on regulated products ATV, 24.hu, September 2026
Scope of the margin cap retailers with annual revenue above 1 billion HUF MKIK statement (Index, 18 September 2026)
Retail food prices, July 2026 −4.4% over one year KSH (MKIK statement, Index, 18 September 2026)
Estimated inflationary effect of phasing out the margin cap at most 0.4 pp, temporarily MNB, June 2026 inflation report (Index, 18 September 2026)
Expected inflation 2026: 1.8%; 2027: 3.1% MNB, September 2026 inflation report (Népszava)
Expected change in food prices 2026: −4.1%; 2027: +5.8%; 2028: +5.9% MNB, September 2026 inflation report (Népszava)
Central bank base rate 5.50% Telex, 26 September 2026
New inflation target 2.5% (±1 pp) from 1 January 2028 MNB Monetary Council, 22 September 2026 (HVG)
Share of subsidised loans in new home loans roughly 80% (Otthon Start) Telex, 26 September 2026

Two remarks belong to the figures. First, part of the cost of the interest-rate cap may be smaller in net terms than the gross amount: according to Portfolio, capping instalments also protected the banks from impairment and provisioning during the difficult period of 2022–2023. Second, according to the Deputy Chair of the Banking Association, 32 per cent of the forward-looking loss from the interest-rate cap is caused by only 5 per cent of the contracts — this figure argues for targeted protection, because the burden is concentrated on a few large, long-maturity loans.

6.3 Policy dimensions

  • Economy (programme points) — ex-ante and ex-post impact assessment of the phase-out, public justification of decisions, restoration of retail competition and monitoring of bank exposure (programme point ID: G20, G19, G5, G22);
  • Social policy (programme points) — targeted transitional protection for vulnerable debtors, automatic, inflation-tracking support for the bottom income quintile (programme point ID: SZ1, SZ8);
  • Public administration and e-government (programme points) — the framework rule as a decision log: the introduction, extension and phase-out of every price intervention with a recorded justification (programme point ID: KI8).

6.4 Literature in detail

6.4.1 Friedrich A. Hayek: The Road to Serfdom

Hayek also interprets the rule of law as an economic category. According to the book’s sixth chapter, the most important difference between free and arbitrary government is that in the former:

“government in all its actions is bound by rules fixed and announced beforehand — rules which make it possible to foresee with fair certainty how the authority will use its coercive powers in given circumstances and to plan one’s individual affairs on the basis of this knowledge.”

Hayek’s argument is twofold. The economic argument is that actors can use their own knowledge effectively only if they can foresee the state’s steps; the political argument is that an ad hoc decision inevitably decides in favour of one affected group at the expense of another. According to one of the chapter’s sharpest sentences, the more the state “plans”, the more difficult planning becomes for the individual. Applied to the current situation of the interest-rate cap: the government’s attempt to tie the phase-out to the interest-rate environment would not in itself have been wrong — the mistake is that the condition was not accompanied by an announced, numerical rule and a final date. A rule consisting of a threshold and a final date restores precisely the predictability that Hayek considers the essence of the rule of law, without the government giving up tying the phase-out to an economic condition.

📖 Source: Friedrich A. Hayek: The Road to Serfdom

6.4.2 Peter F. Drucker: The Effective Executive

In the chapter on effective decisions, Drucker distinguishes the truly unique event from the recurring, generic situation. In his view, the latter must always be answered with a rule, a principle, and the most common mistake is to treat a recurring situation as a series of independent ad hoc decisions. On temporary measures he writes:

“One of the most obvious facts of social and political life is the longevity of the temporary. […] The effective decision-maker […] asks himself every time, ‘If I had to live with this for a long time, would I be willing to?’”

Among his examples are the French rent controls of the First World War, intended for a few months, which were still in force fifty years later. In another chapter, Drucker also proposes that every government programme be regarded from the outset as temporary, ending automatically after a specified period unless the legislator explicitly extends it after an independent review. The other two elements of a decision for him are the precise specification of boundary conditions and built-in feedback. The repeated extension of the interest-rate cap and the margin cap is a textbook example of handling a recurring situation with ad hoc decisions. The framework rule under 3.1 transposes the three elements of the Drucker recipe — rule, boundary condition, feedback — at once.

📖 Source: Peter F. Drucker: The Effective Executive

6.4.3 International Monetary Fund (IMF): World Economic Outlook (2024)

The third chapter of the IMF’s October 2024 outlook report examines why a significant share of reforms fail or run out of steam. According to the chapter, some of the attempted reforms are never implemented — close to 20 per cent of measures increasing competition in electricity markets — and the most reliable predictor of successful implementation is not the macroeconomic situation, but whether the government applied a consultation and communication strategy and compensatory measures. The foreword by the report’s chief economist sums it up as follows:

“Better communication can only go so far. Instead, building trust between the government and its people […] and the inclusion of proper compensatory measures to mitigate distributional effects are essential features.”

According to the chapter, support for reforms is largely determined by beliefs and perceptions, around half of which consist of misunderstandings and misinformation; analysis produced by independent, non-partisan institutions has in many cases played a key role in building consensus. In the same volume, a box on central-bank balance-sheet reduction finds that the phase-out of extraordinary instruments has so far had little market impact, partly because it was carried out slowly, predictably and in a timely manner, with ample communication. Applied to the interest-rate cap and the margin cap, the two lessons reinforce each other: a public impact assessment before the phase-out reduces misunderstandings, targeted protection reduces the resistance of the losers, and an announced schedule reduces market disruption.

📖 Source: International Monetary Fund (IMF): World Economic Outlook (2024)

6.5 International comparison

The closest international parallel is the phase-out of central banks’ extraordinary instruments. According to the IMF analysis cited, the major central banks began to reduce their balance sheets, swollen during the pandemic, by announcing the pace in advance and communicating the steps extensively — which is why the market impact remained small. This pattern can be transferred directly to the interest-rate cap: the problem is not the phase-out itself, but the uncertainty of its timing and condition. In the region, the margin cap is not a Hungarian peculiarity: Romania has applied a margin cap on basic foodstuffs since 2023, and Croatia maintains a regulated price for a range of products, and in both countries the measure has been extended or broadened several times — Drucker’s “longevity of the temporary” applies here too. Compared with this, the novelty of MIAK’s proposal is the reintroduction threshold: the phased-out price cap is replaced not by yet another ad hoc extension, but by protection that is fixed in advance, targeted and ends by itself.

Economy

  • G20 — Economic-policy impact assessment system (Drucker audit)
  • G19 — Radical transparency in economic decision-making
  • G5 — Competition policy and anti-monopoly
  • G22 — Financial-stability monitoring and shadow-bank regulation

Social policy

  • SZ1 — Targeted support
  • SZ8 — Consumption stimulus in the lower income band

Public administration and e-government

  • KI8 — Drucker-principle effectiveness measurement in public administration

Proposed new programme point: Uniform phase-out framework rule for general price interventions — exit threshold, final expiry date, notice period, ex-ante impact assessment, stricter reintroduction threshold — for the Economy area.

6.7 List of sources

Press sources (MIAK topic monitor, 27 September 2026 — topic 3, and the related MIAK press monitors):

Knowledge base references (books):

  • 📖 Friedrich A. Hayek: The Road to Serfdom
  • 📖 Peter F. Drucker: The Effective Executive
  • 📖 International Monetary Fund (IMF): World Economic Outlook (2024)

MIAK internal materials:

  • MIAK policy area: Economy (programme points; programme point ID: G20, G19, G5, G22)
  • MIAK policy area: Social policy (programme points; programme point ID: SZ1, SZ8)
  • MIAK policy area: Public administration and e-government (programme points; programme point ID: KI8)
  • MIAK topic monitor, 27 September 2026 — topic 3, score: 80/100
  • MIAK press monitor, 18 September 2026 — topic 10; 23 September 2026 — topic 3; 27 September 2026 — topic 4

Supplementary public data sources:

  • MNB — Inflation Report (June and September 2026), Financial Stability Report
  • KSH — consumer price index, food sub-groups
  • MNB — time series of BUBOR and reference interest rates

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