Part I — Situation overview

On 2 October 2026, four mutually independent cases appeared in the press on a single day, and all of them concerned the use of public money in the previous government term. The Prime Minister’s Office announced that during the review of the Sovereignty Protection Office (SZH), abolished in the summer, it had found further documents. According to these, in 2025 and 2026 the office paid a total of more than 46 million forints to two law firms for studies and consultancy, without meaningful competition. One of the lawyers received 27.4 million forints for two in-person consultations, both held for the same 16 people in his own office. The other firm received 19 million forints for a study on the extension of the European Union’s competences, which was completed within 17 days of being commissioned and was duly paid for. According to the Ministry of Justice, however, neither the study, nor any document certifying its handover and acceptance, nor any professional justification of the fee can be found (Telex, 24.hu, 444.hu, ATV). The Prime Minister’s Office therefore supplemented its earlier criminal complaint against person or persons unknown on suspicion of breach of trust. Breach of trust is financial loss caused, through breach of duty, by a person entrusted with managing another’s assets. Tamás Lánczi, the former president of the office, told Magyar Nemzet that the proceedings were a political show trial and claimed that the study is at the Prime Minister’s Office. The same day, a Telex report revealed that Századvég Konjunktúrakutató Zrt. has been operating since 1 October under the name Magyar Gazdaságkutató és Tanácsadó Zrt., and that its headcount has been halved. Between 2024 and April 2026, the Cabinet Office of the Prime Minister paid more than 26 billion forints to the two Századvég organisations. Defence Minister Romulusz Ruszin-Szendi announced that he had filed a criminal complaint because the previous leadership had sold 108 Soviet-made BTR wheeled armoured personnel carriers to Serbia for about half a billion forints (HVG, Telex). Finally, HVG and Magyar Nemzet reported that the National Assembly’s National Security Committee would on Monday, 5 October, hear Péter Szijjártó, the former Minister of Foreign Affairs and Trade, who after the election took up a senior position at the Chinese car maker BYD.

In recent months MIAK has dealt with these threads at several points. In July, when the Sovereignty Protection Office was abolished, it asked for a public closing balance and document security. The analysis of the move to BYD proposed a mandatory cooling-off period. On 25 September it wrote about emergency procurement and performance certification of consultancy work, and earlier it had also proposed a public case-status register for accountability cases. The new element now is that the four cases, side by side, show the recurring forms of missing controls. One is the study that was paid for but could never be read publicly. The second is the analysis institute that depended on a single state client. The third is the state asset whose value was not estimated by an expert, and the fourth is the former minister whose move is not covered by any enforceable rule. In none of the cases named is there an indictment or a court decision. Those concerned are entitled to the presumption of innocence.

MIAK’s reading: in the four cases, criminal liability is decided by the investigating authorities, the prosecution service and ultimately the court — not by the press and not by the government. The common problem, however, is not criminal but institutional. In each case, commissioning, acceptance and price-setting were in the hands of a single actor, and no one could see this from the outside. These gaps remain open even once every proceeding has been closed.

Part II — Foundations in the literature

Three books provide an interpretive framework for the topic. Robert Klitgaard, an American economist and researcher of anti-corruption strategies, starts from the premise in Controlling Corruption that corruption spreads where monopoly meets free discretion and there is no accountability. Against procurement collusion he therefore recommends broadening competition, independent cost estimates and narrowing the discretion of procurers. The SZH’s study commissions display exactly these three conditions. Susan Rose-Ackerman, professor of law and economics at Yale University, describes in Corruption and Government how, in the sale of state assets, the valuation itself can be corrupted, and in extreme cases the asset finds an owner without any valuation or auction. She also argues that the hardest conflict-of-interest problem to manage is the employment of former officials at firms they previously dealt with in an official capacity. Sergei Guriev and Daniel Treisman, an economist and a political scientist, show in Spin Dictators how today’s authoritarian regimes hide messages that serve those in power in seemingly neutral, factual forms. This framework explains why the discrepancy between the public and non-public results of a government-dependent analysis institute is a public matter. The detailed treatment of the literature — by author — is in section 6.4 Literature in detail.

Part III — MIAK’s concrete proposal

MIAK proposes three measurable measures. The first concerns study and consultancy commissions, the second the sale of military equipment that has become surplus, and the third the enforceability of the cooling-off period for former ministers.

3.1 Open procedure and a public study repository for study and consultancy commissions (government decree by 31 March 2027, retrospective inventory by 30 June 2027)

MIAK proposes that the Government regulate by decree the study, analysis and consultancy commissions of central state administration bodies and state-owned companies. The decree should consist of four elements. First: for commissions above a net 5 million forints, an open call accessible to anyone in the Electronic Public Procurement System (EKR) should be mandatory, with a tender deadline of at least ten working days. The estimated value and the evaluation criteria must be laid down in writing before the call. In the SZH case it was precisely the deadline of a few days, the narrow circle of invitees and the undocumented estimated value that ruled out competition. Second: within 30 days of acceptance, the finished study should be uploaded to a public, searchable state study repository, together with the data of the client, the price and the contract. The only exception should be classified data, and even then the title and the price must be published. If a study cannot be uploaded because it cannot be found, this should automatically trigger the recovery investigation proposed in the analysis of 25 September. Third: the Prime Minister’s Office should draw up a retrospective inventory of the government studies commissioned between 2018 and 2026, and publish those that are not classified. The reason is that, according to Telex, journalists had to obtain some of the Századvég studies through years of litigation, and in one case more than 350 studies were withheld. Fourth: the Treasury should flag when a framework contract — that is, an agreement for an annual sum fixed in advance that can be drawn down in instalments — is drawn down faster than the time-proportionate pace. According to Portfolio, out of the annual 9.4-billion framework concluded with Századvég, a gross 7.68 billion forints was paid out in the first quarter of 2026. In Klitgaard’s framework (see 6.4.1) this means broadening competition and narrowing discretion. This is the application of the A2 public procurement transparency and the A1 public money dashboard programme points to the consultancy market.

3.2 A transparent valuation and sales rule for surplus military equipment (government decree by 31 March 2027)

MIAK proposes that the Government lay down by decree how military equipment that has become surplus to defence needs may be sold. It should contain five elements. First: before the sale, at least two mutually independent valuers specialising in military equipment should prepare valuations. According to the Defence Minister, the value of the BTRs was set by a valuer who had previously dealt with real estate. Second: the sale price may not be lower than the average of the two valuations, unless the Government decides otherwise with a public justification, for example for reasons of alliance or foreign policy. Third: if the sale takes place through a state-owned intermediary company, the intermediary’s purchase price, resale price and margin must also be published. According to HVG, the ministry sold the equipment at a price above the estimated value, but to its own company, and it was only this company that passed it on to Serbia at a higher price. Fourth: within 30 days of every sale, the number, type, technical condition and price of the equipment should be made public. According to HVG and Telex, the handover was originally reported only by the Serbian side, and the ministry disclosed the number of units only after a court order. Fifth: on whatever cannot be disclosed for national security reasons, the Defence Minister should regularly inform the National Assembly’s committee responsible for defence matters, which can scrutinise the sales in closed session. Rose-Ackerman (see 6.4.2) describes how, in the sale of state assets, the valuation itself can be corrupted. Two independent valuations and the publication of the intermediary’s margin reduce this risk. This is an extension of the HV2 defence spending transparency programme point to the revenue side: the principle is that everything is public by default, and secret only where justified.

3.3 An enforceable cooling-off period with independent decision-making power (bill to be submitted by 31 December 2026)

In July MIAK proposed a mandatory cooling-off period. Under it, a former minister or senior official could, for a specified period, only take up employment with permission at a company whose affairs he or she had previously decided on in an official capacity. According to HVG, Prime Minister Péter Magyar promised in July to extend the conflict-of-interest rules, but the press sources processed do not mention any bill having been submitted. The hearing planned for Monday now reveals another gap. According to HVG’s article of 16 September, the chair of the National Security Committee, István Apáti, himself said that as a standing committee they can oblige the former minister to cooperate, but cannot initiate any meaningful sanction. The committee hearing is therefore political scrutiny, not a legal proceeding, and it cannot replace one. MIAK therefore proposes that the law to be adopted by the National Assembly on the basis of the Government’s proposal go beyond the July proposal on three points. First: former ministers and state secretaries should, for two years, be obliged to notify every new employment in advance. Second: the notification should be decided on by an independent body, with a binding decision and a public justification. Third: breaking the rule should have consequences, for example a fine. Where the former official would take up work in a strategic sector, at a company with foreign state ties, the body should also seek the opinion of the national security services. This is an extension to members of the government of the three-year revolving-door ban already proposed for the heads of regulatory authorities in programme point G6, supplemented with the national security aspect of the KP21 China analysis framework. According to Rose-Ackerman (see 6.4.2), post-employment is the hardest conflict-of-interest issue to manage, because the rule is worth nothing without enforcement.

The three proposals are linked by one principle: whoever commissions, sells or decides with public money should have their decision verifiable after the fact, and it should not depend on the good faith of a single actor. A study cannot disappear if it goes into a public repository. The price of an armoured vehicle can be verified if two independent valuations stand behind it. And a cooling-off period is worth something if there is someone to enforce it. This is the accountability term of Klitgaard’s formula (see 6.4.1): monopoly and discretion are harmless if external control operates alongside them.

Part IV — Expected effects and risks

Dimension Expected effect Risk
Public money Competition grows in the consultancy market, unjustifiably high unit prices fall; drawdowns of framework contracts stay time-proportionate The open procedure slows the commissioning of urgent analyses; ministries may split assignments below the threshold
Public administration The study repository shows what the state already knows, reducing duplicate commissions Because of publicity, clients may request critical internal analyses less often and switch to oral consultancy
Defence A market price flows in for surplus equipment, which can be spent on force development Double valuation is costly and slow; for transfers to allies, justifying the price may cause diplomatic tension
Foreign policy and economic diplomacy Moves by former government members to companies with foreign state ties go through prior screening An overly strict rule may deter private-sector professionals from taking on government roles
Rule of law Control depends not on individual criminal complaints and political winds, but on a rule known in advance If the rule is applied only to the previous government’s cases, it looks like political revenge and loses its credibility

The most important trade-off is the price of publicity. The argument against the study repository is that if every paid-for analysis is public, ministries will rather discuss sensitive questions orally, without a written trace. That would be worse even than the current state of affairs. The Telex report, however, gives an example of exactly the opposite: the Századvég studies that were obtained showed that in several cases the consultants criticised government measures and warned of political risks. Publicity therefore protects independent professional opinion rather than threatening it. The proposal becomes risky if classification is used en masse to circumvent publication. That is why the title and price of classified studies must be published as well.

For the cooling-off period, the risk is proportionality. A general ban would raise constitutional concerns, because it restricts the free choice of occupation. This is why MIAK proposes individual, justified decisions instead of a ban: the body weighs the specific sector and the person’s prior decision-making involvement. The rule must look forward. Applying it retroactively would look like legislation tailored to individuals, and that would weaken precisely the rule-of-law credibility the rule is meant to strengthen.

Part V — Measurability and summary

5.1 What is worth following? (suggested KPIs)

MIAK suggests the following key performance indicators (KPIs). These are suggested indicators, not government commitments.

  • The share of paid-for state studies that are publicly available. Target: at least 90% of the non-classified studies accepted in 2027 in the study repository within 30 days of acceptance; the 2018–2026 inventory published by 30 June 2027.
  • The share of single-bid procedures in study and consultancy commissions. Worth publishing annually, with a meaningful reduction set as a target over two years.
  • The sale price of military equipment sales relative to the average of the independent valuations. Target: a published price and valuation for every sale, and a public government justification for sales below the valuation.
  • The adoption of the law on the cooling-off period and the number of the body’s public decisions. Worth following how many notifications arrive and in how many cases the body imposes conditions or a ban.

5.2 Summary

MIAK’s request is addressed to the Government and the National Assembly, and is tied to three deadlines. By the end of 2026: a bill on an enforceable cooling-off period, with a body that has independent decision-making power. By 31 March 2027: a government decree on the open procedure for study and consultancy commissions and on the public study repository, as well as on the sales rule for surplus military equipment. By 30 June 2027: the inventory and publication of government studies from 2018 to 2026. In the ongoing cases, responsibility is decided by the authorities and the court. MIAK asks that these cases leave behind not only proceedings but also rules.

Of MIAK’s foundational values, transparency and accountability are at stake here. Transparency, because a study paid for with public money, or the price of a state asset, belongs to the citizens, not to the client. Accountability, because control is independent of the political situation only if it is required by a rule known in advance, rather than by a new government’s after-the-fact review.

Part VI — Justifications and further sources

6.1 Press framing across the spectrum

In the left-liberal band, Telex covered the topic in two articles. The headline of the piece on Századvég spoke of the collapse of the “ideological hinterland” of the NER (System of National Cooperation, the self-designation used by the Orbán governments). The paper reconstructed the downsizing from company reports and NAV register data, and recalled the lawsuits fought over the release of the studies. Telex presented the SZH case matter-of-factly, building on the Prime Minister’s Office’s statement. 444.hu chose a more personal frame: the headline highlighted Tamás Lánczi’s name, and the article also recalled previously published data on spending with the office’s bank cards. HVG presented the armoured-vehicle sale as a continuation of its own earlier investigation. It stressed that the ministry had previously made contradictory statements, and that selling the decommissioned Soviet equipment was in itself a justified decision — the question is the price. HVG framed the Szijjártó hearing from the angle of the more than 70 billion forints of state infrastructure development granted to BYD.

In the mainstream band, 24.hu and ATV followed the Prime Minister’s Office’s statement almost word for word, without their own assessment. In the business press, Portfolio, citing 444.hu’s findings, focused on the March survey Századvég prepared for the government. It highlighted that the non-public results showed a much less favourable public mood than the public forecasts, and that the drawdown of the framework contract deviated from the time-proportionate pace. In the conservative band, Magyar Nemzet foregrounded the position of those concerned. According to Tamás Lánczi, the study is at the Prime Minister’s Office, and it is absurd that the Prime Minister’s Office is communicating about the case while the National Asset Recovery and Asset Protection Office (NVVH) has taken it over. The article on the Szijjártó hearing reported the national security risk as a claim by the Tisza parliamentary group, not as a fact. On the processed day, no stand-alone article appeared in the conservative band on Századvég’s restructuring or the armoured-vehicle sale.

6.2 Facts and data

The newly uncovered commissions of the Sovereignty Protection Office (based on the Prime Minister’s Office’s statement of 2 October 2026):

Item Value Source
Amount paid to two law firms (2025–2026) more than 46 million forints Telex, 24.hu, 444.hu, ATV
Fee for two in-person consultations 27.4 million forints; both times for the same 16 people, in the lawyer’s office 24.hu, 444.hu
Fee for the study that cannot be found 19 million forints; completed 17 days after being commissioned Telex, 24.hu, 444.hu
The SZH’s budget support this year more than 6 billion forints 444.hu
Communication and event-organisation spending (over about 2.5 years) about 3.67 billion forints; the police are investigating this matter on suspicion of breach of trust Telex

Századvég’s state assignments and restructuring:

Item Value Source
Payments by the Cabinet Office of the Prime Minister (2024 – April 2026) more than 26 billion forints Telex
Of which in the first quarter of 2026 more than 7.6 billion forints (a gross 7.68 billion according to Portfolio) Telex, Portfolio
Annual amount of the 2023 framework contract 9.4 billion forints, with time-proportionate drawdown Portfolio (based on 444.hu)
Termination of the contract 30 April 2026 Telex
Name change 1 October 2026: Magyar Gazdaságkutató és Tanácsadó Zrt. Telex, HVG
Headcount 72 + 4 people at the two companies at the end of 2025; 37 people on 2 October 2026 (a reduction of more than 51%) Telex, HVG
2025 revenue and after-tax profit of Századvég Konjunktúrakutató Zrt. 4.36 billion and 419.29 million forints respectively Telex, HVG
2020 assignment concluded with the Ministry for Innovation and Technology net 9.34 billion forints; the list of studies was not released in 2022 Telex

Data on the BTR sale:

Item Value Source
Number of BTRs sold to Serbia 108 units (according to the minister) HVG, Telex
Sale price about half a billion forints HVG, Telex
Unit price about 4.6 million forints by Telex’s calculation, about 5.5 million according to HVG Telex, HVG
Data released earlier after a court order 66 units, 935 thousand euros HVG, Telex
Lynx combat vehicles replacing the BTRs 218 units, 800 billion forints Telex

The sources differ on the unit price. Telex divided the half a billion forints by 108 units, while HVG calculated from the previously released purchase price of 935 thousand euros for 66 units. Both values are of the same order of magnitude, so the table gives both by source.

Background to the Szijjártó hearing: according to the Tisza parliamentary group, based on the foreign ministry’s documents, state infrastructure development worth more than 70 billion forints was linked to BYD’s investment (HVG). The National Security Committee launched an inquiry in September. As a standing committee it can oblige cooperation but cannot initiate any meaningful sanction; the hearing may take place in closed or public session (HVG, 16 September 2026).

6.3 Policy dimensions

  • Transparency and anti-corruption policy (programme points) — open procedure and a public study repository for study and consultancy commissions (programme point ID: A2); real-time publicity of payments and framework contracts (programme point ID: A1);
  • Defence (programme points) — a valuation and sales rule for surplus military equipment, with parliamentary scrutiny in closed session (programme point ID: HV2);
  • Economy (programme points) — extending the revolving-door ban to members of the government, measuring dependence on state clients (programme point ID: G6);
  • Foreign policy (programme points) — national security screening of former officials moving to companies with foreign state ties (programme point ID: KP21);
  • Legal foundations (background material) — the separation of the criminal complaint, the investigation, the indictment and the court decision; the political, not judicial, nature of a parliamentary committee hearing.

6.4 Literature in detail

6.4.1 Robert Klitgaard: Controlling Corruption

In one of his boxes, Klitgaard resolves the apparent contradiction that, according to some experts, more rules reduce corruption, while according to others they increase it. His answer is that the condition for corruption is monopoly combined with discretion, together with a lack of accountability. A rule in itself is neither good nor bad: what matters is whether it narrows or widens discretion, and whether it helps or hinders accountability. In the chapter on procurement collusion he also offers a toolkit. In his view competition must be broadened by bringing in new bidders, through greater publicity and lower barriers to entry. Independent cost estimates and external sources of information must be brought in, and the discretion of procurers must be narrowed through decision rules and review. All three factors appeared in the SZH case. Discretion: the client freely determined the circle of invitees and the deadline. Monopoly: some of those invited did not even submit a bid. Lack of accountability: the study could vanish without a trace. Proposal 3.1 addresses all three factors: the open call strengthens competition, the estimated value fixed in advance limits discretion, and the study repository strengthens accountability.

📖 Source: Robert Klitgaard: Controlling Corruption

6.4.2 Susan Rose-Ackerman: Corruption and Government

In the chapter on high-level corruption, Rose-Ackerman examines the sale of state assets. She describes how, for assets of uncertain value, insiders can gain an information advantage. The valuation itself can be corrupted by valuers lacking the appropriate expertise or connected to an interested party. In extreme cases the asset goes, without valuation or auction, to whoever has the best political connections. Her examples include a case in which the consultant organising the sale was himself connected to the buyer. Another part of the book names post-employment as the hardest conflict-of-interest problem to manage. It describes the American rule under which former federal officials may not, for two years, represent others before their former office in matters they worked on. It also shows that President Clinton asked senior officials for a five-year voluntary commitment of self-restraint. According to the author, every country needs a basic conflict-of-interest programme backed by legal sanctions. She adds, however, that simple rules work best, because over-complicated oversight can itself become a field for abuse. Applied to the BTR case: the valuer’s expertise and independence are not a formality but a condition of the price’s credibility (3.2). Applied to the cooling-off period: the rule must be simple but enforceable (3.3).

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

6.4.3 Sergei Guriev and Daniel Treisman: Spin Dictators

Examining contemporary authoritarian regimes, Guriev and Treisman distinguish “fear dictatorships”, built on open repression, from “spin dictatorships”, built on manipulation. One tool of the latter is to hide messages that serve those in power in a seemingly neutral, factual form. An example is a questionnaire disguised as opinion research, for which the authors cite the 2015 national consultation on immigration as a Hungarian case. The book also points out that those in power meanwhile need accurate information about the real public mood. The Századvég case can be interpreted within this framework. According to Telex and Portfolio, the public forecasts showed a Fidesz victory even before the election, whereas the non-public survey handed to the government signalled serious discontent. If only part of the results of an analysis institute run on public money reaches the public, public money finances both the government’s own information-gathering and public opinion-shaping at the same time, but only the former is accurate. The study repository in proposal 3.1 and the measurement of client concentration make this duality visible.

📖 Source: Sergei Guriev – Daniel Treisman: Spin Dictators

6.5 International comparison

For the publicity of studies and contracts, the Slovak central register of contracts is the well-known model. Since 2011, state contracts as a rule enter into force only after being published online. MIAK’s A1 programme point has already adopted this model; proposal 3.1 would bring before the public not only the contract but also the performance, that is, the study itself. The difference is essential: the contract only shows how much was paid, while the study also shows what was received for it.

On the transparency of defence procurement, the practice of the Swedish Defence Materiel Administration (FMV) is the starting point of programme point HV2. The same principle can be applied to the sale of military equipment as to procurement: publicity is the default, classification is the justified exception, and the latter is counterbalanced by closed parliamentary scrutiny.

For the moves of former government members, the United Kingdom’s advisory body, the Advisory Committee on Business Appointments (ACOBA), is the most frequently cited example. For two years after leaving office, former ministers must seek the committee’s advice before taking up new employment. A recurring criticism in British debates is that the committee’s advice is only advisory, and breaching it carries no meaningful consequence. This is the same gap to which the chair of the Hungarian National Security Committee also referred. According to MIAK’s July analysis, former members of the European Commission are subject to a two-year notification and examination obligation. Proposal 3.3 therefore asks not merely for notification but for a binding decision with consequences: international experience shows that an advisory body alone is not enough.

Transparency and anti-corruption policy

  • A1 — Public money dashboard
  • A2 — Public procurement transparency

Defence

  • HV2 — Defence spending transparency

Economy

  • G6 — Programme against rent-seeking and regulatory capture

Foreign policy

  • KP21 — Four-dimensional China analysis framework

Proposed new programme point: Public state study repository — publication of every study and analysis commissioned with public money within 30 days of acceptance, with a client-concentration statement — for the Transparency and anti-corruption policy area.

Proposed new programme point: Sales rule for surplus military equipment — double independent valuation, publication of the intermediary’s margin, parliamentary scrutiny in closed session — for the Defence area.

6.7 List of sources

Press sources (MIAK press monitor, 3 October 2026 — topic 3):

Supplementary press sources (background):

Knowledge-base references (books):

  • 📖 Robert Klitgaard: Controlling Corruption
  • 📖 Susan Rose-Ackerman: Corruption and Government — Causes, Consequences, and Reform
  • 📖 Sergei Guriev – Daniel Treisman: Spin Dictators (Spindiktátorok)

MIAK internal materials:

Supplementary public data sources:

  • Electronic Public Procurement System (EKR) — https://ekr.gov.hu/
  • K-Monitor public money databases — https://k-monitor.hu/
  • OECD Public Integrity Indicators (the OECD indicator system measuring public-sector integrity)

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