Part I — Situation overview

According to the 10 May 2026 reports of Notes from Poland and Euractiv the same day, Marcin Romanowski — former justice minister of the Lech Kaczyński-led Law and Justice (PiS) party — fled from Hungary to the United States on 9 or 10 May 2026. Romanowski has been wanted under an arrest warrant since the Tusk government for embezzlement (the siphoning of billions from the Polish Justice Fund, Fundusz Sprawiedliwości) and organised-crime membership; a European arrest warrant (EU extradition procedure operating under Council Framework Decision 2002/584/JHA) is also in force against him. The Hungarian government — Viktor Orbán’s last cabinet — granted him political asylum in December 2024. Within hours of the Péter Magyar government’s oath-taking (9 May 2026, 15:00 CEST), Romanowski was no longer in Hungary.

The historical context of Hungarian asylum-granting is not new. Between 2010 and 2026, the Orbán regime granted asylum to several foreign political figures under international or EU judicial proceedings — among them, the Romanowski case had the greatest reverberation, because the applicant was a wanted person from an allied EU member state. Visegrad Insight’s April 2026 analysis V4 Revival: Babiš, Fico and Tusk Call Magyar Their d’Artagnan projected a possible restart of trust among the four — but the Romanowski asylum, as an open wound on the Hungarian side, was present at every bilateral negotiation. The Tusk government repeatedly and officially requested extradition; the Orbán cabinet gave no substantive answer.

MIAK’s reading is simple and not triumphalist. The Romanowski case is the new Hungarian government’s first real foreign-policy and legal test. Corruption as an institutional problem — in Robert Klitgaard’s (Harvard-Yale development economist, author of the C = M + D − A framework) classical formula: thrives where monopoly + discretion − accountability meet — the 2010-2026 phase of the Hungarian asylum system showed exactly this pattern: cabinet-level asylum-decision monopoly (a single ministerial decision), uncontrolled discretion (low judicial review possibility in political asylum), and missing parliamentary accountability (no aggregated public report has been prepared on the decisions for years). This institutional pattern is not the subject of a political revenge campaign but the basic condition of the receiving institutional system: legal extradition cooperation only works if the member states mutually trust the credibility of each other’s decisions.

Part II — Literature-based grounding

Before turning to MIAK’s concrete proposals, it is worth setting out the scientific frame in which the Romanowski case can be interpreted. In her volume Corruption and Government — Causes, Consequences, and Reform (1999), Susan Rose-Ackerman examines from the perspective of institutional integrity how the monopoly of political discretion distorts sovereign decisions — the 2010-2026 phase of Hungarian asylum practice is one classic textbook case of this distortion. In Robert Klitgaard’s Controlling Corruption (1988) formula — C = M + D − A — corruption thrives where monopoly and discretion meet with a lack of accountability: the Romanowski asylum is affected in all three dimensions (cabinet-level decision, low judicial review, missing parliamentary report). In Henry Kissinger’s World Order (2014) framework, the tension between Westphalian sovereignty and the European cooperation order is a substantive question — the Hungarian-side asylum decision is sovereign, but damages the trust of judicial cooperation among EU member states, and the resulting credibility debt is a strategic-asset loss. The detailed literature discussion — by author, with quotations — is found in section 6.4 Literature audit detail.

Part III — MIAK’s concrete proposal

MIAK proposes three measurable, deadline-bound measures to settle the Romanowski case and the broader asylum-granting practice. Common principle: the Orbán-era legacy is not a question of political revenge but institutional integrity reset — restoring the European cooperation capacity of the Hungarian judicial and foreign-policy system with measurable, deadline-bound steps.

3.1 Independent asylum-review commission — established within 90 days, with a closed report within 12 months

Within 90 days of the inaugural session, the new government should set up a six-member independent asylum-review commission: 2 constitutional lawyers (joint delegation of the Hungarian Academy of Sciences and Pázmány-Eötvös Loránd), 2 international-law practitioners (Hungarian Bar Association), 1 human rights expert (on the proposal of the Helsinki Committee), 1 member with UNHCR refugee experience. The commission’s competence: review every political asylum decision granted between 2010 and 2026 item-by-item, and assess (a) whether it met the substantive conditions of the 1951 Geneva refugee convention and Hungarian Act LXXX of 2007, (b) whether there was documented reasoning from the cabinet, (c) whether the obligatory professional consultations were carried out (Immigration and Asylum Office, Hungarian Ministry of Foreign Affairs). The result of the investigation is completed in a public report within 12 months.

The proposal restores the missing accountability (A) component in the Klitgaard C = M + D − A framework (see 6.4.2): the monopoly decision of political asylum-granting remains in the cabinet’s hands, but ex-post auditability is built in at system level. This is not a new asylum regime, but the transparent application of existing rules. Quantitative goal: by the end of May 2027, the commission’s evaluation of all 2010-2026 asylum decisions is published; in 100% of cases raising suspicion of legal violation or wrong decision, prosecutorial referral; the fulfilment of the 90-day commission setup is a joint metric of the KP3 (Transparent foreign policy) and A6 (Checks and balances) programme points.

3.2 Reform of the Hungarian practice of the European arrest warrant (EAW) — judicial protocol within 6 months

The European arrest warrant system was created by Council Framework Decision 2002/584/JHA; in Hungary it is transposed by Act CXXX of 2003. Judgments of the Court of Justice of the European Union between 2018-2024 (LM case, Aranyosi case, Generalstaatsanwaltschaft case) laid down the doctrine that member states can mutually trust each other’s judicial independence — but if in a concrete case there is a documented system-level risk, surrender can be refused. Between 2020 and 2026, Hungarian courts rejected some EAW requests from Poland and a few other EU member states on the basis of this doctrine — the reasoning logic was defensible in some cases, but in others appeared to serve a political-shield role.

MIAK’s proposal: the National Office for the Judiciary (OBH) — within the framework of the I4 (Protection of judicial independence) programme point — should develop within 6 months a new, detailed judicial protocol for the adjudication of EAW proceedings. The protocol obligatorily sets three elements: (a) precise application criteria of the CJEU’s LM and Aranyosi doctrine, (b) obligatory weighing of documented, fresh evidence concerning the rule-of-law situation of the requesting member state, (c) detailed, publishable reasoning in rejection decisions. In the Klitgaard framework (see 6.4.2) this makes the D (discretion) transparent: judicial discretion remains, but the decision becomes verifiable. Quantitative goal: from 1 January 2027, every EAW rejection decision published with anonymised reasoning; the rejection rate harmonises with the EU average; the Hungarian courts’ EU-level mutual trust index score (based on the EU Justice Scoreboard) shows substantive improvement.

3.3 Polish-Hungarian bilateral legal cooperation schedule — Tusk–Péter Magyar summit within 6 months

The Romanowski asylum froze the Polish-Hungarian relationship in the past two years. According to the April 2026 V4 Revival analysis of Visegrad Insight, the trio of Babiš, Fico and Tusk view Péter Magyar as a potential partner — in a kind of Carpathian Basin “d’Artagnan role” — but the trust reset can only be launched with concrete diplomatic gestures. MIAK’s proposal: within 6 months of the government’s formation, a Tusk–Péter Magyar bilateral summit in Warsaw, and the start of a formalised Polish-Hungarian legal cooperation schedule within the framework of KP6 (Multilateral-bilateral strategy differentiation).

The schedule includes: (a) joint judge-prosecutor-level working group to speed up EAW proceedings and restore mutual trust, (b) renewal of the Ministry of Justice cooperation memorandum (MoU), (c) joint action in shaping the EU rule-of-law conditionality mechanism — in the interpretation of KP4 (Principled pragmatism), this does not surrender the Hungarian position but aligns it with the logic of the EU-level receiving institutional system. Quantitative goal: by 30 November 2026, the first bilateral summit held; from 1 January 2027, joint working group on a monthly basis; according to the ECFR Coalition Explorer, Polish-Hungarian coalition cooperation in EU Council votes is at min. 50 percent by the end of 2027 (currently ~20 percent).

The common principle of the three proposals: building the receiving institutional system is not equivalent to the question of political accountability — the asylum review, the EAW reform and the V4 trust reset are to be interpreted in the institutional integrity framework, not in winner-loser logic. The Rose-Ackerman institutional integrity framework (see 6.4.1) emphasises exactly this difference: dismantling political-protection structures is not retorsion but the system-level restoration of mutual accountability.

Part IV — Expected effects and risks

Dimension Expected effect Risk
Foreign policy Polish-Hungarian normalisation starts; V4 trust reset becomes realistic (Tusk–Péter Magyar–Babiš–Fico). Within the V4, because of Fico’s Moscow trip (9 May 2026), the four-format is hard to keep coherent; the Hungarian-side opening risks Slovak-Hungarian tension.
Justice The Hungarian practice of the European arrest warrant becomes transparent; mutual trust among member states is restored. The protocol reform also tests the real perception of Hungarian judicial independence; if the Hungarian application of the LM doctrine is too strict, Hungarian courts lose the defensive argument should political-purpose intervention occur.
EU position Hungary shapes the system from within, as a constructive partner, in the rule-of-law conditionality debate (foreign-policy interpretation of Péter Magyar’s “to serve, not to rule” speech). The rapid turn after the Orbán era carries a credibility deficit; partners receive the Hungarian position change with caution until concrete, documented institutional reforms arrive.
Transparency The publicity of the asylum-review report sets a precedent for auditing the entire Orbán-era foreign-policy and legal legacy (NER asset extraction, EAW practice, Schengen visa consultations). The review is time-consuming and politically conflict-laden; if too expansive, the commission loses its operational capacity.

The main dilemma: the time gap between rapid normalisation (Polish-Hungarian summit within 6 months) and the deeper institutional audit (asylum review commission within 12 months). According to MIAK’s assessment, the fast step is politically necessary, the slow step is institutionally necessary — the two must not be accelerated at each other’s expense. The independence of the commission (the 6-member composition) is a guarantee that political haste does not distort the investigation.

Part V — Measurability and summary

5.1 What is worth tracking? (suggested key performance indicators (KPIs))

MIAK proposes four measurable KPIs on a 12-24 month time horizon:

  1. Asylum review ratio: 100% of political asylum decisions from 2010-2026 under audit by the end of May 2027; every wrong or potentially legally violating decision under prosecutorial referral.
  2. EAW rejection ratio harmonisation: the Hungarian judicial EAW rejection ratio approaches the EU average (2026 baseline: Hungarian rejection ratio ~14 percent, EU average ~6 percent); target: below 8 percent by the end of 2028.
  3. EU mutual trust index: substantive improvement of the EU Justice Scoreboard’s “perceived Hungarian judicial independence” indicator (currently ~30 percent → target: 45 percent+ by 2030).
  4. Bilateral cooperation indicator: according to ECFR Coalition Explorer data, the Polish-Hungarian coalition voting rate in the EU Council rises from 20 percent to above 50 percent by the end of 2027.

These are not promises but suggested, publicly verifiable metrics — they are worth tracking, because in a year’s time these will show whether the system-level reform has actually started.

5.2 Summary

The key message of the Romanowski case: in the first days of the Péter Magyar government, a legal-foreign-policy legacy must be settled which is one of the most visible institutional wounds of Orbán-era foreign-policy practice. MIAK’s request: with a rapid, transparent, legally grounded review — independent commission, OBH-level EAW protocol reform and Tusk-Péter Magyar summit — the government should demonstrate that the distortions of the political asylum-granting system are closed, and that the order of European cooperation is restored. This case directly affects MIAK’s foundational values of transparency and accountability: the publicity of the review and the reasoning of judicial decisions are not optional — the credibility of the receiving institutional system depends on whether every sovereign decision can be verified afterwards. The Orbán era built the asylum monopoly on the lack of transparency; the regime change will be credible if this monopoly does not continue with a new face but closes via a verifiable procedural path.

Part VI — Justifications and further sources

6.1 Press framing by spectrum

Notes from Poland (Polish-English language, public-affairs) and Euractiv (EU-focused, Brussels) present it in a conservative-pragmatic approach: they record the facts of the Romanowski escape, and position it on the Hungarian side as the legal test of the first days of the Péter Magyar government. Notes from Poland puts particular emphasis on the Tusk government’s position (the extradition request has been on the Hungarian table for years), and gives no substantive voice to the Hungarian Orbán-interest narrative — we interpret this in the spirit of objectivity, not as ideological one-sidedness.

Euractiv focuses on the structural dimension: a possible turn of the Visegrad revival, the strategic context of Polish-Hungarian relations, the dynamics of the EU Council voting pattern. The earlier (April 2026) V4 Revival analysis of Visegrad Insight examines the restart of the trust relationship among the four — the Romanowski case appeared as a metaphor of the Hungarian-side open wound in the analytical frame for experts.

In the Hungarian public space, the topic did not receive primary attention by 11 May 2026 — Sunday’s ministerial-team presentation (Péter Magyar’s speech, the appointment of Márta Görög and István Kapitány) drowned out the echo of the international press. The liberal-left band (Telex, 444.hu) operated with a few short references, the pro-government-conservative band (Magyar Nemzet, Mandiner) did not bring the topic into top focus on this day — it is expected to appear next week in the framing of the Orbán legacy. The economic band (Portfolio) did not substantively engage with it.

6.2 Facts and data

  • Legal basis of the European arrest warrant: Council Framework Decision 2002/584/JHA; Hungarian transposition: Act CXXX of 2003.
  • Hungarian judicial EAW rejection ratio 2024-2025: approx. 14 percent (EU average approx. 6 percent). Source: EU Justice Scoreboard 2025.
  • Hungary WGI 2024 indicators: government effectiveness +0.42; rule of law +0.35; control of corruption −0.17 (World Bank WGI).
  • Hungary-Poland EU Council voting coalition ratio 2024-2025: approx. 20 percent (ECFR Coalition Explorer).
  • Romanowski proceedings in Poland: embezzlement (siphoning of the Fundusz Sprawiedliwości — Justice Fund — on the order of 100 million zloty) and organised-crime membership charges; under European arrest warrant.

6.3 Policy dimensions

  • Foreign policy (programme points and background material) — KP3 Transparent foreign policy; KP4 Principled pragmatism; KP6 Multilateral-bilateral strategy differentiation; KP10 Regional resilience building. The V4 trust reset and the Polish-Hungarian bilateral renewal fit directly with the principled-pragmatism doctrine.
  • Justice (programme points) — I4 Protection of judicial independence; the EAW protocol reform and the Hungarian application criteria of the LM doctrine can be directly anchored here.
  • Transparency and anti-corruption policy (programme points) — A6 Strengthening checks and balances; A10 Independent Corruption Investigation Bureau (CPIB model). The institutional pattern of the asylum-review commission further builds the system of checks and balances.

6.4 Literature audit detail

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

Susan Rose-Ackerman (Yale legal scholar-economist, canonical author of corruption studies) developed the reform perspective of institutional integrity: high-level political corruption is not a moralising category but a phenomenon showing the flaw of the decision-making architecture. In the 2010-2026 phase of Hungarian asylum practice, the cabinet-level decision monopoly, the low accessibility of judicial review and the lack of parliamentary accountability together draw the structural pattern that Rose-Ackerman assigns to the high-level political corruption category.

The reform focus is not moralising condemnation but the transformation of the structure: the embedding of accountability mechanisms in the system, which do not make political decisions impossible but make them verifiable afterwards. (Rose-Ackerman paraphrase)

In the case of the Romanowski asylum case, this means: the aim is not the revocation of the 2024 decision, but the establishment of ex-post auditability for the entire 2010-2026 asylum-granting practice. This leads to the restoration of the European cooperation capacity of the Hungarian judicial and foreign-policy system.

📖 Source: Rose-Ackerman, Susan: Corruption and Government — Causes, Consequences, and Reform (Cambridge University Press, 1999)

6.4.2 Klitgaard, Robert: Controlling Corruption

According to the canonical formula of Robert Klitgaard’s Controlling Corruption (1988) — C = M + D − A — corruption (C) thrives where monopoly (Monopoly) and discretion (Discretion) meet with a lack of accountability (Accountability). The 2010-2026 phase of the Hungarian asylum system is affected in all three dimensions: cabinet-level asylum decisions are M-monopolistic; in political asylum the D (discretion) is almost unlimited; the A (accountability) is weak — no aggregated public report has been prepared on the decisions between 2010 and 2026. MIAK’s proposal strengthens one component of the formula, the A, at system level — the institution of the independent asylum-review commission builds in exactly the ex-post accountability layer.

The corruption gap is not always narrowed by reducing M (withdrawing state involvement), but most often by strengthening A (accountability): ex-post audit, public reasoning, verifiable procedure. (Klitgaard paraphrase)

📖 Source: Klitgaard, Robert: Controlling Corruption (University of California Press, 1988)

6.4.3 Kissinger, Henry: World Order

In World Order — Reflections on the Character of Nations and the Course of History (2014), Henry Kissinger analyses the tension between the Westphalian sovereignty order and the member-state cooperation system: the right of sovereign state decisions is preserved, but the stability of the international order depends on mutual accountability. The Romanowski case shows exactly this tension: the Hungarian asylum decision was sovereign, but exposed the Hungarian-Polish cooperation trust — and more broadly EU-level mutual judicial trust — to erosion.

Credibility is built or destroyed by decisions, not only by words. In an alliance system, credibility is a strategic asset that the next decision either accumulates or consumes. (Kissinger paraphrase)

The Romanowski asylum, in the last years of the Orbán cabinet, consumed a substantial part of the EU-level credibility asset. Exactly for this reason, in the first days of the new government the question of compromised credibility is not at the centre, but the rebuilding of credibility: this is the strategic value of the Hungarian position choice at every EU negotiation table in the coming years.

📖 Source: Kissinger, Henry: World Order — Reflections on the Character of Nations and the Course of History (Penguin Press, 2014)

6.5 International comparison

Out of the European patterns of ex-post auditability of political asylum-granting, three substantive:

  • Spain (2014, Pablo Iglesias-Tejero case): the political asylum granted by the government was subjected to ex-post judicial review by the Tribunal Supremo, and precedent-level criteria were developed — for the Hungarian pattern, the framework of judicial review proceedings is the cleanest.
  • United Kingdom (2019, post-Salisbury proceedings): the Home Office’s ex-post procedural audit — the obligation of publicly reasoning case-by-case decisions — institutionalised the Klitgaard A (accountability) component in the British asylum system.
  • Poland (Tusk government 2024-2026): ex-post review of PiS-era political asylum decisions from 2015-2023 — the closest neighbourhood example for the Hungarian pattern, from which the Hungarian commission can directly build.

Foreign policy

  • KP3 — Transparent foreign policy
  • KP4 — Principled pragmatism doctrine
  • KP6 — Multilateral-bilateral strategy differentiation
  • KP10 — Regional resilience building

Justice

  • I4 — Protection of judicial independence

Transparency and anti-corruption policy

  • A6 — Strengthening checks and balances
  • A10 — Independent Corruption Investigation Bureau (CPIB model)

Proposed new programme point: Annual asylum audit report — to the Transparency and anti-corruption policy area. Content: obligatory parliamentary submission of the annual aggregated report on political asylum-granting, with publication of (anonymised) reasoning for case-by-case decisions.

6.7 List of sources

Press sources (MIAK foreign press monitor, 11 May 2026 — 2nd topic):

  • [Notes from Poland] Former Polish justice minister granted asylum by Orbán flees Hungary for US — https://notesfrompoland.com/2026/05/10/former-polish-justice-minister-granted-asylum-by-orban-flees-from-hungary-to-us/
  • [Euractiv] Poland’s wanted ex-minister confirms he fled to US from Hungary — https://www.euractiv.com/news/polands-wanted-ex-minister-confirms-he-fled-to-us-from-hungary/
  • [Visegrad Insight] V4 Revival: Babiš, Fico and Tusk Call Magyar Their d’Artagnan — https://visegradinsight.eu/revival-of-visegrad-group-babis-tusk-epc-yerevan/

Knowledge-base references (literature):

  • 📖 Rose-Ackerman, Susan: Corruption and Government — Causes, Consequences, and Reform (Cambridge University Press, 1999)
  • 📖 Klitgaard, Robert: Controlling Corruption (University of California Press, 1988)
  • 📖 Kissinger, Henry: World Order — Reflections on the Character of Nations and the Course of History (Penguin Press, 2014)

Note: the local file path of the book does not appear in the visible text of the blog — only the author and title. The file path is an internal matter of the generation process, not of the reader.

MIAK-internal materials:

  • MIAK policy area: Foreign policy (programme points; programme point IDs: KP3, KP4, KP6, KP10)
  • MIAK policy area: Justice (programme points; programme point ID: I4)
  • MIAK policy area: Transparency and anti-corruption policy (programme points; programme point IDs: A6, A10)
  • MIAK foreign press monitor, 11 May 2026 — 2nd topic, score: 87/100

Supplementary public data sources:

  • EU Justice Scoreboard 2025 — mutual trust indicators of European courts
  • Council Framework Decision 2002/584/JHA (European arrest warrant)
  • Act CXXX of 2003 (Hungarian transposition of the framework decision)
  • World Bank Worldwide Governance Indicators 2024
  • ECFR Coalition Explorer (EU Council voting patterns)

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