Part I — Situation overview

On 21 May 2026 Science and Technology Minister Zoltán Tanács announced on his official social-media platform: the Managing Authority of the Digital Renewal Operational Programme Plus (DIMOP Plus) had taken decisions on 11 projects totalling HUF 22.59 billion in the final days before the election — more precisely on 8 and 10 April 2026, that is 2-4 days before the 12 April 2026 parliamentary election. Telex in its 21 May 2026 summary opened with the HUF 14.59 billion figure; Népszava and Portfolio gave the full HUF 22.59 billion total, and highlighted the nine cases where the decision was taken two days before the election. According to the indications, the support decisions involved an unusually short 24-day evaluation procedure — the typical DIMOP Plus procedure is significantly longer.

The funding contracts — according to confirmation by 24.hu and Portfolio — have not yet been concluded by the Ministry of Science and Technology; payments are suspended until the detailed checks are concluded. Among the beneficiaries, in the data shared with Telex Zoltán Tanács listed: Civil út Foundation (~HUF 3 billion), Hungarian Reformed Charity Service Foundation (~HUF 3 billion), Tábor Youth-Rescue Foundation (~HUF 2 billion), Baptist Active Love Mission (~HUF 2 billion), MINDFLUENCER Public Benefit Association (~HUF 623 million), Catholic Caritas (~HUF 550 million), Security Research and Development Centre Non-Profit Plc (HUF 1.5 billion) and Hungarian Healthcare Management Society (~HUF 1.5 billion) — the list typically contains ecclesiastical-cooperative and non-profit organisations.

MIAK’s reading: the HUF 22.59 billion public-money distribution is a single matter within one DIMOP Plus Managing Authority — auditing the entire 2025-2026 pre-election period will affect a substantially greater volume. The present analysis does not focus on the individual evaluation of the specific DIMOP case but on the systemic pattern that Zoltán Tanács’s announcement reveals: pre-election public-money distribution in Hungary is not an irregularity but the textbook pattern of Rose-Ackerman’s political business cycle — a structural, not an ad hoc phenomenon.

Part II — Literature audit

Before turning to MIAK’s concrete proposals, it is worth fixing the scholarly framework within which the topic can be interpreted. In Corruption and Government — Causes, Consequences, and Reform (1999) Susan Rose-Ackerman analyses in detail the entanglement of pre-election public-money distribution (election-cycle distribution) and the patronage system (political-organisational patronage networks with public-money distribution): the phenomenon is not country-specific but structural — the party in power gets strong incentives to build short-term electoral support in any system where it can still freely decide on public-money distribution in the last weeks before the election. In Controlling Corruption (1988) Robert Klitgaard distinguishes between the tools of ex-ante control (prior institutional fences) and ex-post investigation (later accountability): his empirical finding is that ex-post mechanisms — though necessary — never reach the preventive efficiency of ex-ante institutional control. The MIAK 3.1 pre-election embargo proposal rests on this theoretical grounding. The detailed literature treatment — author 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 for the systemic handling of pre-election public-money distribution. The proposals focus on ex-ante (preventive) control, not on ex-post (later) accountability — in Klitgaard’s categorisation (see 6.4.2) this is the more effective intervention order.

3.1 6-month pre-election embargo on new support decisions (statutory amendment within 90 days)

A “pre-election embargo” concept should be introduced via an amendment of the new budget act (the Act CXCV of 2011 on public finances in force): in the final 6 months of any government cycle a new or amended support decision (operational programmes, direct government grants, direct ministerial budget reallocation) can only be taken if the State Audit Office (ÁSZ) — an independent public-law body elected with a two-thirds vote — gives a prior opinion on it. The ÁSZ opinion is not a veto but a professional-procedural evaluation: it examines the urgency of the decision, the methodology of beneficiary selection, and the recording of evaluation criteria. Exceptions from the embargo are limited to: (a) natural disaster, (b) urgent threat to life, (c) EU bid deadline pressure (in a verifiable manner). Legal form: amendment of the Public Finances Act + extension of the ÁSZ Act (Act LXVI of 2011) — two cardinal-act amendments, requiring a two-thirds vote, which is available with Tisza’s 141-mandate caucus.

3.2 Automatic mandatory audit by the new government of the previous cycle’s final 6-month decisions (within 180 days)

The new government — whether Magyar Péter’s or a future one — should be required, within 180 days of taking office, to audit 100% of the previous government’s final 6-month support decisions, and to make the audit results public. The audit methodology: where the ÁSZ has already given a prior opinion under 3.1, the ex-post audit only checks implementation compliance; in all other cases (if the decision predates 3.1, or where the ÁSZ opinion was missing) a full substantive audit is mandatory. The 21 May 2026 Zoltán Tanács announcement is the practical antecedent of this obligation — at present it began on an individual, ad hoc decision of the new ministerial leadership; under proposal 3.2 in future this should be a government-level obligation, fixed in law. Related cabinet perspective: 10 ethical framework.

3.3 Mandatory public procurement or transparent minimum 30-day evaluation procedure for EU-fund disbursements (within 12 months: EU negotiation + national legal framework)

The 21 May 2026 announcement highlighted that an unusually short 24-day evaluation procedure was used for certain DIMOP Plus bids. MIAK proposes: for every EU-co-financed support decision above HUF 1 billion either (a) a standard public procurement procedure, or (b) at least a publicly advertised 30-day procedure with documented evaluation criteria should be mandatory. The 30-day minimum can be introduced through amendments to the Hungarian legal framework (the Public Finances Act + Government Decree 272/2014 on the rules of using the 2014-2020 EU funds); in addition, consultation with the EU Commission is needed so that this Hungarian national minimum regulation can be integrated into the conditionality framework (grounded in the 19 May 2026 Kármán talks). Linked to the A4 lobby-register extension (UBO transparency obligation of beneficial owner of the beneficiary organisations), and to the G7 lawful use of EU funds programme point.

The common principle of the three proposals is the structural interruption of the political business cycle (Rose-Ackerman, see 6.4.1) with ex-ante institutional fences: the embargo (3.1), the mandatory audit (3.2) and the 30-day minimum (3.3) together ensure that the public-money procedure in the final months before an election cannot be a party-political financial instrument.

Part IV — Expected impacts and risks

Dimension Expected impact Risk
Budget The structural pattern of pre-election public-money distribution is interrupted, medium-term fiscal discipline improves Deliberate expansion of the embargo exceptions (3.1 (a)-(c)) can become a political tool if the ÁSZ is not sufficiently independent
EU funds The 30-day minimum procedure fits the EU conditionality framework and reduces the risk of repayment In concrete cases of short EU bid windows (e.g. CEF, Horizon Europe) the 30-day minimum may collide with the Commission’s own deadlines
ÁSZ role The ÁSZ becomes the key player of the pre-election embargo — its professional-legal authority grows The ÁSZ’s professional capacity (currently ~200 experts) may not be enough to review 6 months of full government support decisions
Political effect The use of the final months before an election as a party-political financial instrument ceases Future governments may tend to creative interpretations of the exception rules of the 6-month embargo

The main dilemma is the tension between strengthening the ÁSZ role and execution speed. The current DIMOP Plus-style 24-day procedure is fast but untransparent; the proposed 30-day minimum is slower but auditable. MIAK’s assessment is that the transparency benefit outweighs the speed loss — especially because the 30-day minimum would only apply to decisions above HUF 1 billion (smaller, urgent decisions remain in the existing flexible procedure).

Part V — Measurability and summary

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

  • Outcome of the DIMOP Plus audit: in how many of the 11 projects affected by the HUF 22.59 billion does the audit establish irregularities — target: the share and amount of projects qualified by the ÁSZ as irregular should be disclosed transparently.
  • Number of new support decisions in the 6 months before the election (2030): how many new government support decisions are taken in the 6 months before the next (2030) parliamentary election — target: zero, or only cases with prior ÁSZ opinion.
  • 30-day evaluation minimum compliance: what percentage of EU-co-financed support decisions above HUF 1 billion meet the 30-day minimum — target: 100% if proposal 3.3 is adopted.
  • EU funds repayment rate: in 2026-2030 the share of funds reclaimed by the EU relative to total Hungarian EU allocation — target: ≤ 0.5% (current level is around 2-3%).

5.2 Summary

The 21 May 2026 Zoltán Tanács announcement revealed a structural weak point of the Hungarian public-administration system: pre-election public-money distribution is not an irregularity but, in the period after 2010, an institutionalised political business cycle-style pattern in Rose-Ackerman’s typology. MIAK’s three-element reform package — ex-ante embargo, mandatory ex-post audit, EU-compatible minimum procedure — builds on Klitgaard’s institutional control theory and proclaims the primacy of ex-ante mechanisms: instead of punishing afterwards we must prevent systemically. The package of proposals directly touches two of MIAK’s foundational values: transparency (the public disclosure of the HUF 22.59 billion case creates a precedent for mandatory transparency), and accountability (the strengthening of the ÁSZ role places executive use of public money under independent control). The success of the reform becomes measurable in the 6 months before the next 2030 election: if zero new government support decisions are made then, or only with ÁSZ approval, the structural change of the system has taken place.

Part VI — Justifications and further sources

6.1 Press framing by spectrum

In the liberal spectrum Telex gave a detailed, list-level account — it published the announcement with the name of every one of the 9 beneficiary organisations and the precise amounts. This factual coverage is the most data-oriented. HVG chose a more general framing of the topic (“skeletons close to the election”), linking it to similar cases leaking out of other ministries. Népszava emphasised the scandal volume by foregrounding the HUF 22.59 billion total figure (the HUF 14.59 billion figure from Telex may be a narrower subset — the audit will clarify the difference between the two numbers).

In the public-affairs lane 24.hu placed Attila Vári’s own investigation (HUF three billion — the amount awarded two days before the election) alongside Zoltán Tanács’s announcement of a comprehensive audit — procedural-political framing. Portfolio highlighted the economic-fiscal context (“another skeleton from a ministry”) and emphasised the unusual nature of the 24-day evaluation procedure — professional-regulatory framing.

From the conservative-pro-government lane (Magyar Nemzet, Mandiner) the topic did not reach the top-ten focus that day, according to the press monitor — Magyar Nemzet foregrounded the curriculum reform, Mandiner the framing of Magyar Péter’s announcements.

6.2 Facts and data

  • DIMOP Plus Managing Authority pre-election decisions (published amounts):
    • 8 April 2026 and 10 April 2026: 11 projects in total, HUF 22.59 billion (Portfolio reporting)
    • 9 concrete beneficiaries published by Telex: HUF 14.59 billion (Telex partial list)
    • The difference (~HUF 8 billion) concerns further, unnamed beneficiaries — the audit will clarify
  • Election date: 12 April 2026 parliamentary election (NVI 19 April 2026 finalisation)
  • New government’s oath of office: 9 May 2026 (Magyar Péter as Prime Minister, at the constituent session)
  • Leadership of the Ministry of Science and Technology: Zoltán Tanács (in office from 9 May 2026)
  • Relevant statutes:
    • Act CXCV of 2011 on public finances
    • Act LXVI of 2011 on the State Audit Office
    • Government Decree 272/2014 (XI. 5.) on the rules of using the 2014-2020 EU funds

6.3 Policy aspects

  • Transparency and anti-corruption policy (programme points) — the A4 lobby-register extension and the A11 public-property revision are directly concerned; the 3.2 ex-post audit obligation is a new element strengthening the A12 public-power office-holders accountability programme point.
  • Economy (programme points) — the G7 lawful use of EU funds programme point is directly concerned by proposal 3.3.
  • Digitalisation and AI regulation (background material) — in the context of DIMOP Plus as an operational programme targeted at the digital sector, the D3 digital public procurement and algorithmic transparency programme point connects.

6.4 Literature in detail

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

Rose-Ackerman uses the term political business cycle to describe the phenomenon where the ruling government, in the final quarter of the electoral cycle, raises the public-money expenditures it can discretionarily distribute — to build short-term electoral support. The phenomenon is structural, not country-specific: in chapter 6 of the book (Bribes, Patronage, and Gift Giving) Rose-Ackerman lists Philippine, Nigerian and Latin American cases as examples, all with the common feature of an extraordinary 3-6 month spending spike before the election. The Hungarian 8-10 April 2026 DIMOP Plus case fits typologically exactly here. Rose-Ackerman’s institutional recommendation: the best tool to interrupt the political business cycle is not an ex-post criminal sanction but an ex-ante institutional fence — that is precisely why MIAK proposes the 3.1 pre-election embargo, not the extension of ex-post accountability.

In Rose-Ackerman’s conceptual frame, interruption of the political business cycle is possible through two structural elements of the state decision-making system: (a) the institutional ban on pre-election discretionary spending, (b) public-level recording of the methodology of beneficiary selection.

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

6.4.2 Robert Klitgaard: Controlling Corruption

In Controlling Corruption Klitgaard provides a classification of anti-corruption interventions: ex-ante (prior institutional fences that reduce or eliminate the corruption incentive) vs. ex-post (later detection, investigation and punishment mechanisms that sanction the corruption already occurred). In chapter 3, based on empirical arguments — the Plana BIR reform and Hong Kong’s ICAC as positive examples — Klitgaard argues that ex-ante control is the more effective intervention: ex-post mechanisms never reach the preventive efficiency a well-designed institutional framework can provide. The MIAK 3.1 pre-election embargo proposal rests on this theoretical grounding — we do not want to punish the irregularity detected later but to prevent the incentive situation arising at all.

“Selecting agents for incorruptibility as well as technical competence … Changing the organization’s mission or administrative system so that the agent’s discretion is reduced.” — Klitgaard’s principles name the concrete tools of ex-ante control; the ÁSZ prior opinion fits precisely into the discretion is reduced logic.

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

6.5 International comparison

Several EU member states have introduced institutional regulation to handle pre-election public-money distribution. Germany in the framework of the AO (Abgabenordnung — tax-and-public-finance code) ties decisions on Bundestag grants between 1 April of the election year and the new government taking office to a strict prior committee audit procedure. France in Article L52 of the Code électoral (2003 amendment) bans new discretionary support decisions of the central government to beneficiary areas in the 6 months preceding an election — substantially the same principle as the Hungarian proposal. The Netherlands vests the Algemene Rekenkamer (the Dutch ÁSZ equivalent) with the power to give a prior opinion on every government support decision above EUR 5 million in the final 3 months before an election. The MIAK 3.1-3.3 proposal integrates the French-Dutch pattern into the Hungarian institutional framework — not through a separate “code” regulation but through amendments of the existing Public Finances Act and ÁSZ Act.

Transparency and anti-corruption policy

  • A4 — Lobby-register extension (UBO transparency)
  • A11 — Public-property revision and restitution
  • A12 — Public-power office-holders accountability

Economy

  • G7 — Lawful use of EU funds

Digitalisation and AI regulation

  • D3 — Digital public procurement and algorithmic transparency

Proposed new programme point: Pre-election public-money embargo and mandatory ex-post audit (proposals 3.1 and 3.2 together) — for the Transparency and anti-corruption policy policy area.

6.7 Source register

Press sources (MIAK press monitor, 22 May 2026 — topic 4):

Knowledge-base references (literature):

  • 📖 Susan Rose-Ackerman: Corruption and Government — Causes, Consequences, and Reform (Cambridge University Press, 1999)
  • 📖 Robert Klitgaard: Controlling Corruption (University of California Press, 1988)

MIAK internal materials:

  • MIAK policy area: Transparency and anti-corruption policy (programme points; programme point IDs: A4, A11, A12)
  • MIAK policy area: Economy (programme points; programme point ID: G7)
  • MIAK policy area: Digitalisation and AI regulation (programme points; programme point ID: D3)
  • MIAK press monitor, 22 May 2026 — topic 4, score: 84/100

Additional public data sources:

  • ÁSZ (State Audit Office) — public procurement and public-finance audit reports
  • European Commission DG REGIO — annual reports of operational programmes
  • OLAF (European Anti-Fraud Office) — annual report on the regularity of Hungarian EU funds

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