Part I — Situation overview

On 28 May 2026 the Prime Minister announced, in a video posted on his social-media page from Brussels, that Hungary is officially joining the European Public Prosecutor’s Office (EPPO — European Public Prosecutor’s Office, the joint EU prosecutorial body that investigates and prosecutes crimes harming the EU budget — fraud, corruption, cross-border VAT fraud). The announcement is part of the series of negotiations in which the government is discussing, with the leaders of the European Commission, the release of the several thousand billion forints of cohesion and recovery funds withheld so far. Enlargement Commissioner Marta Kos, meanwhile, spoke favourably about the Ukrainian–Hungarian relationship and the negotiations on opening the chapters of Ukraine’s EU accession.

The picture, however, is not unambiguously favourable. On the same day the Commission signalled: before the funds are paid out it expects substantive reforms, and the pro-government press spoke of the price of “painful austerity”. In parallel, two new infringement procedures were also launched against Hungary — one over informing consumers in connection with the green transition, the other over the incomplete transposition of the EU directive on protecting workers against lead and certain chemical substances — and the new cabinet has two months to dispel the Commission’s concerns. The release of the funds thus depends not on a single gesture, but on the credibility of an entire institutional transition.

In MIAK’s reading, the real novelty of the news is not the fact of the Brussels negotiation — there were several of those in recent weeks — but the membership itself: EPPO accession is a concrete, irreversible institutional commitment, which for the first time tests whether the recovery of the funds comes with genuine accountability or only with a rhetorical concession. The institution-building against corruption is not political stage scenery: the stake is whether the path of public money becomes verifiable. As one of the classics of corruption research, Susan Rose-Ackerman (American legal scholar and economist, professor at Yale University, leading author of the economic and institutional analysis of corruption), puts it: the goal is to “reduce the gains from paying and accepting bribes, not merely to remove the »rotten apples«”.

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

Part II — Literature audit

Before turning to MIAK’s concrete proposals, it is worth fixing the scholarly framework in which EPPO accession and the conditionality can be interpreted. According to the C = M + D − A formula of Robert Klitgaard (American economist, pioneer of the economic modelling of corruption), corruption flourishes where monopoly (M) and discretionary power (D) meet the absence of accountability (A) — and EPPO strengthens exactly the A factor with an EU-level investigative-prosecutorial capacity independent of domestic political influence. Rose-Ackerman devotes a separate chapter to independent prosecutorial and judicial institutions, and to the role of the international community: her argument is that effective reform requires internal political will and external institutional support at the same time — this is precisely the logic of EPPO. Daniel Kaufmann (former head of the World Bank’s governance research programme) breaks down, in his work Governance Matters, the quality of governance into measurable indicators (among them the “control of corruption” and “accountability” indicators), and shows that these are closely linked with development outcomes — this provides the performance yardstick of the funds’ conditionality. The detailed literature treatment — 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 that turn the symbolic act of accession into a verifiable guarantee.

3.1 Substantive filling-out of EPPO membership (within 90 days)

The legal act of joining is worth little on its own if it is not followed by operative cooperation. MIAK proposes that within 90 days the government publish a concrete implementation plan for cooperation with EPPO: the number and appointment procedure of the delegated European prosecutors, the division of labour with the domestic investigating authorities, and the protocol for transferring cases concerning VAT fraud and EU funds. Within the framework of KP19 (international institutional-reform position) and KP4 (principled-pragmatism doctrine), this is not a surrender of sovereignty, but a reciprocity-based institutional relationship serving the protection of Hungarian taxpayers’ money. In Klitgaard’s C = M + D − A frame (see 6.4.1), EPPO directly strengthens the accountability (A) factor, because it removes criminal cases concerning the funds from the exclusive remit of domestic political discretion.

3.2 Making the conditionality two-way — measurable reform for the money (by the autumn 2026 budget)

According to MIAK, the release of the funds must be tied not to political gestures, but to verifiable, quantified reforms — and in such a way that the Hungarian side itself also makes itemised commitments, not only Brussels dictating. Concretely: every project financed from EU funds above 500 million forints should receive a public data sheet (beneficiary, amount, purpose, deadline, performance), and a clawback mechanism should be built in, which reclaims a proportionate part of the support for projects that fail to meet their target indicators. This is the direct application of the A8 (cohesion-policy accountability) and A2 (public-procurement transparency) programme points. The measurability of the reform is the key: Kaufmann’s governance indicators (see 6.4.3) provide the performance yardstick along which both the Commission and the Hungarian public can follow the progress.

3.3 Independent domestic corruption-investigation capacity (by 2028)

EPPO does not replace but complements the domestic institutional system: in purely domestic corruption cases not concerning EU funds, the Hungarian bodies must continue to act. MIAK therefore proposes setting up the A10 (independent corruption-investigation office, modelled on the Singaporean CPIB) and strengthening the A5 (whistleblower system). In this way accession is not a responsibility shifted onto an external institution, but part of a coherent accountability system made up of domestic and EU elements.

The shared principle of the three proposals is that the value of membership is given by consistent compliance with the law: the symbolic accession must be accompanied by operative cooperation, the funds bargain by measurable reform, and the external institution by strong domestic complementation. EPPO strengthens the protection of Hungarian public money only if the internal political will described by Rose-Ackerman and the external institutional frame are present together.

Part IV — Expected impacts and risks

Dimension Expected impact Risk
Economy The controlled release of the funds triggers investment and a demand-boosting effect; a fall in the irregularity rate improves absorption Overly strict, hastily introduced control may slow payment, and the funds may remain unused
Society The transparency of public-money use grows, the space for clientele-based distribution shrinks The “austerity” narrative may breed political resistance if the reform is not accompanied by clear communication
Public administration / justice EPPO cooperation strengthens independent investigative capacity and domestic institutional learning Jurisdictional friction between the domestic prosecution service and EPPO if the transfer protocol is unclear

The main dilemma is stretched between accountability and absorption capacity: if the control is too strict and bureaucratic, the smaller beneficiaries are deterred from applying, and the funds remain unused — a risk also flagged by the cohesion literature. The proposal works if the control stays strong for large projects, while for small projects a simplified accounting eases the administration. EPPO membership tips to the risk side if it remains merely symbolic: if the appointment of the delegated prosecutors drags on, or the domestic cooperation is formal. The Hungarian prosecution service is an independent constitutional body, the Prosecutor General cannot be instructed in a specific case — and precisely for this reason the division of labour with EPPO must rest on legislation, not on an informal bargain.

Part V — Measurability and summary

5.1 What is worth tracking? (suggested KPIs)

MIAK proposes tracking the following performance indicators (KPIs, in English: Key Performance Indicator) — in 12–24 months these will show whether the turnaround is real:

  • whether the irregularity rate of public procurements financed from EU funds falls (target: durably below 1% from the current 2–3% band);
  • what percentage of projects above 500 million forints has a publicly available data sheet (target: 100% by the end of 2027);
  • whether the Hungarian European prosecutors delegated to EPPO have been appointed, and whether a substantive EU-funds case with a Hungarian dimension has been launched;
  • the pace of EU-funds drawdown relative to gross domestic product (GDP) — whether absorption rises alongside the tightening of control.

We stress: these are suggested measurement points that are worth tracking — not government commitments.

5.2 Summary

MIAK’s message to the decision-maker: the announcement of accession is a good start, but credibility is given by implementation. EPPO membership must be filled out with operative cooperation, and the funds bargain with measurable and public conditions — otherwise the turnaround remains rhetorical. The request to the public is that we hold to account not the announcement, but the measurable result (data sheets, irregularity rate, prosecutorial cooperation).

This topic moves two MIAK foundational values. Transparency is concerned because making the path of public money public is the only lasting protection against clientele-based distribution; and accountability, because EPPO and the domestic control institutions supply exactly that missing A factor without which — according to Klitgaard’s formula — the funds, in any amount, would only increase the corruption risk. For MIAK the question is not whether we accept the Brussels conditions, but whether we finally institutionalise the protection of our own public money.


Part VI — Justifications and further sources

6.1 Press framing by spectrum

The economic press (Portfolio) highlighted the factual duality: alongside the announcement of accession, the two new infringement procedures and the two-month deadline, that is, the conditional nature of the funds release. The public-affairs and left-leaning band (ATV, Népszava) rather emphasised the positive, turnaround-signalling side of the announcement, together with the favourable enlargement-commissioner statement on the Ukrainian accession chapters. The pro-government conservative band (Magyar Nemzet, Mandiner), by contrast, chose the frame of “painful austerity” and “Brussels wants reforms before the money” — Mandiner put it that Brussels is trying to avoid the appearance that “it had been withholding the money so far for purely political reasons”. The three bands fit the same event into three different narratives: turnaround, condition and austerity — in MIAK’s data-driven reading all three are part-truths, but none is the full picture.

6.2 Facts and data

  • The scale of the withheld EU funds in the negotiations is several thousand billion forints (cohesion and recovery funds together).
  • The EU-level irregularity rate of cohesion funds is typically 2–3% — in the leading Estonia it is below 0.5%, thanks to digital record-keeping and strong internal audit.
  • Hungary’s governance-quality indicators according to the 2024 data of the World Bank’s Worldwide Governance Indicators: control of corruption −0.17 (a value close to zero but negative, indicating below-EU-average accountability), rule of law +0.35, government effectiveness +0.42.
  • The new cabinet has two months to dispel the Commission’s concerns in the two fresh infringement procedures.

6.3 Policy aspects

  • Foreign policy (programme points) — the framework of EPPO accession and case-based EU coalition-building;
  • Transparency and anti-corruption policy (programme points) — cohesion accountability, public-procurement transparency, independent corruption investigation;
  • Economy (background material) — the absorption capacity of EU funds and the investment effect.

6.4 Literature in detail

6.4.1 Robert Klitgaard: Controlling Corruption

Klitgaard traces corruption back to a simple relationship with a principal–agent–client logic: “Illicit behaviour flourishes where agents have monopoly power over clients, when agents have great discretion, and when accountability of agents is weak.” From this follows the famous formula: corruption is the sum of monopoly and discretionary power, minus accountability (C = M + D − A). The key is not the opposition of state and market, but — in Klitgaard’s words — “competition and accountability”. In the case of EU funds this means: EPPO membership strengthens the A factor, because it brings a prosecutorial capacity independent of domestic political discretion in over criminal cases concerning public money.

📖 Source: Robert Klitgaard: Controlling Corruption

6.4.2 Susan Rose-Ackerman: Corruption and Government

Rose-Ackerman treats corruption as both an economic and a political problem, and stresses: “Effective reform cannot occur unless both the international community and domestic political leaders support change.” She devotes a separate chapter to independent prosecutorial and judicial institutions, and to the anti-corruption role of the international community — and these two threads meet precisely in the construction of EPPO: an international institution that strengthens domestic accountability. In the Hungarian EU-funds case this means that membership is effective only if the internal political will (the undertaking of operative cooperation) and the external institutional frame (EPPO’s competence) prevail together.

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

6.4.3 Daniel Kaufmann: Governance Matters

Kaufmann and his co-authors distinguish and make measurable six basic governance concepts — among them the “accountability”, “government effectiveness”, “rule of law” and “control of corruption” indicators — and show that these indicators are significantly linked with development outcomes. The basic claim: the quality of governance is measurable, and it matters. In the Hungarian EU-funds case this provides the logic of the conditionality: the release of the funds must be tied not to political trust, but to these quantifiable indicators, along which both the Commission and the Hungarian public can follow the actual progress.

📖 Source: Daniel Kaufmann: Governance Matters

6.5 International comparison

EPPO operates today in 24 EU member states; with the Hungarian accession the circle of those staying outside narrows further. In its first years, under real caseload, the institution proved that it is more effective than purely national procedure in detecting cross-border VAT fraud and abuses concerning the structural funds. The practical model of cohesion accountability is given by Estonia: through digital record-keeping and strong internal audit, the irregularity rate of EU funds is the lowest there (below 0.5%). In Poland the introduction of the public-procurement “red flag” (risk-indicator) system cut the share of suspicious procedures by about 15% in the 2014–2020 cycle — proving that Klitgaard’s accountability can also be built technically.

Transparency and anti-corruption policy

  • A8 — Cohesion-policy accountability
  • A2 — Public-procurement transparency
  • A10 — Independent Corruption-Investigation Office
  • A5 — Whistleblower system
  • A14 — International institutional participation and accountability

Foreign policy

  • KP19 — International institutional-reform position
  • KP17 — Case-based coalition-building in the EU
  • KP4 — Principled-pragmatism doctrine

6.7 Source register

Press sources (MIAK press monitor, 29 May 2026 — topic 1):

Knowledge-base references (literature):

  • 📖 Robert Klitgaard: Controlling Corruption
  • 📖 Susan Rose-Ackerman: Corruption and Government — Causes, Consequences, and Reform
  • 📖 Daniel Kaufmann: Governance Matters

Note: the visible text of the blog does not show the books’ local file path — only the author and title. The file path is an internal matter of the generation process, not the reader’s.

MIAK internal materials:

  • MIAK policy area: Transparency and anti-corruption policy (programme points; programme point ID: A8)
  • MIAK policy area: Foreign policy (programme points; programme point ID: KP19)
  • MIAK policy area: Economy (background material)
  • MIAK press monitor, 29 May 2026 — topic 1, score: 87/100

Additional public data sources:

  • World Bank Worldwide Governance Indicators 2024 (control of corruption, rule of law, government effectiveness)
  • European Commission — cohesion and RRF database; European Public Prosecutor’s Office (EPPO) annual report; OLAF; European Court of Auditors

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