Part I — Situation overview

The Hungarian EU-funds matter has entered a new phase: after the agreement, the meeting of the conditions has now come into the centre. On Tuesday 2 June 2026, Michael McGrath, the European Commission’s commissioner for the rule of law and consumer protection, arrived in Budapest — the visit directly after the political agreement reached in the preceding days on the release of EUR 16.4 billion (on the order of HUF 6,000 billion) of previously frozen EU funds. On the Hungarian side the commissioner was received by Bálint Ruff of the Prime Minister’s Office and Márta Görög, the leaders responsible for EU affairs. According to Anita Orbán, state secretary for EU affairs, ’everyone knows that this money is due to Hungarians’ — while the Commission, in Portfolio’s wording, ‘pulled the handbrake because of corruption’, that is, it tied concrete, verifiable conditions to the funds.

To understand the background it is worth placing two things side by side. One is the funding envelope: the unfrozen EUR 16.4 billion is made up of the post-COVID Recovery and Resilience Facility (RRF — the EU’s one-off recovery fund), the cohesion funds tied to the rule-of-law procedure, and the envelope linked to academic freedom. The other is the condition: on 1 June 2026 the European Union’s new anti-corruption directive entered into force, which harmonises the definition of corruption offences, prescribes minimum rules for penalties and limitation periods, and requires a national anti-corruption strategy from every member state. One cornerstone of the EUR 16.4 billion agreement is precisely the transposition of these anti-corruption measures into Hungarian law. The commissioner’s visit and the directive’s entry into force are thus not two separate news items but two sides of the same process: the unfreezing of the money and the condition becoming binding.

In MIAK’s reading the stake is not whether ‘we get’ the money, but whether we meet the conditions with real institutional content or only on paper. For the conditionality system is not an external punishment but addresses precisely the deficiency that originally blocked the funds: the weakness of procurement competition and the shortcomings in detecting corruption. For whoever wants to manage cleanly, the condition is not an obstacle but the guarantee of lasting absorption.

Part II — Literature foundation

Before turning to MIAK’s concrete proposals, it is worth fixing the interpretive frame, because the logic of the conditionality system rests on scholarly foundations. According to Robert Klitgaard (an American development economist, the creator of the still-cited corruption formula), corruption flourishes where a monopoly position and broad discretion meet the absence of accountability — in formula form C = M + D − A (corruption = monopoly + discretion − accountability). In this frame the EU conditions are not arbitrary: they strengthen precisely the A, the accountability factor, and thereby reduce the space for corruption. Susan Rose-Ackerman (an American lawyer-economist, a leading researcher of the connections between corruption and government) adds that ‘grand corruption’ typically takes place precisely through large state projects, public procurements and concessions, and that the most effective protection is a ‘credible, apolitical monitoring system’ — that is, the institutional independence of detection. The two theses together give MIAK’s frame: the condition works when it genuinely strengthens accountability and independent oversight, not when it merely copies statutory text. 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 steps so that the conditionality system is not a box-ticking formality but a lasting guarantee of clean fund management.

3.1 Substantive, non-sham transposition of the anti-corruption directive (by summer 2026)

MIAK proposes that the Hungarian transposition of the new EU anti-corruption directive should not merely meet the conceptual minimum, but that the national anti-corruption strategy be measurable in substance too. In Klitgaard’s C = M + D − A framework (see 6.4.1) this strengthens the A (accountability) factor: the strategy must contain concrete, deadline-bound commitments on limitation periods, the investigative toolkit and prevention, with publicly trackable performance indicators. This builds directly on programme point A14 (international institutional participation and accountability). The responsible ministries are the Ministry of Justice and the Ministry of Finance, and the deadline is the time of the summer milestones set for meeting the conditions. The aim is that the transposition stand up at the EU commissioner’s review as substantive, not formal, compliance.

3.2 Real-time procurement transparency for the unfrozen funds (Q3–Q4 2026)

The cohesion envelope tied to the rule-of-law procedure was withheld precisely because the EU side saw procurement and corruption risks in it. MIAK therefore proposes, along programme point A2 (procurement transparency), that for procurements financed from the unfrozen funds the public, quarterly publication of the share of single-bidder procedures be mandatory, and that tenders crossing this threshold carry a separate obligation to give reasons on the part of the contracting authority. According to Rose-Ackerman’s analysis (see 6.4.2), large state contracts are the primary channels of corruption, so the return on control is greatest here. This does not slow absorption — on the contrary: credible control reduces the risk that the Commission later orders a suspension or correction, which would set back the entire timetable.

3.3 Independent corruption detection with real powers, and the traceability of public money

The third proposal is about the institutional side of detection. Within programme points A10 (independent corruption-investigation office — based on the Singaporean CPIB model) and A1 (public-money dashboard), MIAK holds that the anti-corruption strategy should be given a real institutional backbone: a politically independent body with appropriate investigative powers and resources, which translates into practice the ‘credible, apolitical monitoring’ emphasised by Rose-Ackerman. This should be accompanied by a public, universally accessible public-money website that tracks the entire cycle of the unfrozen funds: milestones, payment requests, committed and actually disbursed amounts. Hungary’s accession to the European Public Prosecutor’s Office (EPPO — the joint prosecution service investigating offences against EU funds) is a natural complement to this backbone. The three proposals are tied together by a single principle: the condition serves the Hungarian people when it genuinely increases accountability — this is the translation into practice of the literature frame (accountability + independent oversight).

Part IV — Expected impacts and risks

Dimension Expected impact Risk
Economy Lasting, correction-free absorption of the HUF 6,000 billion envelope; improving investor and credit-rating assessment If the condition is met only on paper, a later EU correction endangers even the funds already won
Society Cleaner procurement, more predictable developments; the perceptible trust-building effect of public-money transparency The ‘we got the money’ over-communication obscures that meeting the conditions is the harder, longer task
Public administration The anti-corruption institutional system (independent office, EPPO, dashboard) can be built up as a lasting capacity With weak political will the new body remains a powerless ‘paper tiger’

The main dilemma is form versus substance. The government can quickly meet the conditions by transposing the statutory minimum, while the substantive institutional content — independent detection, real procurement competition — fails to follow. The proposal tips to the risk side if meeting the conditions becomes a purely legal-technical exercise: then the funds are formally absorbable, but the space for corruption remains unchanged, and the next EU review may block again. Conversely: substantive, institutionalised control is the fastest and safest path, because it removes the risk of suspension from the entire cycle.

Part V — Measurability and summary

5.1 What is worth tracking? (suggested KPIs)

MIAK proposes watching the following performance indicators (KPIs — numerical indicators from which, 6–24 months later, it can be seen whether the direction was right):

  • the share of single-bidder public procurements in procedures financed from the unfrozen funds (target: a lasting, measurable decline);
  • the completion rate of the committed milestones of the national anti-corruption strategy against the EU deadlines;
  • the establishment of an independent corruption-detection institution with real investigative powers and its annual case number;
  • the existence of the real-time public-money website and its update frequency;
  • the movement of Hungary’s control-of-corruption indicator (World Bank WGI) from the 2024 level of −0.17.

5.2 Summary

MIAK’s message is twofold. To the decision-maker: the unfreezing of funds is a real result, but the request is that the conditionality system be treated not as a nuisance but as the guarantee of lasting absorption — the transposition should be substantive, procurement transparent, detection independent. To the public: it is worth distinguishing between meeting the condition on paper and in substance, because blurring these is misleading. All this moves two MIAK foundational values. Transparency, because it was precisely the absence of public verifiability over the funds that originally blocked the cohesion envelope — the root of the problem is solved only by genuine publicity, not by a further announcement. And accountability, because public money serves the community only if the risk of abuse comes with real, independent detection — MIAK represents this not as an abstract principle but as the concrete tool of the independent office and procurement publication.

Part VI — Justifications and further sources

6.1 Press framing by spectrum

The topic appeared across the entire spectrum, but with differing emphasis. The left-liberal and public-affairs band (Telex, HVG, 24.hu) focused on the binding nature of the conditionality system and the fact of the commissioner’s visit — Telex highlighted the McGrath visit and the Hungarian receiving parties, and HVG that ‘joy abounds over the 16 billion euros obtained, but there are conditions’. The economic band (Portfolio) was the most precise on the mechanism: it separately analysed the content of the new anti-corruption directive, and with the image of ‘pulling the handbrake because of corruption’ it emphasised the binding nature of the condition. The pro-government/conservative band (Mandiner) on this day disputed the Brussels ‘warning’ and the assessment of Hungary’s economic situation, framing the conditionality system rather as political pressure. For MIAK it is precisely this spectrum picture that is instructive: the facts (how much money, on what condition) are common, the debate is about the interpretation of the conditions — which is why MIAK puts the substantive fulfilment of the condition at the centre, instead of the political framing.

6.2 Facts and data

  • The amount of the unfrozen envelope: EUR 16.4 billion (≈ HUF 6,000 billion), nearly 13 percent of Hungary’s budget. (Source: Telex, HVG, ATV, May–June 2026.)
  • The new EU anti-corruption directive entered into force on 1 June 2026: a uniform definition, minimum penalties and limitation periods, a mandatory national anti-corruption strategy. (Source: Portfolio, 1 June 2026.)
  • The rule-of-law commissioner Michael McGrath’s visit to Budapest: 2 June 2026. (Source: Telex, 2 June 2026.)
  • Hungary’s governance-quality indicators (World Bank WGI 2024): control of corruption −0.17, rule of law +0.35 — these are the starting point against which the conditionality system expects improvement.

6.3 Policy aspects

  • Foreign policy (programme points) — within issue-based EU coalition-building (KP17) and transparent foreign policy (KP3), a condition-fulfilling, constructive Hungarian position is the basis of the unfreezing of funds.
  • Transparency and anti-corruption policy (programme points) — procurement transparency (A2), the independent corruption-investigation office (A10), the public-money dashboard (A1) and international accountability (A14) provide the quality benchmark of meeting the conditions.
  • Economy (programme points) — the data-driven budget (G1) is the tool for tracking the use of the funds.

6.4 Literature in detail

6.4.1 Robert Klitgaard: Controlling Corruption

The core of Klitgaard’s analysis is that corruption is not a moral but a structural phenomenon: it arises where the official is in a monopoly position, has broad discretion, and no one holds them to account. Action against corruption is therefore not moralising but the transformation of the structure — increasing the probability of being held to account and narrowing discretion. Among the tools against corruption Klitgaard highlights the probability of exposing the agent’s acts and such a transformation of the organisational system ’that reduces the agent’s discretion’. The EU conditionality system works on exactly this logic: in the case of Hungarian fund use the condition increases accountability (the A factor of the formula), thereby reducing the structural space for corruption — not a punishment but the transformation of the risky structure.

📖 Source: Robert Klitgaard: Controlling Corruption

6.4.2 Susan Rose-Ackerman: Corruption and Government

Rose-Ackerman describes ‘grand corruption’ as a phenomenon taking place at the highest levels of government, through large projects and concessions: ‘governments often grant significant financial advantages to private companies through procurement contracts and the awarding of concessions’, and privatisation processes are particularly vulnerable to insider deals. For her the key to protection is ‘a credible, apolitical monitoring system that tracks down corrupt officials’. In the Hungarian context this underpins MIAK’s proposals 3.2 and 3.3: the cohesion funds were withheld precisely because of procurement and concession risks, so the centre of gravity of meeting the conditions should be procurement competition and independent detection — not the formal transposition of statutory text.

📖 Source: Susan Rose-Ackerman: Corruption and Government

6.5 International comparison

Anti-corruption condition-fulfilment is not a Hungarian peculiarity: the experience of several member states shows that the conditions attached to EU funds work when they receive institutional content. The Singaporean model also cited by Rose-Ackerman (the Corrupt Practices Investigation Bureau, CPIB) exemplifies that a politically independent detection body with real powers brings a measurable improvement in control of corruption over the long term. The EU anti-corruption directive generalises precisely this logic: the aim of the member states’ national strategies is that detection and prevention become institutionalised, rather than remaining campaign-like. Hungary — precisely because of the conditionality of the unfreezing of funds — must set the bar higher than the EU average in transparency, so that the unfrozen funds do not again come into correction risk.

Foreign policy

  • KP17 — Issue-based coalition-building in the EU
  • KP3 — Transparent foreign policy

Transparency and anti-corruption policy

  • A2 — Procurement transparency
  • A10 — Independent Corruption-Investigation Office (CPIB model)
  • A1 — Public-money dashboard
  • A14 — International institutional participation and accountability

Economy

  • G1 — Data-driven budget

6.7 Source register

Press sources (MIAK press monitor, 2 June 2026 — topic 2):

Knowledge-base references (literature):

  • 📖 Robert Klitgaard: Controlling Corruption
  • 📖 Susan Rose-Ackerman: Corruption and Government

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

MIAK internal materials:

  • MIAK policy area: Foreign policy (programme points; programme point ID: KP17)
  • MIAK policy area: Transparency and anti-corruption policy (programme points; programme point ID: A2)
  • MIAK policy area: Economy (programme points; programme point ID: G1)
  • MIAK press monitor, 2 June 2026 — topic 2, score: 88/100

Additional public data sources:

  • European Commission RRF Scoreboard; the EU anti-corruption directive (2026); World Bank Worldwide Governance Indicators (WGI) 2024; European Public Prosecutor’s Office (EPPO) annual reports.

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