Part I — Situation overview

At the end of August 2026 European gas storage facilities stand at the lowest level in two decades. According to Euractiv’s report of 21 August 2026, available in full text, the average EU filling rate is around 62 per cent, which falls 15 percentage points (pp) short of the ten-year average. German underground storage facilities — the largest in Europe — stand at 50 per cent; Sebastian Heinermann, head of the Ines storage association, called this a “historic low” and the lowest level ever measured at this time of year, speaking to the German news agency. In parallel the Dutch TTF — the benchmark exchange price of continental gas trading — rose to 65 euros per megawatt hour on Thursday 20 August, a multi-year high. The two figures arrived together in the last refill weeks before the heating season.

The expert and official assessment nevertheless does not follow the 2022 analogy. According to the background material intended for the press by the German ministry of economic affairs, dated 20 August, no gas shortage is expected. Kerstin Andreae, head of the German energy industry association (BDEW), holds that the situation is not comparable with earlier years, and particularly not with the crisis year of 2022; Ben McWilliams, analyst at the Brussels think tank Bruegel, considers that there is at present no cause for excessive concern. The physical basis of the argument rests on three factors. The first is import capability: since 2021 Europe has increased the import capacity able to receive liquefied natural gas (LNG — liquefied natural gas: cooled natural gas transported by ship) by 76 billion cubic metres, to a total of 242 billion cubic metres, and has thereby become the world’s largest LNG buyer. The second is unused reserve: according to Bruegel’s estimate Germany and Belgium used only 40 per cent of this capacity in May and June. The third is the structural fall in demand — according to McWilliams European gas demand is today 15 per cent lower than it was in 2021, because of the spread of heat pumps, building insulation and non-gas-based industrial solutions; solar and wind energy increasingly crowd gas power plants out of electricity generation, while French nuclear output — unlike in 2022 — remains stable.

The Hungarian situation differs from this picture at three points. Hungary has no seaport, so it has access to the above import reserve only indirectly, through the terminals of other member states. At the same time the EU gas storage regulation prescribes a mandatory filling target for Hungary too by the start of the heating season — that is, the remaining refill is compulsory and takes place at the present, multi-year-high price. Finally, the channel of Hungarian gas price risk is today not primarily the politics of the eastern pipeline system but the global LNG market: a lasting closure of the Strait of Hormuz — through which roughly one fifth of the world’s liquefied gas traffic passes — together with the Asian winter peak could cause strong short-term price fluctuation.

MIAK’s reading of this runs out into a single proposition: the present situation is not a question of supply but of pricing and planning — and the pricing decision is being taken now, in August, not in January. If the remaining quantity needed to reach the mandatory storage target has to be bought at the current peak price, then the budgetary burden of household price regulation and of strategic stockholding is already being locked in this summer. This is not a question of communication but a calculation — the result of which is not public today.

Part II — Foundations in the literature

The interpretative framework of the situation comes together in three sources. The most recent edition of the OECD Economic Outlook expressly models the present energy price shock of Hormuz origin: it records that disrupted shipping and the loss of energy facilities have simultaneously raised energy prices and disturbed the supply of other important commodities — fertiliser, for instance — and it gives a numerical path for how much growth slows and how much inflation rises as a result. The 2025 edition of the International Monetary Fund (IMF) World Economic Outlook looks at this risk from the side of fiscal space: according to its analysis commodity price surges hit hardest precisely those commodity-importing countries whose fiscal space is narrow, because they have nothing with which to cushion the effect. And This Time is Different, the work of Carmen Reinhart and Kenneth Rogoff (Harvard economists, researchers who have processed eight centuries of the history of financial crises), gives a methodological warning: arguments of the “this time is different” type have historically gained strength precisely in periods when risk was becoming underpriced — this does not mean that today’s expert assessment is wrong, but that decision planning must not be built exclusively on this one scenario. The detailed treatment of the literature — source by source, with quotations — can be found in section 6.4 Literature in detail.

📖 Source: OECD: Economic Outlook; IMF: World Economic Outlook (2025); Carmen Reinhart — Kenneth Rogoff: This Time is Different — A Panoramic View of Eight Centuries of Financial Crises

Part III — MIAK’s concrete proposal

MIAK proposes three measurable measures. All three start from the fact that the question of winter supply is today not a physical one but a matter of pricing and measurement.

3.1 A public advance calculation of the remaining refill — broken down by quantity and price (before the close of the 2027 budget negotiation)

MIAK asks that the government publish the quantity and pricing advance calculation of the storage refill remaining until the start of the heating season: how much gas is still missing from the mandatory filling target, at what price its procurement is expected, and what the aggregate quantity and average price of the already booked, hedged (pre-fixed price) positions is. The breakdown of the publication is simple: quantity × expected average price, scenario by scenario, together with the ratio of the hedged and the unhedged part. The data does not require the details of individual commercial transactions to be made public — market-sensitive items are interpretable in aggregate too, and this practice works in several member states. The argument is strictly one of planning: the pricing of the remaining refill simultaneously determines the budgetary burden of household price regulation, the expenditure on strategic stockholding and the energy cost falling on industry, so if this data becomes known after the close of the budget negotiation, then the following year’s budget will be settling after the fact the consequences of a decision already taken but not priced in. The proposal is the joint application of the G1 data-driven budget and the G25 energy price shock preparedness programme points. A clarification of competences: household energy price regulation lives at the level of government decree, whereas the content of the EU storage obligation is determined by an EU legal act — the Hungarian legislator cannot shape the latter, only the manner of compliance and its budgetary handling.

3.2 A new energy security indicator: booked seaborne terminal capacity, with duration and price (first publication by the first quarter of 2027)

The second proposal replaces the indicator itself. The domestic gas storage filling percentage is the most frequently cited energy security figure of recent years, while the present European situation shows precisely that this is not the decisive factor: what protects Europe from shortage is not the high storage level but the unused import capacity. Since Hungary has no seaport, the measure of Hungarian supply flexibility is how much Croatian (Krk) and Greek terminal capacity the country has booked, at what price and for what duration. MIAK asks that this data — in aggregate, on the basis of auction results and capacity booking contracts, quarterly — become a regularly published indicator, and that it be the official measure of the K7 energy market shock resilience programme point in place of the storage percentage. The indicator should consist of three parts: booked capacity in annual quantity, the weighted average price of the booking, and the remaining average duration of the bookings. The yield is twofold: on the one hand it makes visible whether the country’s supply depends on a single route or on several parallel ones, and on the other it makes Hungary comparable with the other landlocked member states of the region — the Slovak, Czech and Austrian booking data come from these same auction results.

3.3 A pre-fixed price threshold for switching on industrial energy cost relief (simultaneously with the 2027 budget)

The third proposal concerns the manner of crisis management. The practice of recent years has been that the government responded to an energy price surge after the fact, by an individual decision: when industrial energy costs already hurt, a rescue package was born, with varying conditions. MIAK asks that the legislator fix in advance at what lasting breach of what TTF price level, to what extent and for what period industrial energy cost relief switches on automatically, and below what price level it switches off. The rule should contain three elements: the threshold value (for instance the breach of a given euro per megawatt hour level over a specified number of days), the formula for the extent of the support, and the sunset date — that is, the point in time fixed in legislation at which the measure automatically ceases if the legislator does not amend it beforehand. This is the energy market application of the G15 counter-cyclical fiscal stabiliser programme point. The argument is not theoretical: a rule fixed in advance is cheaper, because the enterprise can plan with it in advance and therefore does not have to price in the uncertainty; and it is cleaner, because the award of an individual rescue package is a matter of discretion, which always carries a risk from the point of view of the public money transparency under A1.

The three proposals are held together by a single principle: expert assessment should be an input, not a risk management strategy. According to today’s consensus there will be no shortage, and this assessment rests on good data — but the Reinhart–Rogoff warning (see 6.4.3) applies precisely to such situations: the quality of preparation is measured not by the baseline scenario but by the handling of the extreme case. None of the three proposals assumes that the experts are wrong; all three concern what can be fixed in advance, publicly, for the case in which the unexpected scenario occurs. At EU level the same logic is the content of the issue-based coalition building under KP17: the landlocked member states have a common interest in strengthening access to terminal capacity and joint procurement coordination, and on this question Hungary has natural allies.

Part IV — Expected effects and risks

Dimension Expected effect Risk
Budget The price of the remaining refill is known before the budget negotiation, so it is an item that can be planned in rather than settled after the fact Publishing the advance calculation is also a market signal: if the data is too detailed, it may worsen the procurement bargaining position
Energy security Booked terminal capacity as an indicator measures real supply flexibility, not a stock percentage that is misleading on its own Introducing the indicator may in the short term give an unfavourable picture if it turns out that booking is concentrated on a single route
Industry The pre-fixed price threshold makes the upper limit of energy costs predictable, which helps investment decisions If the threshold is too low, automatic support switches on even when the market would correct by itself
Foreign policy Joint advocacy with the landlocked member states acquires a concrete, technical subject Joint procurement coordination is slower than bilateral bargaining and less flexible in the short term
Household prices Pricing becomes more transparent and the burden of regulation foreseeable A public price advance calculation does not in itself reduce the price; if communication promises this, it leads to a loss of trust

The main question for deliberation lies in the tension between data publicity and the procurement bargaining position. The more detailed the published advance calculation, the more precisely the market sees how large a quantity the country has to buy and by when — which in principle may worsen the price obtainable. The practical solution is aggregation and delay: quantity and average price in aggregate, while the concrete transactions become public afterwards, with a delay fixed in advance. This is the same structure as that applied by several member state energy regulators. The proposal tips over to the risk side if the price threshold rule comes into being but the associated sunset date does not: an automatic support without a deadline becomes just as lasting a budgetary obligation as discretionary rescue packages, only in a less visible way. There is a measure of ideology-free conduct here too: the public advance calculation now proposed makes the present government’s own procurement decisions verifiable first of all, and that is what gives it its credibility.

Part V — Measurability and summary

5.1 What is worth following? (proposed KPIs)

The performance indicators below (KPIs, Key Performance Indicators) will show in 12 and 24 months whether energy security planning has genuinely become data-based. These are proposed benchmarks, not government commitments.

  • The advance calculation of the remaining refill: whether the missing quantity and the estimated average price appear publicly, still before the close of the 2027 budget negotiation.
  • The hedging ratio: what percentage of the gas quantity needed for the heating season is booked at a pre-fixed price — it is worth following how this ratio develops from year to year.
  • Booked seaborne terminal capacity: whether by the first quarter of 2027 the annual capacity booked at the Croatian and Greek terminals, the weighted average price and the remaining duration are published.
  • Route concentration: what percentage of the booked capacity is concentrated on a single terminal — this is the simplest indicator of diversification.
  • The existence of the price threshold rule: whether the threshold value, the formula and the sunset date of automatic industrial energy cost relief get into the 2027 legislative package.

5.2 Summary

MIAK’s request to the decision-maker is three steps. Before the close of the 2027 budget negotiation the quantity and pricing advance calculation of the remaining storage refill should be public, together with the aggregate data on hedged positions. The Hungarian energy security indicator should be booked seaborne terminal capacity instead of the domestic storage percentage — with quantity, price and duration, published quarterly. And it should be fixed in advance at what price level industrial energy cost relief switches on and off. And to the public, one request as to outlook: the news that “storage is at a two-decade low” is not in itself bad news, nor good — the question is how much it costs to fill it, and where we can obtain gas from if the usual route is blocked.

Two MIAK foundational values are directly in play here. Data-drivenness, because all three proposals fill the same gap: today public discourse on Hungarian energy security is built on a single, misleading indicator — storage filling — while the data measuring real flexibility is not public. And accountability, because the pre-fixed price threshold and the public advance calculation together make it verifiable after the fact whether procurement and support decisions were made according to the fixed rule — with discretionary, ex post packages this question cannot even be put.

Part VI — Justifications and further sources

6.1 The framing of the press, spectrum by spectrum

The Brussels professional press carried the topic in a fact-reporting, counterpointing structure. Euractiv’s piece placed the claim in the headline itself: storage levels at a historic low do not mean a supply crisis. The structure of the article follows this as well — first the alarming data (a 62 per cent European average, a 50 per cent German level, 65 euros/MWh), then the official and analyst counterarguments (the German ministry’s background material, the statements by BDEW and Bruegel), and finally the structural explanation (increased import capacity, reduced demand, stable French nuclear output). This framing is deliberately panic-dissolving and its factual basis is strong; its single shortcoming is that it does not discuss separately the different situation of the landlocked member states.

The global news band framed the same story from the side of geopolitical risk. Al Jazeera’s live coverage followed the escalation around the Strait of Hormuz, and in this framing the gas price is not a European stockholding question but a Middle Eastern security one. The two narratives do not contradict each other, but they lead to different decision conclusions: from one it follows that there is nothing to be done, from the other that the main risk lies not in storage but on the transport route. In MIAK’s reading both framings are incomplete on their own — European structural protection is real, but Hungarian access to that protection is not automatic.

The EU budget band carries a third thread: in a separate piece Euractiv reported that the Commission has published the list of energy projects eligible for budget flexibility relief. This thread is directly connected with the present topic — the financing of refilling and of terminal capacity development may in part run through this channel as well — but in the press the two stories live separately. In the Hungarian press this international debate did not appear as an independent topic today; the domestic energy policy focus was on the water level of the Danube and the operation of Paks.

6.2 Facts and data

Data Value Source
European average storage filling around 62 per cent Euractiv, 21 August 2026
Divergence from the ten-year average −15 percentage points Euractiv, 21 August 2026
The classification of the level the lowest end-of-August value in two decades Euractiv, 21 August 2026
German storage filling 50 per cent Euractiv / Ines, 21 August 2026
TTF quotation on 20 August 2026 65 euros/MWh (multi-year high) Euractiv, 21 August 2026
Date of the German economics ministry background material 20 August 2026 Euractiv, 21 August 2026
Growth in European LNG import capacity since 2021 +76 billion cubic metres Euractiv, 21 August 2026
Total European LNG import capacity 242 billion cubic metres Euractiv, 21 August 2026
German and Belgian LNG capacity utilisation in May–June 40 per cent Bruegel (after Euractiv)
Change in European gas demand compared with 2021 −15 per cent (structural) Ben McWilliams, Bruegel (after Euractiv)
Share of global LNG traffic passing through the Strait of Hormuz roughly one fifth Energy Flux (after the foreign press monitor)
Euro area growth forecast for 2026 0.8 per cent, with higher energy prices OECD: Economic Outlook
G20 inflation forecast for 2026 4.0 per cent (1.2 percentage points above the earlier expectation) OECD: Economic Outlook

Two rows of the table together yield the non-obvious conclusion of this post. The 40 per cent utilisation of the capacity of the German and Belgian terminals means that there is a significant reserve in the European system — but this reserve is physically located on the seacoast. For Hungary this reserve exists only in so far as a capacity booking contract ties it to the country. The 62 per cent European stock level is therefore not directly relevant Hungarian data; the relevant data is how many cubic metres of import capacity the Hungarian system has access to on a contractual basis — and this figure does not today feature among the regularly published energy security indicators.

6.3 Policy dimensions

  • Economy (programme points) — preparation for an energy price shock, data-driven budget planning and the rule-based stabiliser: G25, G1, G15;
  • Environment and climate (programme points) — the indicator of energy market shock resilience and the planning of the energy transition: K7, K2;
  • Foreign policy (programme points) — joint advocacy with the landlocked member states on terminal access and joint procurement: KP17;
  • Transparency and anti-corruption policy (programme points) — putting support decisions on a rule-based footing: A1.

6.4 Literature in detail

6.4.1 OECD: Economic Outlook

The OECD’s most recent report on economic prospects deals expressly with the energy price shock that forms the background of the present situation. The report names disrupted shipping at Hormuz and the loss of energy facilities as the triggering cause, and derives the growth and inflation path from this.

“The conflict in the Middle East entails human and economic costs for the countries directly affected and is testing the resilience of the world economy. The halting of shipments through the Strait of Hormuz, and the closure or damaging of energy infrastructure, have sent energy prices surging and disrupted the global supply of energy and of other important commodities, such as fertilisers.”

The report adds that the extent and duration of the conflict are highly uncertain, but that the lasting persistence of higher energy prices perceptibly raises corporate costs and consumer prices, which worsens growth prospects. According to the numerical path, euro area growth moderates to 0.8 per cent in 2026, precisely because of higher energy prices, while inflation in the G20 countries may reach 4.0 per cent, 1.2 percentage points above the earlier expectation. Applied to the Hungarian situation, this gives proposal 3.1 its urgency: if the outlook reckons with lastingly high energy prices, then the pricing of refilling is not a one-off but a budget item recurring over several years.

📖 Source: OECD: Economic Outlook

6.4.2 IMF: World Economic Outlook (2025)

The IMF’s outlook report treats a commodity price surge as an independent, named risk, and — what is most important from the point of view of the present Hungarian situation — ties the weight of the risk to fiscal space.

“Commodity prices surge again on the back of climate shocks, regional conflicts, or broader geopolitical tensions. […] Commodity-importing countries are particularly exposed to rising inflationary pressures amid limited fiscal space.”

The report also warns in the same place that pressure on the independence of key economic institutions — central banks among them — may undermine hard-won policy credibility and may also worsen the reliability of data. The linking of the two thoughts gives the macroeconomic basis of MIAK’s argument: for a commodity-importing country with narrow fiscal space, the cheapest instrument for handling a price surge is not ex post spending but a rule fixed in advance and reliable data — precisely the content of proposals 3.1 and 3.3.

📖 Source: IMF: World Economic Outlook (2025)

6.4.3 Carmen Reinhart — Kenneth Rogoff: This Time is Different

The central claim of Reinhart and Rogoff’s work, which processes eight centuries of financial crises, is the description of a recurring pattern of thinking. The authors show that major crises are usually separated from one another by longer quiet periods, and that these periods create in decision-makers and investors the impression that the old rules no longer apply.

“Major default events tend to be separated by years, if not decades, creating an illusion among policy makers and investors that ’this time is different’.”

It is important to specify what this reference does not claim. The authors do not say that expert assessment formulated in quiet periods is wrong — today’s European gas market analysis rests on a strong factual basis, and the structural arguments (increased import capacity, reduced demand) are verifiable. What the volume says is methodological: preparation must not be sized exclusively for the baseline scenario, because it is precisely in quiet periods that the inclination to rule out the extreme case is strongest. Applied to the Hungarian situation this means that the “there will be no shortage” assessment can and indeed should be accepted as a planning basis — but alongside it, it must be fixed in advance what happens if the conjunction does occur after all: a lastingly cold winter, further unplanned LNG outages and weak renewable output at the same time. That fixing is the price threshold rule under proposal 3.3.

📖 Source: Carmen Reinhart — Kenneth Rogoff: This Time is Different — A Panoramic View of Eight Centuries of Financial Crises

6.5 International comparison

The energy security practice of the landlocked member states offers several usable patterns. The Czech Republic and Slovakia both secure their flexibility through capacity bookings tied to the German and to the Croatian and Polish terminals, and the Slovak regulator publishes the booking data in aggregate form — precisely the indicator that proposal 3.2 proposes for Hungary as well. Austria ties the strategic storage obligation to a multi-year, pre-announced refill schedule, which spreads the pricing risk over time instead of concentrating it at the late-summer peak.

The capacity booking auctions of the Krk terminal are the region’s common access point, and the auction results are public — that is, no new data collection needs to be started in order to assemble the data under proposal 3.2; the existing, public auction results merely have to be aggregated and published regularly. A model for automatic, threshold-linked industrial energy cost relief also exists: after 2022 several member states applied compensation according to a pre-announced formula, narrowed to energy-intensive sectors, which they phased out when the sunset date expired. The lesson from these cases is consistent: the rule-based solution worked when the date of phasing out was fixed simultaneously with the introduction.

Economy

  • G1 — Data-driven budget
  • G15 — Counter-cyclical fiscal stabiliser
  • G25 — Energy price shock preparedness plan

Environment and climate

  • K2 — Energy transition plan
  • K7 — Energy market shock resilience

Foreign policy

  • KP17 — Issue-based coalition building in the EU

Transparency and anti-corruption policy

  • A1 — Public money dashboard

Proposed new programme point: Terminal-capacity-based energy security indicator — for the Environment and climate policy area: the regularly published Hungarian energy security measure should be, instead of domestic storage filling, the quantity, weighted average price and remaining duration of booked seaborne regasification capacity.

6.7 List of sources

Press sources (MIAK foreign press monitor, 22 August 2026 — topic 1):

Knowledge base references (literature):

  • 📖 OECD: Economic Outlook
  • 📖 IMF: World Economic Outlook (2025)
  • 📖 Carmen Reinhart — Kenneth Rogoff: This Time is Different — A Panoramic View of Eight Centuries of Financial Crises

MIAK internal materials:

  • MIAK policy area: Economy (programme points and background material; programme point ID: G25)
  • MIAK policy area: Environment and climate (programme points and data sources; programme point ID: K7)
  • MIAK policy area: Foreign policy (programme points; programme point ID: KP17)
  • MIAK foreign press monitor, 22 August 2026 — topic 1, score: 90/100

Supplementary public data sources:

  • GIE AGSI+ — daily gas storage stock data by country
  • ENTSOG — transmission capacity and physical flow data
  • ICE Endex — TTF forward price quotations
  • MEKH (Hungarian Energy and Public Utility Regulatory Authority) — monthly gas and electricity market reports
  • LNG Hrvatska (Krk) — capacity booking auction results
  • Bruegel — European natural gas market datasets

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