Part I — Situation overview

On 23 July 2026 the Ministry for Agriculture and the Food Economy (AÉM) withdrew the EU support granted to Gallicoop Zrt. and excluded the company from the call which it had won at the beginning of March. According to the communiqué the National Managing Authority of the Strategic Plan of the Common Agricultural Policy (CAP) withdrew from the grant instruments because, under Act CXCV of 2011 on public finances, the support may be given exclusively to a legal person qualifying as a transparent organisation — that is, one whose ownership structure and beneficial owner can both be established. Gallicoop’s owners are private equity funds, in which the identity of the beneficial owner cannot be established. According to the ministry’s answer to HVG’s question the company won a total of HUF 33 billion with two projects; this is more than six times the amount granted to the enterprises that won the other processing plant calls in due order. On 25 August 2026 the company announced that it is challenging the decision by legal means and will make use of every remedy available to it.

The prior history of the call is at least as essential as the withdrawal. According to the compilation by Telex’s G7 column, the Ministry of Agriculture launched the “Champions of the Food Industry Programme” in August 2023, and the government called upon the agriculture minister by resolution to designate the enterprises participating in the programme. It emerged from a government resolution of late 2024 that Gallicoop had been designated a participant, and that the minister had been instructed to examine the possibility of investment support from the CAP Strategic Plan. According to the ministry’s statement today, Gallicoop was the only winner of the call, and according to agriculture minister Szabolcs Bóna’s Tuesday social media post it was also its only participant. G7 also recorded that no public list of the designated companies could be found, and that it was likewise not transparent on the basis of what criteria an enterprise got into the programme. On the basis of the 2025 figures Gallicoop is a stable, export-capable large enterprise: its consolidated net revenue was HUF 87.2 billion, of which HUF 34.4 billion was export; revenue under the non-consolidated accounts was HUF 53 billion and after-tax profit HUF 5.4 billion. The company employs close to 1,600 people, and paid no dividend either in 2024 or in 2025.

The decision is not an isolated one. Portfolio recalled that at the beginning of August the board of the Hungarian Development Bank excluded OPUS TITÁSZ Áramhálózati Zrt. from calls financed from the EU recovery fund, likewise invoking transparency requirements, and that on the same day the recovery of HUF 126 billion of public money was announced through the early redemption of Duna Aszfalt’s bonds. This is therefore the first large case in a series of asset recovery measures to enter the judicial phase. MIAK’s reading: the transparency test is in itself a strong and party-neutral legal basis — precisely because it is not about the person of the owner but about whether the ownership chain can be established. The risk lies not in the legal basis but in the selectivity of its application: if the same ground for exclusion is applied to only one beneficiary, then even a lawful decision will be recorded as a political act — and it will have to be defended as such before the court as well.

Part II — Foundations in the literature

Three volumes describe why the procedure and not the legal basis is what is really at stake in this topic. In her work Corruption and Government Susan Rose-Ackerman (American lawyer-economist, one of the founding authors of corruption research) shows that a vague eligibility standard interpreted case by case is the most dangerous institutional construction: alongside it the authority can in practice deny the service to anyone, and the person concerned cannot prove that they have been treated unfairly. The formula C = M + D − A in Controlling Corruption by Robert Klitgaard (American economist, a classic author of the institutional analysis of corruption) — corruption is the sum of monopoly and discretion, less accountability — can be read here in the reverse direction as well: the power to withdraw support is in itself monopoly plus discretion, so its legitimacy can be built up solely from the side of accountability. And Why Nations Fail by Daron Acemoglu and James A. Robinson (economists, leading authors of institutional economics; awarded the Nobel Memorial Prize in Economics in 2024) supplies the distinction which is the yardstick for judging today’s case: the rule of law is not the same as rule by law, because the essence of the former is that rules cannot be applied selectively or arbitrarily. The detailed treatment of the literature — 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. None of them is about whether the concrete withdrawal was right or wrong — that will be decided by the court, and rightly so. The proposals are aimed at ensuring that the review programme as a whole stands up to legal scrutiny and to scrutiny before the public.

3.1 A single review list and a transparency criteria system published in advance (within 30 days)

The AÉM and the other support-managing bodies should publish the full list of those pending and already granted supports to which the public finances act’s requirement of a transparent organisation applies, and should indicate which is under review, which has been closed, and with what result. Alongside the list, the criteria system determining the order and the yardstick of the review should also be published — for example, a support amount threshold, the type of ownership structure, the number of competitors in the application procedure. The aim is not speed but simultaneity: every case to be examined on the same legal basis should be judged by the same yardstick and in the same procedural order. This is the procedural supplement to the clawback element of the A8 cohesion accountability programme point: the programme point itself already prescribes a public project-level data sheet, and this now has to be extended to review decisions as well. In Klitgaard’s frame (see 6.4.2) this is precisely the narrowing of D, of discretion — not the removal of the competence, but its binding to a rule.

3.2 Publication of the full reasoning of withdrawal decisions, with business secrets redacted (simultaneously with the decision)

The full reasoning of the decision on withdrawing support — with the legal basis indicated, the established facts and a list of the evidence — should be made public simultaneously with the decision, with those parts affecting genuine business secrets redacted. Present practice is considerably less than this: the ministry’s position can be reconstructed from an answer to a press question and from a social media post, and the ministry did not comment to G7’s question on the reasoning of the decision of 23 July. This difference is not a formality. According to Article XXIV of the Fundamental Law of Hungary everyone has the right to have their affairs handled by the authorities impartially, fairly and within a reasonable time; and the practical content of the right to fair procedure is precisely the knowability of the reasoning. The publicity of the reasoning is at the same time the strongest protection against the charge of selectivity: if the public sees that identical reasoning was produced in two similar cases, the charge of political motivation becomes unfounded. The proposal stands at the intersection of the A1 public money dashboard and the I3 legislative impact assessment programme points.

3.3 Machine-readable publication of CAP beneficiary data by the start of the 2027 application cycle

The beneficiary data of CAP support — beneficiary, amount, legal title, project aim, deadline for performance, the transparency classification of the beneficial owner — should be placed on a single, searchable and downloadable, machine-readable platform. In the present situation not even a public list of the designated participants of the “Champions of the Food Industry Programme” was available, and the criteria of designation could not be established either — this is the gap because of which the debate today revolves around a single case, instead of the programme as a whole being transparent. The proposal is the direct implementation of the MG2 agricultural data platform programme point: the programme point set the target that by 2026 100 per cent of CAP support should be available in searchable and downloadable format instead of the present publication in PDF lists. Danish practice shows what this gives: there the agricultural support data are fully public, and the press regularly analyses the list of the largest beneficiaries — publicity is thus continuous, rather than tied to a change of government.

The three proposals are linked by a single principle: the credibility of asset recovery depends not on from whom support is withdrawn, but on whether the yardstick of withdrawal is known in advance, is the same for everyone, and can be verified afterwards. On Rose-Ackerman’s argument (see 6.4.1) an uncertain yardstick is not neutral: it always favours whoever applies the yardstick. This is as true in the case of the present government as it was in the case of the previous one.

Part IV — Expected effects and risks

Dimension Expected effect Risk
Economy A single criterion published in advance reduces investment uncertainty: enterprises know in advance what ownership structure excludes them from public money If the review drags on, investments under way come to a halt; in the Gallicoop case close to 1,600 employees and the domestic supplier base are affected as well
Society Linking public money to the beneficial owner is the strongest anti-corruption instrument, one aimed not at a person but at a structure The case can be framed as “politics of revenge” if it is applied to only one beneficiary — and this framing carries away the legitimacy of the lawful decision too
Public administration A documented, uniform procedure gives the support-managing body a position that can also be defended in judicial review Reviewing cases with the same legal basis simultaneously requires substantial administrative capacity; in the event of a capacity shortage the programme is left half-finished

The main trade-off is between speed and uniformity. In an asset recovery process after a change of government a fast, spectacular first step is politically understandable — but legally it is precisely speed that is the greatest risk, because singling out an individual case is the hardest to defend before a court. The A8 programme point itself warns of this from the other direction: excessively strict accountability may come at the expense of absorption capacity, because if project owners fear sanctions they would rather not apply, and the funding remains unused. In the present case this appears in concrete form: a significant part of the investments of the Hungarian food industry is realised from support funding, and if the yardstick of the revocability of granted support is unpredictable, the propensity to invest falls among lawfully acting enterprises as well. The proposal tips to the risk side if the review list is never drawn up and the programme continues as a series of individual cases: the strength of the legal basis is then lost, and every single decision becomes a separate political debate.

Part V — Measurability and summary

5.1 What is worth following? (proposed KPIs)

MIAK proposes the following performance indicators (KPIs) for monitoring. These are proposals, not government commitments — they serve to make the uniformity of the review programme judgeable in 6, 12 and 24 months.

  • Review coverage: what percentage of the support cases to be examined on the transparency legal basis have undergone a formal review — proposed target 100% within 12 months, with a quarterly public status report.
  • Publicity of reasoning: in what percentage of withdrawal decisions the redacted full reasoning appeared simultaneously with the decision — proposed target 100% from the next decision.
  • Performance before the courts: how many of the challenged withdrawal decisions remained in force with final effect — this is the ultimate yardstick of the legal quality of the programme; proposed monitoring horizon 24 months.
  • Data publicity: what percentage of CAP support data is available in machine-readable, downloadable format — the target value of the MG2 programme point is 100%.

5.2 Summary

MIAK’s key message: the transparency test is a good legal basis, but it works only if it is not applied in a single case. We ask the decision-maker to publish within 30 days the full list of support cases to be reviewed on the same legal basis together with the criteria system of the review, to issue the redacted full reasoning simultaneously with every withdrawal decision, and to create the machine-readable register of CAP beneficiary data by the start of the 2027 application cycle. And we ask the public not to look at the question from the direction of the person of the beneficiary: what matters is whether the yardstick is the same for everyone.

Of MIAK’s foundational values two are in play here. Being ideology-free, because in this case it is easiest of all to turn the policy question into a choice of political side — whereas the transparency requirement is valuable precisely because it examines not the political attachment of the owner but the knowability of the ownership chain; this yardstick will in future be applicable to any beneficiary of any government. And accountability, because a withdrawal decision is in itself an exercise of power: in a monopoly position, with discretion. According to Klitgaard’s formula such a construction is made legitimate solely by strengthening the accountability side — that is, public reasoning is not a weakening of the decision but the only thing that protects the decision in the long run.

Part VI — Justifications and further sources

6.1 The framing of the press, spectrum by spectrum

The liberal-left and public affairs band used two complementary frames. Of HVG’s two pieces, one carried the company side (“Mészáros’s turkey plant is going to court after the new government withdrew the EU support from them”) and lifted the employment argument from the company’s communiqué into the headline; the other carried the ministry’s reply and made the legal basis — the transparency problem of the private equity fund ownership structure — the axis of the article. 444.hu carried the news with a factual headline. Telex processed the case on two different levels on the same day: one article reconstructed the ministerial reasoning, while the material of the G7 column dug up the prior history of the programme — the launch in 2023, the government resolution of late 2024, and the fact that no public list of the designated companies could be found. This is the only treatment in the spectrum that presents today’s decision not as an event but as the consequence of a programme that was opaque from the start.

The economic band strengthened the dimensions of legal remedy and of context. Portfolio broke the day into two articles: one set out the company’s announcement of litigation and the employment argument, the other the agriculture minister’s reasoning on social media — namely the claim that the call had a single participant, and that the amount granted is more than six times that of the enterprises which won in due order. Portfolio also placed the case within the series of asset recovery measures, recalling the exclusion of OPUS TITÁSZ at the beginning of August and the redemption of the Duna Aszfalt bonds. 24.hu carried the announcement of the legal steps in short, factual form.

The pro-government and conservative band on this day framed not the concrete case but the general question of EU funds. Magyar Nemzet’s article “EU funds may land at foreign companies” raises the thesis that the obligations undertaken behind the EU funds brought home are not known, and that the funding may go to foreign enterprises. This is a verifiable claim, one that would be answered by the publicity of CAP and cohesion beneficiary data — the same publicity that MIAK proposes in the MG2 programme point. It is worth recording: the conservative band here does not dispute the lawfulness of the decision but emphasises the national aspect of the use of funds — in substance this is a different question, but answering it would require exactly the same data platform.

6.2 Facts and data

Fact Value Source
Amount of the withdrawn support HUF 33 billion (two projects) Information from the AÉM, 25 August 2026
Date of the granting of the support 4 March 2026 Gallicoop’s communiqué
Date of the withdrawal 23 July 2026 Gallicoop’s communiqué, AÉM
Legal basis Act CXCV of 2011 — requirement of a transparent organisation Information from the AÉM
Ratio to the winners in due order more than sixfold AÉM, statement of agriculture minister Szabolcs Bóna
Number of participants in the call 1 (Gallicoop) statement of the agriculture minister, 25 August 2026
Launch of the programme August 2023 compilation by Telex G7
Gallicoop consolidated net revenue (2025) HUF 87.2 billion, of which HUF 34.4 billion export Telex G7
Gallicoop after-tax profit (2025) HUF 5.4 billion Telex G7
Employees close to 1,600 Gallicoop’s communiqué
Related case exclusion of OPUS TITÁSZ from the recovery fund, beginning of August 2026 Portfolio

One methodological remark is warranted on the figures: two differing revenue figures for the same year appeared in the press. Consolidated net revenue is HUF 87.2 billion, revenue under the non-consolidated accounts HUF 53 billion — the difference arises from the difference in the scope of consolidation, and is not a contradiction. MIAK gives both figures tied to their source.

6.3 Policy dimensions

  • Transparency and anti-corruption policy (programme points) — the project-level register of EU funds, the procedure of the clawback mechanism and the publicity of the use of public money (programme point ID: A8, A1, A2);
  • Agriculture (programme points) — machine-readable publication of CAP beneficiary data and anomaly screening (programme point ID: MG2);
  • Justice (programme points) — protection of property rights and legislative impact assessment: the predictability of the route of legal remedy against a withdrawal (programme point ID: I5, I3);
  • Economy (background material) — the predictability of support policy as a factor of the investment environment.

6.4 Literature in detail

6.4.1 Susan Rose-Ackerman: Corruption and Government

The central methodological claim of Rose-Ackerman’s volume is that corruption is not primarily a moral but an incentive question: it appears where the official has discretion and the client has no alternative. One of the book’s most precise observations concerns the fact that a vague eligibility standard is not an accidental shortcoming but a working instrument: alongside it the authority can deny the service to anyone, and the person concerned cannot prove that they have been treated unfairly.

“Another strategy is to maintain vague and uncertain qualification standards. Then officials can withhold services from anyone who does not make a payoff, but it will be difficult for anyone to prove that they have been unfairly treated.” (Susan Rose-Ackerman: Corruption and Government)

In another chapter of the volume, directly relevant to the present case, the author analyses what happens if an enterprise fears that its contract may be invalidated for political reasons: the investor switches to a short-term outlook, avoids immobile capital goods that are hard to extract, and its investment horizon shortens. In the Gallicoop case both mechanisms can be observed, only from opposite directions. The designation procedure — without a public list and without knowable criteria — is precisely the vague yardstick Rose-Ackerman writes about; and the present withdrawal, if it remains an isolated one, strengthens precisely the perception that contracts can be politically invalidated. MIAK’s proposal therefore argues not against the withdrawal but for a single list: the same instrument that now remedies the vagueness of the yardstick can tomorrow also create predictability.

📖 Source: Susan Rose-Ackerman: Corruption and Government

6.4.2 Robert Klitgaard: Controlling Corruption

The best-known result of Klitgaard’s book is a simple relationship: unlawful behaviour flourishes where the official has a monopoly position over the client, where discretion is wide, and where accountability is weak.

“CORRUPTION = MONOPOLY + DISCRETION − ACCOUNTABILITY” (Robert Klitgaard: Controlling Corruption, box figure 12)

The volume’s more important finding — and the one decisive for the present case — however concerns the dual nature of rules. According to Klitgaard, rules are not in themselves good or bad from the point of view of corruption: a rule may create rents and increase actual discretion (for example if it is so complicated that the client does not understand it), but it may also reduce discretion and facilitate accountability — on his example, in the way that an admissions committee is obliged to select on the basis of a score.

This gives the design logic of MIAK’s proposal. The power to withdraw support is necessarily monopoly plus discretion; this cannot and need not be abolished, because it is precisely this power that makes it possible to recover unlawfully granted funds. What can be influenced is the other two terms: narrowing discretion by means of a criteria system published in advance (proposal 3.1), and strengthening accountability by means of the publicity of the full reasoning (proposal 3.2). In Klitgaard’s frame, therefore, MIAK is not limiting the power but improving both manageable terms of the formula.

📖 Source: Robert Klitgaard: Controlling Corruption

6.4.3 Daron Acemoglu – James A. Robinson: Why Nations Fail

Through the story of the eighteenth-century English Black Act the volume shows what distinguishes the rule of law from rule by law. According to the authors the English elite — even though it had the parliamentary majority for it — could not enforce the strict, repressive law indiscriminately, because an institutional principle that had already taken shape stood in its way.

“The Whigs were also constrained by the rule of law, the principle that laws should not be applied selectively or arbitrarily and that nobody could be above the law.” (Daron Acemoglu – James A. Robinson: Why Nations Fail)

To this the book adds the clarification often lost in today’s debates: the rule of law is not the same as rule by law. For the latter a formally adopted legal provision is enough; for the former it is necessary that the rule bind the wielder of power too, and that it apply to everyone equally.

Read in this frame, the Gallicoop case stands exactly on the dividing line. The legal basis — the transparency requirement of the public finances act — is formally in force and substantively defensible; if, however, it is applied to only one beneficiary, then it follows the pattern of rule by law. If the same requirement extends to every case concerned, on a single list and with an identical yardstick, then it follows the pattern of the rule of law. The difference is decided not by the content of the legal basis but by the publicity of the scope of its application — and this is the difference that the court too will have to weigh.

📖 Source: Daron Acemoglu – James A. Robinson: Why Nations Fail (Hungarian edition: Miért buknak el a nemzetek?)

6.5 International comparison

The requirement that the beneficial owner be knowable is not a Hungarian peculiarity: under the European Union’s anti-money-laundering directives every member state maintains a beneficial ownership register, and the EU common provisions regulation for 2021–2027 expressly prescribes the recording of beneficiary and beneficial ownership data in the management of EU funds. There are two established models for uniform application. One is the thematic audit: according to the practice of the European Court of Auditors and the national audit offices, cases with a similar risk profile are examined as a cohort rather than one by one, and the sampling methodology is published in advance. The other is the Danish model of data publicity, where agricultural support data are fully public and the press regularly analyses the lists of the largest beneficiaries — this maintains continuous social pressure, independently of any change of government. The Estonian precedent of the A8 programme point shows the same logic from the other side: there the irregularity rate of EU funds is the lowest in the EU, and this was achieved not by subsequent withdrawals but by digital record-keeping and strong internal auditing. The lesson for the Hungarian situation: withdrawal is always more expensive and more uncertain than prevention — but if withdrawal does take place, the only way in which it also stands up before a court is a uniform, documented procedure.

Transparency and anti-corruption policy

  • A8 — Cohesion policy accountability
  • A1 — Public money dashboard
  • A2 — Public procurement transparency

Agriculture

  • MG2 — Agricultural data platform
  • MG4 — Digitalisation of small farmers

Justice

  • I5 — Protection of property rights
  • I3 — Legislative impact assessment

Proposed new programme point: Uniform support review procedure — for the Transparency and anti-corruption policy area: cohort-based review, with criteria published in advance, of supports that may be withdrawn on the same legal basis, with simultaneous publication of the full reasoning of the decisions.

6.7 List of sources

Press sources (MIAK press monitor, 26 August 2026 — topic 3):

Knowledge base references (literature):

  • 📖 Susan Rose-Ackerman: Corruption and Government
  • 📖 Robert Klitgaard: Controlling Corruption
  • 📖 Daron Acemoglu – James A. Robinson: Why Nations Fail (Hungarian edition: Miért buknak el a nemzetek?)

MIAK internal materials:

  • MIAK policy area: Transparency and anti-corruption policy (programme points; programme point ID: A8, A1, A2)
  • MIAK policy area: Agriculture (programme points; programme point ID: MG2)
  • MIAK policy area: Justice (programme points; programme point ID: I5, I3)
  • MIAK press monitor, 26 August 2026 — topic 3, score: 89/100

Supplementary public data sources:

  • Hungarian State Treasury — support and beneficiary database
  • European Commission — CAP beneficiaries portal
  • OLAF — annual report
  • Fundamental Law of Hungary — Article XXIV (right to fair official procedure)

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