Part I — Situation overview

On the last Monday before the 9 May 2026 parliamentary inaugural session, on 4 May 2026, two events of different direction recorded the contours of the Tisza government’s first Brussels test. First, Andres Ritter, the prospective candidate for the European Chief Prosecutor’s post at the European Public Prosecutor’s Office (EPPO), in his interview given to the Süddeutsche Zeitung expressed that “he can hardly wait to help Péter Magyar’s government recover the illegally acquired assets — quick action is necessary, otherwise the illegally acquired assets may easily disappear for good”. Ritter’s argument is clear: Hungarian accession to the European Public Prosecutor’s Office is the most direct institutional mechanism for the recovery of EU funds already lost and for the prevention of future corruption risks. Second, Dávid Vitézy, the future minister of transport and investment, reported in a Facebook post that János Lázár, the outgoing minister, in his last days withdrew the execution tenders for the Debrecen–Nyíregyháza railway development, as well as for the Népliget station of the Budapest ring railway and for the modernisation of the Ferencváros section. “With this, the new government soon to take office inherits a realistic risk of losing about 280 billion forints in EU funding from the departing cabinet” — Vitézy stated.

The two events are substantively interconnected: the absorption risk of EU funds — according to Vitézy, “in the past two years the country has irrevocably lost 1 billion euros twice” — covers exactly the structural problem that Ritter’s EPPO mandate is designed to handle. Alongside the 280 billion forint railway risk stands a further 116 billion HUF in EU funding (the framework previously won for the HÉV vehicle procurement tender), threatened by a tender procedure “announced in the last weeks of the campaign and closed without a valid bid” — according to Vitézy, János Lázár “not only halted substantive railway development, but also dismantled the state investment institutional system”. In this context, the Lázár legacy is not simply a daily political debate, but a structural institutional-financial risk that the new government must handle in its first week.

The third substantive strand of the debate is the asylum-procedure penalty fee question. Due to the 2021 Hungarian asylum regulation — which the Court of Justice of the European Union found unlawful in Case C-823/21 — according to ATV’s reporting on 5 May 2026, “close to 1 billion euros has been lost” from the state budget in the form of a daily 1 million euro penalty over the past years. Dániel Hegedűs, Brussels-based political analyst, recorded already in HVG in April 2026: “after accession to the European Public Prosecutor’s Office, the EU cannot withhold EU funds” — EPPO accession can therefore bring results in two directions at once: (i) European-level handling of future corruption proceedings, and (ii) the release of funds with the fulfilment of the institutional condition system of the currently blocked funds. MIAK’s reading: the change of government on 9 May 2026 gives no postponement in the institutional arrangement of the Brussels-Budapest relationship — EPPO accession, handling of the Lázár legacy and the absorption schedule of funds are parallel urgent tasks.

Part II — Literature foundation

The interpretation of the debate becomes complete in the framework of four modern foundational texts of corruption theory and institutional economics. Robert Klitgaard (development economist of Harvard, Stanford and the RAND research institute), in his Controlling Corruption (1988), gives the classical formula: C = M + D − A, where C is corruption, M is the monopoly position, D is discretionary competence, and A is accountability — “corruption flourishes where monopoly position and discretionary competence meet a lack of accountability”. Susan Rose-Ackerman (Yale law professor) in Corruption and Government (1999, second edition 2016) systematises the design principles of anti-corruption agencies — independent mandate, adequate resources, transparent internal organisation, externally accountable operation. The European Public Prosecutor’s Office (EPPO), as an EU-level agency, is precisely the supranational realisation of this Rose-Ackerman model — based on TFEU Article 86. TFEU Article 325 (Protection of Financial Interests, PIF) is the competence basis of the EPPO, the operational implementation of which is provided by Council Regulation 2017/1939. Daron Acemoglu and James A. Robinson (institutional economists; Acemoglu was in 2024 a laureate of the Sveriges Riksbank Nobel Memorial Prize in Economics) in Why Nations Fail (2012) interpret the last-week pattern of the Lázár legacy with the dichotomy of inclusive and extractive institutions: “the action pattern of the outgoing political elite is often aimed not at legacy settlement, but at the conservation of extractive interests” — railway tender withdrawals are a typical institutional reflex. The detailed literature treatment is contained in section 6.4 Literature details.

Part III — MIAK’s concrete proposal

MIAK proposes three measures, building on each other, in the first 100 days of the new government — for EPPO accession, handling of the Lázár legacy, and targeted allocation of the first wave of cohesion funds, respectively.

3.1 Submitting the EPPO accession application within 60 days

MIAK proposes that the new government, within 60 days following the 9 May 2026 taking office, submit the EPPO accession application to the Council and the European Parliament. The schedule of the accession process: (i) the constitutional regulatory package submitted by the government — amendment of the prosecution law and the criminal-cooperation rules so that the competence separation between the Hungarian Prosecutor General’s Office and the EPPO is transparent; (ii) the Council decision on Hungarian accession in the framework of enhanced cooperation; (iii) preparation of an operational cooperation protocol between the European Public Prosecutor’s Office and the Hungarian prosecution, OLAF, the new Anti-Corruption Authority and the Government Audit Office. EPPO accession strengthens the A component of Klitgaard’s (see 6.4.1) C = M + D − A formula at the EU level — it anchors accountability from outside, as an institutional mechanism. At the same time it has concrete financial impact: according to Dániel Hegedűs’s analysis, after EPPO accession “the EU cannot withhold EU funds” — one of the most important milestones of the rule-of-law conditionality system is fulfilled.

3.2 Lázár-legacy tender-withdrawal audit within 30 days

MIAK proposes that the future Ministry of Transport and Investment under Dávid Vitézy’s leadership within 30 days following the 9 May 2026 taking office launch the Lázár-legacy tender-withdrawal audit. The substantive elements of the audit: (i) complete item list of ministerial tender withdrawals between 1 March 2026 — 8 May 2026, by project (date of announcement, date of withdrawal, amount of EU funds affected, responsible decision-maker); (ii) legal-procedural examination by project of whether the official justification of the withdrawal stands (objective examination of the “the public procurements were not properly prepared” argument); (iii) rescue schedule by project — which tender can be restarted with revised announcement in such a way that the original EU fund allocation is preserved; (iv) Commission notification of those projects in which a rule-of-law risk also exists (e.g. the political motivation of the tender withdrawal can be substantiated). Methodologically the audit uses the Klitgaardian C = M + D − A formula: tender withdrawals represent a structural risk where the ministerial monopoly position (M), the ministerial discretion (D) and the lack of accountability (A) are present together. The proposal at the same time follows the Rose-Ackerman (see 6.4.2) anti-corruption agency design principles: the audit also involves an independent professional body (State Audit Office, independent organisational unit of the Government Audit Office).

3.3 Targeted allocation of the first wave of cohesion funds (30-180 day horizon)

MIAK proposes that the new government target the first wave of cohesion funds (estimate: 7–9 billion EUR may be released in the second half of 2026 if the milestones of the rule-of-law conditionality system are met): on small-volume, many-beneficiary, demonstratively compliant projects. Suggested allocation weighting: (i) basic-care digitalisation (~30%) — e-equipment development of the GP system, expansion of the e-prescription system, support for NEAK healthcare data-disclosure reforms; (ii) public-education infrastructure (~25%) — school equipment development, energy renovation, accessibility upgrades; (iii) household energy-efficiency loan (~25%) — heating modernisation of low-income households, insulation, heat-pump support; (iv) road and rail small- and medium-scale projects (~20%) — particularly the rescue of the projects affected by Lázár-style tender withdrawals. The targeted allocation follows the Acemoglu-Robinson (see 6.4.3) inclusive institutional pattern: not a few mega-projects of a narrow economic elite, but direct perception of many thousands of beneficiaries. At the same time the communications effect is also inclusive: Hungarian society directly feels the return of EU funds, which strengthens the political legitimation of EU membership.

The three proposals together draw a gradually deepening reform: the EPPO accession application 60 days, the Lázár audit 30 days, the allocation of the first wave of cohesion funds 30-180 day horizon. The three are the operationalisation of rule-of-law conditionality — not as an abstract obligation, but as a concrete institutional-financing schedule.

Part IV — Expected impacts and risks

Dimension Expected impact Risk
EU funds Release of the first cohesion-RRF wave of EUR 7–9 bn in the second half of 2026; cessation of the penalty proceedings (asylum 1 bn EUR, ‘child protection’ 700-800 m EUR). Cessation of penalty proceedings comes only with the fulfilment of the regulatory conditions — e.g. it is to be interpreted together with the repeal of the 2021 ‘child protection’ law (see the parallel blog).
EPPO accession Structural accountability mechanism at the EU level; capacity expansion of the Hungarian anti-corruption sector; normalisation of the Brussels-Budapest relationship. The competence separation between the Hungarian Prosecutor General’s Office and the EPPO is constitutionally sensitive — amendment of the Hungarian prosecution law requires a two-thirds parliamentary majority. With the Tisza parliamentary group’s 141 mandates this exists, but professional consultation is needed.
Lázár legacy The 280 bn HUF + 116 bn HUF EU funds of the railway and HÉV tenders can be saved — if the audit runs quickly, and the new government restarts them with revised announcement within deadline. Due to the multi-year planning cycle of the railway and HÉV projects, a restarted tender means at least 6-12 months of slippage — even in case of successful rescue. Time is the main opponent here.
Political communication The narrative of “we are bringing back the EU funds” is easy to communicate; many beneficiaries directly feel the change. The “Brusselsism” conservative press narrative (see 6.1) may give an attack surface if the Tisza government communicates EU-supported projects immoderately. MIAK proposes matter-of-fact, numerical, concrete-milestone-based communication.

The common element of the four dimensions: success depends on time-sensitivity. The EPPO accession process and the cohesion fund drawdown both have a 6-18 month time horizon — the Lázár audit, by contrast, 30 days. The synchronisation of the three tempos is the strategic task of the cabinet.

Part V — Measurability and summary

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

In one year (May 2027) it is recommended to look at four indicators:

  1. EPPO accession milestones: submission of the application (target: within 60 days), Council decision (target: within 6 months), signing of the operational cooperation protocol (target: within 12 months).
  2. Volume of released EU funds: cumulative release volume of funds blocked or delayed on 9 May 2026 (cohesion + RRF + rule-of-law conditionality funds). Target: at least EUR 5 bn cumulative drawdown success in the first 12 months.
  3. Lázár-legacy tender rescue: of the tenders withdrawn in János Lázár’s last week, how many were restarted, and what is the amount of EU funds preserved during the restart. Target: at least 70% tender-rescue rate — in amount at least HUF 280 bn preserved EU funds.
  4. Worldwide Governance Indicators (WGI) — Control of Corruption: the World Bank’s annual anti-corruption indicator for Hungary. Target: above +0.30 (2024 value: +0.15 — substantive movement is measurable within 12 months, full catch-up is 4-5 years).

5.2 Summary

The two events of 4 May 2026 — Andres Ritter’s Süddeutsche Zeitung interview and Dávid Vitézy’s announcement on the Lázár legacy — record a precise policy request to the new government. MIAK asks the new government to submit the EPPO accession application within 60 days on the basis of TFEU Article 86, to launch the Lázár-legacy tender-withdrawal audit within 30 days for the rescue of HUF 280 bn + HUF 116 bn in EU funds, and to target the allocation of the first wave of cohesion funds on small-volume, many-beneficiary, demonstratively compliant projects. The proposals operationalise the transparency, data-drivenness and accountability foundational values: transparency through the public documentation of the Lázár audit, data-drivenness through the objective criteria of the tender-withdrawal examination, and accountability through the structural accountability mechanism of EPPO accession. Rule-of-law restoration is not identity politics, but a 7-9 trillion forint budgetary question — every month of delay is concrete damage measurable in fillérs to the Hungarian state budget.

Part VI — Justifications and additional sources

6.1 Press framing across the spectrum

Liberal-left band (HVG, Telex, 24.hu, 444.hu, Népszava). HVG handled the topic with a double leading story: the interview-analysis of the prospective head of the European Public Prosecutor’s Office (“The next head of the European Public Prosecutor’s Office can hardly wait to help Péter Magyar recover the siphoned-off EU funds”) and the economic article analysing the parliamentary positioning of Fidesz (“And then Fidesz politely asks Péter Magyar’s people not to abuse the two-thirds power”). The practical railway tender announcement was also reported in detail by Telex and 24.hu. The liberal-left band brought the structural perspective of EPPO accession to the foreground.

Economic band (Portfolio). Portfolio appeared with two articles: the Lázár-legacy analysis (“János Lázár has left such a farewell gift that puts close to 300 billion forints of EU funds at risk”) and the Vitézy announcement (“Dávid Vitézy: the European Union funds must be saved”). The Portfolio’s focus was on the numerical risk — HUF 280 bn, HUF 116 bn, EUR 1 bn lost annually — as the main narrative.

Public-affairs band (ATV). ATV brought the topic with two articles: the EU-funds race against time (“Péter Magyar is racing against time for the EU funds”) and the EUR 1 bn lost due to asylum regulation (“Close to one billion euros lost due to the unlawful asylum regulation”). The public-affairs band thus highlighted the time-sensitivity.

Conservative band (Magyar Nemzet, Mandiner). Magyar Nemzet and Mandiner reinforced the contrast between Brussels and sovereignty as a framing — on this day they did not bring the EPPO accession question independently as a leading story; the Lázár-legacy debate seems to them rather a ministerial communications question that requires the Tisza government’s self-reflection. The conservative band thus brought the criticism of the Brussels-alignment narrative to the foreground — without accompanying the numerical (HUF 280 bn) risk with concrete substantive commentary.

Across the entire spectrum EPPO accession and the Lázár legacy got the leading place in the liberal-left and economic bands; the conservative band reinforced the ideological framing.

6.2 Facts and data

  • EPPO (European Public Prosecutor’s Office): an EU agency established on the basis of Council Regulation 2017/1939, operating on the basis of TFEU Article 86. Currently 24 EU member states participate (in the framework of enhanced cooperation); Hungary is not a member (in addition to Poland, Sweden, Ireland, Denmark; Poland signalled accession intent in 2025).
  • Andres Ritter is a German prosecutor, current head of EPPO-EE; expected to take over the European Chief Prosecutor’s position in the second quarter of 2026.
  • Lázár legacy (railway tender withdrawals): Debrecen-Nyíregyháza railway development, Budapest ring railway Népliget station, Ferencváros section modernisation — together a risk of about HUF 280 billion in EU funds (Dávid Vitézy 4 May 2026 communication).
  • HÉV vehicle procurement tender: a tender announced during János Lázár’s campaign period, to which no valid bid was received; the EU funding affected is HUF 116 billion.
  • According to Vitézy’s analysis, in the past two years EU funds of EUR 1 bn (~HUF 400 bn) were lost annually due to irregularities — two-year cumulative damage ~HUF 800 bn.
  • Asylum case C-823/21: 2021 final judgment of the EU Court of Justice, daily EUR 1 m penalty fee ~ over 5 years close to EUR 1 bn (ATV 5 May 2026 communication).
  • Tisza parliamentary group mandate count: 141 (NVI 19 April 2026 finalisation). Amendment of the prosecution law requires a two-thirds (134) mandate.

6.3 Policy aspects

  • Foreign policy (programme points and background material) — EU-Hungary relationship arrangement, RRF negotiations, EPPO accession;
  • Transparency and anti-corruption policy (programme points) — EPPO accession schedule, rule-of-law conditionality, corruption accountability;
  • Economy (programme points) — EU funds absorption, cohesion-RRF allocation, budgetary impact analysis.

6.4 Literature details

6.4.1 Robert Klitgaard: Controlling Corruption

Klitgaard’s main thesis sentence is the C = M + D − A formula: “corruption flourishes where monopoly position and discretionary competence meet a lack of accountability — anti-corruption policy must therefore aim not at the punishment of »ill-intentioned acts« in itself, but at the reform of the structural components (M, D, A)”. In the Hungarian 2026 context, the last-week tender withdrawals of the Lázár legacy directly illustrate the formula: the outgoing ministry (i) had monopoly position in railway development (M) in the transport and investment portfolio, (ii) applied broad ministerial discretion to the tender withdrawal decisions (D), (iii) while accountability (A) was minimal during the change-of-government power transition — the Tisza government was not yet in office, parliamentary control was not yet organised, the press and civil monitoring react slowly. Klitgaard’s recipe: strengthening A — independent audit, EPPO accession, parliamentary inquiry committee — is the structural answer.

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

6.4.2 Susan Rose-Ackerman: Corruption and Government

Rose-Ackerman systematises the design principles of anti-corruption agencies. “The well-designed anti-corruption agency shows four characteristics: political independence, adequate resource allocation, transparent internal organisation, and outward-facing accountability — including reporting obligation to parliament and the press.” The European Public Prosecutor’s Office (EPPO), as an EU-level agency, is precisely the supranational realisation of this Rose-Ackerman model. EPPO is independent (from member-state political influence), has adequate resources (from the EU budget), is of transparent internal organisation (European Chief Prosecutor + delegated prosecutors per member state), and on the basis of the PIF directive has reporting obligation towards the European Parliament. Hungarian EPPO accession is therefore not the founding of a new agency locally, but entry into an already existing Rose-Ackerman model — therefore quicker and institutionally more solid than the founding of a domestic anti-corruption agency would be.

📖 Source: Susan Rose-Ackerman: Corruption and Government: Causes, Consequences, and Reform (Cambridge University Press, 1999, second edition 2016)

6.4.3 Acemoglu — Robinson: Why Nations Fail

In Acemoglu and Robinson’s framework, the action pattern of the outgoing political elite is one of the most frequent extractive institutional reflexes: “when a narrow power elite loses political position, in the last weeks before exit it often takes extractive steps — to conserve the financial or institutional positions of its own circle, or to push the successor into a worse starting position so that its own period appears brighter in comparison”. The last-week tender withdrawals of the Hungarian Lázár legacy are typical illustrations of this pattern: the departing cabinet withdrew its railway and infrastructure tenders, while for the incoming cabinet the rescue is operationally difficult (restart time, project planning slippage). The proposed Lázár audit (3.2) is therefore not only a concrete procedural examination, but the structural exposure of the Acemoglu-Robinson extractive institutional reflex, and the recording of a mechanism of accountability for the outgoing elite — so that in the case of subsequent changes of government the last-week tender-withdrawal pattern already entails legal risk.

📖 Source: Daron Acemoglu — James A. Robinson: Why Nations Fail (Crown Business, 2012; Hungarian: Miért buknak el a nemzetek, HVG Könyvek, 2013)

6.5 International comparison

Poland (EPPO accession in 2025): the post-October-2023 Tusk government signalled the EPPO accession intent officially within 18 months following taking office — this shows for the Hungarian model the reachability of a shorter deadline frame. The Polish accession process runs according to Article 11 of Regulation 2017/1939 (enhanced cooperation). Czechia (EPPO membership since 2021): the competence separation between the Czech Prosecutor General’s Office and the EPPO consolidated between 2021-2024 after substantive debates — the Hungarian accession process starts with this experience base. Slovakia (EPPO membership since 2021, debates under the 2024 Fico government): the 2024 Fico government tried to weaken the structural accountability mechanism through prosecutorial reform — the Commission initiated penalty proceedings. The Hungarian accession process must proceed along professional consensus and constitutional stability — otherwise the Slovak pattern may be repeated.

Foreign policy

  • KP4 — principled pragmatism in EU negotiations
  • KP7 — EU-law dispute settlement and management of penalty proceedings

Transparency and anti-corruption policy

  • A3 — Anti-Corruption Authority and Ethics Council
  • A8 — EPPO accession and EU-level accountability

Economy

  • G7 — absorption of cohesion funds and RRF compliance
  • G12 — public-procurement reform and transparent tender procedure

Proposed new programme point: Outgoing-government legacy-audit protocol — independent examination of change-of-government tender withdrawals — to the Transparency and anti-corruption policy area.

6.7 List of sources

Press sources (MIAK press monitor, 5 May 2026 — topic 4):

Knowledge-base references (literature):

  • 📖 Robert Klitgaard: Controlling Corruption (1988)
  • 📖 Susan Rose-Ackerman: Corruption and Government (1999/2016)
  • 📖 Daron Acemoglu — James A. Robinson: Why Nations Fail (2012)
  • 📖 TEU/TFEU consolidated 2012 — in particular TFEU Article 86 (EPPO), Article 325 (PIF), and Council Regulation 2017/1939 on the establishment of the EPPO
  • 📖 OECD Economic Survey of the EU 2025 — absorption analysis (cohesion funds and RRF)

MIAK internal materials:

  • MIAK policy area: Foreign policy (programme points; programme point ID: KP4, KP7)
  • MIAK policy area: Transparency and anti-corruption policy (programme points; programme point ID: A3, A8)
  • MIAK policy area: Economy (programme points; programme point ID: G7, G12)
  • MIAK press monitor, 5 May 2026 — topic 4, score: 76/100

Additional public data sources:

  • European Commission RRF reports (Hungary 2024-2025); OLAF annual report 2024; EU Cohesion Open Data; Transparency International CPI 2025; Worldwide Governance Indicators 2024.

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