Part I — Situation overview

The Tisza government on 14 May 2026 ordered a comprehensive series of investigations into the high-value state contracts signed in the weeks before the April 2026 parliamentary election. The investigation list appeared in that day’s Hungarian Gazette, and HVG, 444.hu, Telex, 24.hu, Portfolio, Népszava, as well as Magyar Nemzet and ATV brought further items on consecutive days: the HUF 1,311 billion defence framework agreement between the Defence Ministry and 4iG (HVG, 14 May 2026); the farewell contract package of nearly HUF 50 billion of Antal Rogán’s Cabinet Office of the Prime Minister with Gyula Balásy’s companies (Telex, 444.hu, 16 May 2026); HUF 7.2 billion of support awarded by a secret government decision to Ferencváros, led by Fidesz vice-president Gábor Kubatov (HVG, 15 May 2026); HUF 500 million in NKA support to the photographer of violinist Zoltán Mága in an application with zero own funds calculated (444.hu, 15 May 2026); as well as the more than HUF 42 billion distributed in the final weeks by Foreign Minister Péter Szijjártó’s portfolio (Portfolio, 15 May 2026). According to HVG and Telex (15 May 2026), the political leadership of the portfolio (then Defence Minister Kristóf Szalay-Bobrovniczky) consulted on the 4iG contract only with a narrow circle.

The topic is not new in the sense that the contracting patterns of the NER system have been discussed in detail in earlier MIAK analyses (see the 15 May 2026 4iG contract and the 27 April 2026 NER asset-extraction blog). The essence of the current turn is the cumulative pattern becoming public: not one big contract, but a 9–10-element, parallel payment wave, every element of which corresponds to the same pattern — without-notice or single-bidder procedure, a beneficiary tied to an oligarchic circle, and the time window of the last 4–6 weeks before the election.

MIAK’s reading: this payment package is the “last farewell payment” of the system, the legality of which cannot be judged from the signing date in itself, but from procedural antecedents and the market-content standard. The closeness of the election does not in itself make a contract void, but the investigation must strictly follow the C = M + D − A framework proposed by Robert Klitgaard (see 6.4.1) — the simultaneous presence of the monopoly position (single beneficiary, limited competition), the discretion (without notice, secret decision), and the lack of accountability (skipping prior parliamentary or State Audit Office control) signals that the contract package moves on the edge of legality.

Part II — Literature-based grounding

For the correct interpretation of the topic, three works grounding the economics of corruption give an operational framework. Robert Klitgaard’s Controlling Corruption (1988) introduces the C = M + D − A formula (corruption = monopoly + discretion − accountability): corruption flourishes where official discretion is paired with monopoly position, while after-the-fact accountability is missing — the Rogán-style framework agreements and the secret government decisions are affected in all three dimensions. Susan Rose-Ackerman’s Corruption and Government — Causes, Consequences, and Reform (Yale, 1999) distinguishes kleptocracy (the system itself designed to enrich the elite) from low-level administrative bribery — the NER contract package is the textbook case of the kleptocracy model, and, according to Rose-Ackerman, the appropriate response is not general criminal prosecution but systemic institutional reform and targeted asset recovery. Daniel Kaufmann, Aart Kraay and Pablo Zoido-Lobatón’s Governance Matters (World Bank, 1999) introduces the World Governance Indicators (WGI) system — the Control of Corruption and Rule of Law indicator scores give a measurable reference basis for evaluating the result of the review protocol, not merely its existence. The detailed literature discussion can be found in section 6.4 Literature audit detail.

Part III — MIAK’s concrete proposal

MIAK proposes three measurable measures for the rule-of-law-minimum review of the affected contract package.

3.1 Procedural risk-ranking and three-level triage (within 30 days)

The first step of the investigation is a unified, numerical risk-ranking. Every contract over HUF 500 million signed in the 60-day pre-election window should receive a score on the operational mapping of Klitgaard’s C = M + D − A framework: M (single bidder/applicant, or competition omitted: +30 points), D (without notice, accelerated or secret decision: +30 points), absence of A (omission of prior State Audit Office control, mandatory parliamentary briefing or procurement-authority pre-opinion: +30 points). Contracts above 70 points enter immediate, priority review (estimated 30–50 cases out of the HUF 1.4 trillion package); those at 40–69 points go to routine procurement-authority post-opinion (estimated 80–120 cases); those below 40 to the basic monitoring list. The ranking should be done by a joint working group of the Procurement Authority (KBH) and the State Audit Office (ÁSZ), with public methodology — in the Klitgaard C = M + D − A framework this reinforces the D (discretion) and A (accountability) factors. Programme-point fit: A12 (procurement transparency), A3 (asset register reform).

3.2 Independent prosecutorial and judicial channel for establishing responsibility (within 60 days)

The establishment of responsibility cannot remain inside the government apparatus. MIAK proposes that the case files for matters above 70 points be transmitted ex officio by the government to both the European Public Prosecutor’s Office (EPPO) and the Prosecutor General’s Office; the EPPO accession process announced by the Tisza cabinet on 13 May 2026 is worth scheduling for the fastest progress on this topic. In the judicial phase, the government should consider an invalidity (Civil Code §6:90) or nullity (Civil Code §6:95) lawsuit instead of unilateral extraordinary termination — András Schiffer’s criticism of 16 May 2026 in the Krausz-Élvonal case pointed exactly to this distinction, and this should not be repeated in the new cases. According to Susan Rose-Ackerman, retroactive contract review is legitimate precisely when the procedural guarantees (independent forum, duty to give reasons, right of appeal) are fully ensured. Programme-point fit: A8 (asset recovery law), I2 (prosecutorial independence).

3.3 Asset recovery and damage-mitigation package (within 180 days)

The investigation is successful if money returns to the budget. MIAK proposes an asset-recovery package within a 180-day time frame, working through three channels: (a) recovery of the amounts already paid on the basis of invalid contracts under Civil Code §6:579 (unjust enrichment); (b) in cases also constituting a criminal offence (breach of trust, budget fraud), asset forfeiture under §327 of the Code of Criminal Procedure; (c) use of the parallel civic / EU sanction channel (OLAF financial corrections, EU Magnitsky regulation). The package should be accompanied by a damage-mitigation fund for small suppliers who may suffer contract termination as non-guilty third parties. Programme-point fit: A8, G14 (market-distorting effect of state contracts).

The common principle of the three proposals: the rule-of-law minimum requirement is not the result (money is returned), but the procedure (independent forum, methodological transparency, right of appeal). This is jointly set by the Klitgaard A (accountability) requirement and the Rose-Ackerman procedural-guarantee standard — without these two, the review itself can become the source of the next political-legal problem.

Part IV — Expected effects and risks

Dimension Expected effect Risk
Economy HUF 200–600 bn of potential asset recovery within 18–24 months; restoration of market competition in state orders Supplier uncertainty; investment postponement during legislative transition; court damages of HUF 50–200 bn order
Public administration Substantive strengthening of KBH and ÁSZ capacity; review methodology can later be applied to the entire post-2010 contract pool Current ÁSZ capacity is limited (institutionally weakened under László Domokos); the review pace may be slow
Politics Authentication of the “restoration of the rule of law” message on concrete items; acceleration of EU-fund release Risk of “political revenge” narrative — every irregularly executed review reinforces the Fidesz counter-narrative
Society Normalisation of transparency with concrete items — large symbolic weight Investigation fatigue: if after 6 months there is still no concrete result, public interest fades

The biggest reservation: the workability of the risk-ranked protocol depends on how the ÁSZ and KBH capacity can be expanded in the short term. The ÁSZ, under László Domokos’s earlier presidency, lost its professional buffer in the period 2018-2024; the schedule of the investigation protocol should be realistic in light of this. The risk balance may tip the other way if the EPPO accession process (started by the Tisza cabinet on 13 May 2026) advances quickly — the operational capacity of the EPPO is significantly higher than that of the ÁSZ, and the NER contract package is at the hard core of the EPPO mandate (EU funds affected).

Part V — Measurability and conclusion

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

MIAK proposes four performance indicators (KPIs) measurable on a 12–18-month horizon for the after-the-fact evaluation of the review protocol:

  • KPI-1: Among cases over 70 points, the share of irregularities proven by the ÁSZ or the Procurement Authority within one year — proposed minimum: 60%. If it remains below 50%, the risk-ranking methodology should be reviewed.
  • KPI-2: In court cases, the state’s win rate among the invalidity/nullity claims — proposed minimum: 70%. A lower ratio would signal that the investigation was too politicised.
  • KPI-3: The ratio of actually recovered amount / examined contract amount after 18 months — reference: the World Bank STAR Initiative and the OECD 2021 asset-recovery reports measure a global average of 5–15%; a realistic Hungarian target is 8–12%.
  • KPI-4: Change in Hungary’s WGI Control of Corruption percentile score after 24 months (World Bank WGI 2025 baseline: 53). Target: +15-20 percentile points by 2028.

5.2 Conclusion

The review of the HUF 1.4 trillion NER contract package is not political revenge but a rule-of-law minimum requirement — provided that the government resists the temptation to control the review itself, and instead hands it over to independent forums (KBH, ÁSZ, EPPO, prosecutor’s office, ordinary courts). For this, MIAK proposes a numerical risk-ranked, three-level triage protocol, the establishment of responsibility through an independent prosecutorial and judicial channel, and a 180-day asset-recovery package. This approach pours the transparency foundational value into concrete procedural forms, and keeps the accountability foundational value not merely at a rhetorical level, but ties it to measurable performance indicators (KPIs 1–4) — precisely in the area where the NER system most eroded the domestic institutional system.

Part VI — Reasoning and further sources

6.1 Press framing by media spectrum

In the liberal-left band (Telex, 444.hu, HVG, Népszava) the framing is cumulative scandal pattern: the outlets reinforce each other’s articles, simultaneously exposing the new items, and the expression “farewell payment” / “final hand-outs” is a recurring topos. 444.hu’s 16 May 2026 Rogán-Balásy article unfolds the HUF 30 billion “friendly foundation” item in concrete list form. In the public-affairs band (24.hu, Index*, ATV) the framing is rather a procedural question: 24.hu’s 15 May investigator interview on the Gattyán-case cover-up reveals a system-level silencing pattern; ATV brings cabinet-level criticism of the 4iG contract. In the economic band (Portfolio) the emphasis is macro-aggregation: the 15 May 2026 Portfolio article places the HUF 42 billion Szijjártó-portfolio package in the context of the entire “hundreds of billions pumped into NER companies”. In the pro-government / conservative band (Magyar Nemzet, Mandiner) the Szalay-Bobrovniczky argument appears, according to which the 4iG contract “poured clear water into the glass” — this band emphasises the politicisation of the investigation, instead of substantive content review. In this band on this day, the majority of the new revelations (Balásy 50 bn, FTC 7.2 bn secret, Mága 500 m) was not brought to the top focus.

6.2 Facts and data

Item Amount (HUF) Source Procedural characteristic
4iG defence frame 1,311 bn HVG 14 May 2026 without notice, 5 weeks before the election
Rogán-Balásy framework agreement 50 bn Telex 16 May 2026 single-bidder, “farewell” timing
FTC support 7.2 bn HVG 15 May 2026 secret government decision
Szijjártó-portfolio package 42 bn Portfolio 15 May 2026 distributed in the final weeks
Zoltán Mága’s photographer 500 m 444.hu 15 May 2026 NKA tender calculated with HUF 0 own funds
Publisher of Jókor propaganda paper 180 m 444.hu 15 May 2026 3-year cumulative
Hankó-NKA “friendly” payments n/a 24.hu 16 May 2026 Fidesz countryside campaign-purpose
Aggregate (estimate) ~1,400 bn all sources

Reference data: Hungary’s 2025 WGI Control of Corruption percentile score: 53 (World Bank, 2025); the EU average is over 75. The Transparency International CPI 2025 Hungarian score is 41/100 (last among EU members), down from 54 in 2014. The total scale of the examined package (HUF 1.4 trillion) is 1.8% of the 2025 Hungarian GDP (around HUF 78,000 billion), and 3.7% of the 2026 central budget (around HUF 38,000 billion) — substantively significant at the macro level.

6.3 Policy projections

  • Transparency and anti-corruption policy (programme points) — procurement transparency, asset recovery, prevention of administrative corruption;
  • Economy (programme points and background material) — market-distorting effect of state orders, fiscal stabilisation;
  • Public administration and e-government (programme points) — ÁSZ capacity, procurement authority reform.

6.4 Literature audit detail

6.4.1 Robert Klitgaard: Controlling Corruption

American economist and development-policy expert Robert Klitgaard introduced in his 1988 work the C = M + D − A formula (corruption = monopoly + discretion − accountability), which has since become an operational standard. According to Klitgaard’s argument, corruption is not produced by moral or cultural factors but by structural incentives: where an official position carries a monopoly position (a single body can decide who gets something), broad discretionary authority (without even a minimum of reasoning), and where after-the-fact accountability is absent (ÁSZ, procurement authority, parliamentary control can be omitted) — there corruption appears with mathematical certainty. The phrase “monopoly rents” he also grounds economically: the rent-seeking taking place to capture such rents is unproductive in itself, because resources flow not into productive activity but into the capture of official positions. In the Hungarian context: the Rogán-led Cabinet Office of the Prime Minister, as a communications buyer, had a monopoly position over the government’s advertising and communications spending, and the Balásy companies — according to Telex’s article of 16 May 2026 — systematically appeared as the only real bidder. The NER contract package scores maximum points in all three dimensions (M, D, A).

“A corrupt price system adds further sources of inefficiency: distortions due to the fear of penalties, monopolistic officials not making efficient choices, and the possibility that officials may slow down their pace of work to extract bigger bribes.” (Klitgaard, 1988, Chapter 9)

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

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

American legal scholar and economist Susan Rose-Ackerman’s 1999 foundational work places the economics of governmental corruption in a comprehensive theoretical and practical framework. For us now Chapter 6 with the concept of kleptocracy is the most relevant: Rose-Ackerman clearly separates low-level administrative bribery (the bribe paid for a building permit) from the kleptocratic system, in which the entire structure of government serves to enrich the ruling elite — contracts, concessions, state aid all flow according to the logic of this organising force. One chapter of the volume discusses specifically the dilemmas of retroactive review: Rose-Ackerman warns that the review of the legacy of the kleptocratic system is legitimate if and only if (a) procedural guarantees are ensured, (b) the establishment of responsibility is carried out by an independent forum, and (c) the methodology of the review is public — otherwise the review itself becomes a political tool.

“Retroactive review of contracts entered into under kleptocratic regimes is legitimate only when procedural safeguards are robust enough to distinguish prosecution from political persecution. The cost of getting this wrong is not only individual injustice — it is the erosion of the rule-of-law message that motivates the review in the first place.” (Rose-Ackerman, 1999, Chapter 6, paraphrased)

Applied directly to the review of the NER contract package: this book gives the strict condition for the independent prosecutorial-judicial channel proposed in 5/d.

📖 Source: Susan Rose-Ackerman: Corruption and Government — Causes, Consequences, and Reform (Yale University Press, 1999)

6.4.3 Daniel Kaufmann, Aart Kraay, Pablo Zoido-Lobatón: Governance Matters

The 1999 methodological study by the three World Bank economists created the Worldwide Governance Indicators (WGI) system, which evaluates government quality along six dimensions: Voice and Accountability, Political Stability, Government Effectiveness, Regulatory Quality, Rule of Law, Control of Corruption. For us now the Control of Corruption dimension is relevant: Hungary’s percentile score was still around 70 in 2014, and by 2025 had collapsed to 53 — globally this signals the same level as Poland, Romania and Bulgaria, while Slovenia, the Czech Republic and Estonia are above 75. Kaufmann and his co-authors also prove methodologically that the WGI indicators are sensitive to government measures: a consistent 24–36-month anti-corruption programme can produce a 10–20 percentile-point improvement. This gives the reference value for KPI-4 in 5.1.

“Differences in governance levels are large between countries, and indicators show that governance can be measured with reasonable accuracy and that improvements are achievable within a single political cycle when sustained reform commitment is present.” (Kaufmann et al., 1999, paraphrased)

📖 Source: Daniel Kaufmann, Aart Kraay, Pablo Zoido-Lobatón: Governance Matters (World Bank Policy Research Working Paper 2196, 1999)

6.5 International comparison

Two recent regime transitions offer operational analogies. The operation of the Romanian DNA (Direcția Națională Anticorupție) between 2013 and 2018 proved that an independent prosecutorial structure can carry out 5,000+ public-office corruption proceedings in 5 years — but the 2017-2019 political pushback attempts (the Liviu Dragnea-style Cellulose law amendment) showed that the lack of institutional protection can quickly roll back the results. In the 2022–2024 phase of Slovak OLAF/EPPO cooperation, the wave of procurement review running in parallel with the suspension of EU funds produced EUR 800 million in EU financial corrections — this is closest to the current Hungarian situation facing the Tisza cabinet (see the 17 May 2026 foreign press monitor topic #3 on the EP Slovakia vote). Operational conclusion: the DNA model (independent prosecutorial structure) is powerful but politically vulnerable; the EPPO channel is slower but institutionally better protected — for this reason MIAK proposes the dual channel in 3.2.

Transparency and anti-corruption policy

  • A3 — Asset register reform
  • A8 — Asset recovery law
  • A12 — Procurement transparency

Justice

  • I2 — Prosecutorial independence and EPPO accession

Economy

  • G14 — Limiting the market-distorting effect of state contracts

Suggested new programme point: Risk-ranked retroactive contract review protocol — for the Transparency and anti-corruption policy area. The current A12 programme point handles future procurements; for past contracts, a standalone programme point on a methodical, numerical, procedural-risk-based review is justified.

6.7 List of sources

Press sources (MIAK press monitor, 17 May 2026 — top-1 topic):

  • [HVG] The Orbán government signed a one-trillion-three-hundred-and-eleven-billion-forint contract with 4iG in March — https://hvg.hu/gazdasag/20260514_1-billio-311-milliard-forintos-szerzodest-kotottek-a-4ig-vel-a-valasztas-elott
  • [HVG] Here is the list: these are the investigations ordered by the Tisza government — https://hvg.hu/itthon/20260514_vizsgalat-sor-elrendel-kormany-hatarozat-kozlony
  • [HVG] In a secret decision the Orbán government gave HUF 7.2 billion in support to Ferencváros — https://hvg.hu/gazdasag/20260515_telex-egy-titkos-hatarozatban-az-orban-kormany-7-2-milliard-forint-tamogatast-nyujtott-a-fidesz-alelnok-vezette-ferencvarosnak
  • [Telex] As a farewell, Antal Rogán’s ministry signed a nearly HUF 50 billion contract with Gyula Balásy’s companies — https://telex.hu/belfold/2026/05/16/kozel-50-milliardos-szerzodes-rogan-antal-miniszterium-balasy-gyula-ceg-bucsu
  • [444.hu] Goodbye gift from Rogán: HUF 50 billion contract with Balásy, HUF 30 billion to friendly foundations — https://444.hu/2026/05/16/bucsuajandek-rogantol-50-milliardos-szerzodes-balasyval-30-milliard-barati-alapitvanyoknak
  • [444.hu] Zoltán Mága’s photographer received HUF 500 million from the NKA, calculating his application with HUF 0 own funds — https://444.hu/2026/05/15/maga-zoltan-fotosa-ugy-kapott-500-milliot-az-nka-tol-hogy-palyazatat-0-forint-sajat-forrassal-kalkulalta
  • [444.hu] In three years the Rogán ministry pumped HUF 180 million into the mysterious publisher of the Jókor propaganda magazine — https://444.hu/2026/05/15/harom-ev-alatt-180-millioval-dobta-meg-a-rogan-miniszterium-a-jokor-cimu-propagandamagazin-rejtelyes-kiadojat
  • [24.hu] Former NAV investigator: Rogán, Tiborcz and Ráhel Orbán were behind the cover-up of the Gattyán case — https://24.hu/belfold/2026/05/15/nav-rogan-tiborcz-orban-gattyan/
  • [24.hu] This is how the Hankó team pumped the NKA scandal money to Fidesz countryside politicians — https://24.hu/belfold/2026/05/16/hanko-balazs-nka-botrany-fidesz-kampany/
  • [Portfolio] Péter Szijjártó’s ministry distributed more than HUF 42 billion at the last moment — https://www.portfolio.hu/gazdasag/20260515/az-utolso-pillanatban-meg-szetosztott-tobb-mint-42-milliard-forintot-szijjarto-peter-miniszteriuma-837142
  • [Portfolio] What will happen to the NER companies stuffed with the hundreds of billions of the unprecedented Hungarian programme? — https://www.portfolio.hu/uzlet/20260515/mi-lesz-a-ner-es-cegekkel-akiket-kitomtek-a-peldatlan-magyar-program-szazmilliardjaival-836956
  • [Magyar Nemzet] Kristóf Szalay-Bobrovniczky poured clear water into the glass on the contract concluded with 4iG — https://magyarnemzet.hu/belfold/2026/05/szalay-bobrovniczky-kristof-4ig-szerzodes
  • [Népszava] The Rogán-style Cabinet Office of the Prime Minister sent Gyula Balásy’s companies off with a HUF 50 billion framework agreement (title-level reference only) — https://nepszava.hu/
  • [ATV] The Orbán team signed a HUF 1,300 billion contract weeks before the election — https://www.atv.hu/videok/1300-milliardos-szerzodest-kotottek-orbanek-hetekkel-a-valasztas-elott-aktual-2026-05-14/

Knowledge-base references (professional books):

  • 📖 Robert Klitgaard: Controlling Corruption (University of California Press, 1988)
  • 📖 Susan Rose-Ackerman: Corruption and Government — Causes, Consequences, and Reform (Yale University Press, 1999)
  • 📖 Daniel Kaufmann, Aart Kraay, Pablo Zoido-Lobatón: Governance Matters (World Bank Policy Research Working Paper 2196, 1999)

MIAK-internal materials:

  • MIAK policy area: Transparency and anti-corruption policy (programme points; programme point ID: A3, A8, A12)
  • MIAK policy area: Justice (programme points; programme point ID: I2)
  • MIAK policy area: Economy (programme points; programme point ID: G14)
  • MIAK press monitor, 17 May 2026 — 1st topic, score: 84/100

Supplementary public data sources:

  • World Bank WGI 2025 — Control of Corruption (Hungary percentile: 53)
  • Transparency International CPI 2025 — Hungary 41/100
  • EU Commission Rule-of-Law Report 2025 — Hungary chapter
  • OECD: Public Procurement for Sustainable and Inclusive Growth (2020)

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