Part I — Situation overview

On 3 September 2026 the new leadership of the Magyar Nemzeti Bank (MNB) filed a criminal complaint on suspicion of misappropriation, negligent management, fraud and abuse of office in the matter of five properties linked to the central bank: the Education and Training Centre at Balatonakarattya, Bölcsvár, the MNB Buda Centre, the MNB Supervisory Centre and Money Museum, and the Pallas Athéné Conference Centre are affected. The basis for the step is the report on the screening of the operations of MNB-Ingatlan Kft. and the newly prepared valuations: according to these, the investments were significantly overpriced, and the real value of the buildings falls substantially short of their book value. The procedure is an extension of the criminal complaint filed by the central bank in October 2025 in connection with the refurbishment of its headquarters, which is already at the investigation stage. On the same day it became known that the MNB had released to Transparency International Hungary the list of contracts concluded after 1 January 2025, and announced in a statement that in future it will publish the tabulated data of its contracts quarterly on its own website — in the wording of the statement, “as a measure going beyond the statutory requirements”. The Tisza party members of the parliamentary committee of inquiry, meanwhile, moved that day for the hearing of former Fidesz MPs Erik Bánki and Lajos Kósa.

The background shows why the present publicity is not self-evident. Miklós Ligeti, legal director of Transparency International, submitted a public-interest data request in July for the 2025 and 2026 contracts. The central bank refused, arguing that the publication obligation under the annex to the act on informational self-determination (Infotv.) does not apply to it, because it is not a budgetary organ. The organisation then, in mid-August, turned to the National Authority for Data Protection and Freedom of Information (NAIH) for legal remedy, relying on the fact that the Constitutional Court had already stated in spring 2016 that the central bank performs a public task and manages exclusively public money, and is therefore obliged to account to the public. The data set now released contains 269 contracts, of which 232 items have a specific sum attached, worth close to 21 billion forints in total; the central bank also released the contracts below five million forints, of which there are roughly eighty. The largest item is the five contracts of 4iG, linked to the name of Gellért Jászai, worth 5.855 billion forints; the second is the communications commission of Lounge Design Kft., part of the business interests of Gyula Balásy, for more than 2.3 billion forints. In the two-odd months before György Matolcsy’s departure some sixty contracts were concluded, the rest fall within the term of the new leadership.

MIAK’s reading: today brought two threads that must be sharply separated from each other. One is that of legal responsibility — here the investigating authority and the prosecution service act, the court decides, a criminal complaint is not in itself evidence, and the parliamentary committee of inquiry neither draws nor may draw a criminal law conclusion. The other thread, more significant from MIAK’s point of view, is the structural fault: that the data on the central bank’s asset management became known following a public-interest data request and a remedy before the authority, as a voluntary undertaking. An institutional transparency system works when publicity is the default state and secrecy is the exception requiring justification. In Hungary this is the other way round today — and that is not the fault of a single leadership but of the structure of the regulation.

Part II — Foundations in the literature

The interpretive frame is given by three sources. The first is the constitutional text in force itself: Article 39 of the Fundamental Law records the requirement of transparent management extending both to national assets and to public money, and expressly classifies the data relating to these as public-interest data. Article 41 pairs central bank independence with personal guarantees — a six-year presidential mandate, appointment by the President of the Republic on the proposal of the Prime Minister — and, together with these, an annual reporting obligation to the National Assembly. In the logic of the text, then, independence is not exemption but autonomy burdened with accountability. The second is Second Treatise of Government by John Locke (seventeenth-century English philosopher, one of the founders of modern constitutional thought), according to which every delegated public power is power exercised in trust, that is, as a fiduciary competence bounded by its purpose — and the trustee cannot invoke its own autonomy against the purpose of the trust. The third is Globalization and Its Discontents by Joseph E. Stiglitz (American economist, Nobel Memorial Prize laureate in economics, one of the developers of the theory of information asymmetry), which describes the pattern in which precisely those financial institutions that demand transparency of others prove to be the least transparent. Together the three sources lead to the same place: central bank autonomy concerns monetary policy, not the publicity of property purchases and communications commissions. 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. The starting point is that central bank independence is a valuable institution worth protecting: the freedom of monetary policy from day-to-day political influence is the result of decades of international experience. The question is not the existence of independence, but its extent — and whether the duty to account attached to it is proportionate to it.

3.1 Raising the publicity of central bank contracts to statutory level (simultaneously with the 2027 budget legislative package)

The National Assembly should supplement the central bank act with a provision bringing all of the central bank’s contracts, whether for consideration or gratuitous, under a publication obligation. Four elements have to be laid down. One: without a value threshold — the present voluntary data release showed precisely that the circle below five million forints also yields an interpretable pattern; without the eighty small contracts the picture would be incomplete. Two: in a form suitable for machine processing, that is, in an open tabular format with a uniform contracting-party identifier, because a list published as an image is formally public but practically impossible to analyse. Three: with a thirty-day deadline from the conclusion of the contract, not as a subsequent quarterly summary — it is timeliness that makes publication an instrument of control. Four: the data set should contain the contracting party, the subject matter, the sum, the duration and the legal basis of the conclusion of the contract. The proposal is a concretisation of MIAK’s programme point A1 (Public money dashboard), and does not touch the autonomy of monetary policy decision-making. Locke’s proposition (see 6.4.2) is directly applicable here: the extent of power exercised in trust is bounded by the purpose of the trust, not by the trustee’s self-interpretation.

3.2 A uniform data disclosure regime for asset management organisations founded from public assets (with effect from 1 January 2027)

The rule should not apply to the central bank alone. It should extend to every foundation, business association and asset management organisation created out of public assets or for the performance of a public task, irrespective of whether it is formally a budgetary organ. The MNB foundation construction became possible precisely because, by the choice of organisational form, it was possible to break free of the publication obligation while the origin of the assets remained unchanged. The essence of the proposal is therefore to tie the obligation to the origin of the funds, not to the organisational form: if the assets derive from public money, the data remain public-interest data, however many legal persons they pass through. This is a direct application of programme point A6 (Strengthening checks and balances), and is in harmony with the quoted requirement of Article 39 of the Fundamental Law (see 6.4.1). Its practical element is a uniform, central publication interface to which the organisations concerned upload in an identical data structure — dispersed disclosure in formats differing from website to website is in itself an obstacle today.

3.3 Separating the work of the committee of inquiry from the criminal proceedings (before the first hearing, laid down in the rules of procedure)

The parliamentary committee of inquiry is an organ of the National Assembly: it uncovers political and institutional responsibility and formulates legislative proposals, but it does not investigate, does not bring charges and does not establish guilt — that is the competence of the investigating authority, the prosecution service and the court. This has to be stated expressly in the committee’s rules of procedure and in all its public communications, because conflating the two threads causes harm in both directions: a political finding anticipating an ongoing criminal procedure makes the committee’s report open to attack, while waiting for the court decision would paralyse for years the legislative work that is the committee’s real task. The success criterion for the committee is therefore not who admitted what at the hearing, but whether the final report contains concrete, textual proposals for legislative amendment on the publication obligation, on the limits of asset management constructions and on the ex post scrutiny of the central bank’s asset management. Alongside A6, the yardstick is given by programme point G19 (Radical transparency in economic decision-making).

The three measures are bound together by a single principle: what is voluntary can be withdrawn. The central bank’s present undertaking is right in substance, and MIAK welcomes it — but it is precisely the kind of act that the next leadership can abolish with a single statement, just as the present one introduced it with a single statement. Institutional transparency becomes resilient when it rests not on the goodwill of the leadership but on a statutory obligation. Stiglitz’s observation (see 6.4.3) warns of exactly this: financial institutions that proclaim transparency tend to be the least transparent in their own operations if nothing compels them to the contrary.

Part IV — Expected effects and risks

Dimension Expected effect Risk
Public finance Central bank procurement becomes comparable; recurring contracting parties and pricing outliers can be demonstrated by analysis The publication obligation may become formal: incomplete data fields, delayed uploading, unanalysable format
Central bank operation The duty to account is strengthened without touching monetary policy, and the legitimacy of independence grows Under overreaching regulation, publicity for the detailed data of market operations would impair the efficiency of implementation — monetary transactions have to be excluded item by item
Legal certainty An obligation tied to the origin of the funds eliminates evasion through organisational form Too broad a definition of the circle concerned may also reach private contractual partners — the boundary between business secrets and public-interest data has to be drawn item by item
Parliamentary control The legislative yield of the committee of inquiry becomes measurable The committee’s slide into the criminal law register damages the credibility of the report and may infringe the procedural rights of those concerned

The main question for consideration is the limit of publicity. The operation of a central bank has elements — open positions in foreign exchange market operations, security procurements, transactions in progress — whose immediate publicity would cause real operational harm. MIAK’s proposal is therefore not “everything, immediately”, but an itemised delimitation: operations falling within the monetary policy toolkit should remain under the present, delayed disclosure regime, while operating expenditure — property, construction, communications, consultancy, IT — should come under full publicity. The proposal tips to the risk side if this delimitation is carried out not by the law but by the institution’s own discretion: then we end up where we started.

Part V — Measurability and summary

5.1 What is worth following? (suggested KPIs)

The performance indicators (KPIs) below will show over twelve to twenty-four months whether the step was substantive or remained a one-off gesture.

  • Completeness of publication: the ratio of the number of contracts published quarterly to the items of operating expenditure appearing in the annual accounts — a suggested target above 95 per cent by the end of 2027.
  • Data quality: the machine processability of the published table — a suggested yardstick that the file should appear in an open tabular format, with a uniform contracting-party identifier and a completed sum field for at least 90 per cent of items.
  • Timeliness: the average number of days between the conclusion of the contract and publication — a suggested target below 30 days.
  • Legislative yield: the number of textual proposals for legislative amendment in the committee of inquiry’s final report, and how many of these had their parliamentary debate started within six months of the adoption of the report.

5.2 Summary

MIAK’s request in a single sentence: the National Assembly should raise the central bank’s voluntary undertaking into a statutory obligation, and extend it to every asset management organisation created out of public assets. This is not a step against the central bank — on the contrary, it is the long-term protection of its independence. Nothing weakens an institution’s autonomy more than the suspicion that it is using that autonomy to avoid accounting; and nothing strengthens it more than accounting becoming an automatic, boring routine.

Two MIAK foundational values are in play here. Transparency, because in today’s situation publicity is an exception that has to be fought for: a civil organisation had to submit a data request, receive a refusal and turn to an authority for it to become public whom the central bank paid out of public money. And accountability, because in the present system the extent of accounting depends on the institution’s own decision — this is a contradiction in terms, since the essence of accountability is precisely that it is not the accounting party that decides how much it shows. MIAK is not talking about personal responsibility, because that is for a court to decide; it is talking about the rule, because it is the rule that will still be working in the next decade.

Part VI — Reasoning and further sources

6.1 The framing of the press by spectrum

The liberal-left band put the ownership and beneficiary side at the centre of the news. The 444.hu article headlined “6 billion to Gellért Jászai, more than 2 billion to a Balásy company – money poured from the MNB led by Mihály Varga to the NER oligarchs” highlighted the concentration of payments — the two interests together account for some 40 per cent of the sum — and reconstructed in detail the legal reasoning behind the refusal of the data request. Telex carried the same data set but with a different emphasis: it stressed that the MNB provided broader information than was requested, and also released the contracts below five million forints. HVG worked up the third thread of the day, György Matolcsy’s video statement. Népszava carried the topic at headline level (headline-level reference only).

The economic band reported both developments in an event-focused way, without evaluation. Portfolio carried the criminal complaint and the quarterly publication undertaking in two separate articles; in the latter the text expressly quotes the MNB’s self-description — “a measure going beyond the statutory requirements” — and lists the antecedents starting from the August stages of the legal dispute. This band takes no position on whether this is a voluntary undertaking or an obligation.

The pro-government and conservative band built its framing on the central bank’s own communication. The Magyar Nemzet piece headlined “Will everything come to light? The central bank has published the data of a mass of contracts” presented the step as the institution’s own transparency effort, and reached the conclusion that the dispute over the interpretation of the law between Transparency International and the central bank had “become moot”. Mandiner, taking over the MNB’s statement verbatim, foregrounded the commitment to responsible and transparent management, and framed the criminal complaint as a logical consequence of the screening report.

The choice of narrative between the bands differs substantively at one point, and this difference is relevant in policy terms: the pro-government band regards the legal dispute as closed because the data have appeared; the liberal-left band holds that the subject of the dispute is not the one-off release of data but the existence of the obligation. MIAK considers this second reading the more precise one, for a regulatory-technical rather than a political reason: a voluntary disclosure does not legally render moot the question whether the disclosure is mandatory.

6.2 Facts and data

Data Value Note
Number of published contracts (after 1 January 2025) 269 444.hu’s figure; Telex wrote of 259 contracts — the difference suggests different filtering of the data set, the order of magnitude is the same
Items with a sum field 232 no value is given for the remaining items
Total contractual amount close to 21 billion HUF since the start of 2025
4iG contracts 5.855 billion HUF, 5 items the largest single contracting party
Lounge Design Kft. (communications) more than 2.3 billion HUF the second largest item
Contracts below five million forints approx. 80 the publication of these was not mandatory
Contracts before György Matolcsy’s departure approx. 60 in a little over two months, until March 2025
Foundation assets covered by the committee of inquiry’s mandate 266 billion HUF + 127 billion HUF the central bank foundation and the foundation of the János Neumann University in Kecskemét, respectively
Cash and securities seized as evidence more than 91.8 billion HUF in May 2026

The source of the data is the press treatment of the contract list released by the central bank, together with the public description of the parliamentary committee of inquiry’s mandate. The proportions do not in themselves prove irregularity — in MIAK’s view the essential finding is that these proportions became visible only now, at the end of a data request procedure, whereas their publication could be a routine task.

6.3 Policy dimensions

  • Transparency and anti-corruption policy (programme points) — restoring the default state of publicity for public money data, eliminating evasion through organisational form (programme point ID: A1, A2, A6);
  • Economy (programme points) — the public reasoning of economic decisions and the recording of the decision-making trail (programme point ID: G19, G1);
  • Administration of justice (background material) — the delimitation of the criminal procedural and the parliamentary fact-finding threads, and the procedural rights of those concerned at committee hearings;
  • Public administration and e-government (programme points) — the uniform, machine-processable publication interface as administrative infrastructure (programme point ID: KI8).

6.4 Literature in detail

6.4.1 National Assembly: Fundamental Law of Hungary

Two provisions of the Fundamental Law together give the legal frame of the present situation, and the relationship between the two is the essential point. According to the official reasoning attached to Article 39, the rule “records […] the requirement of transparent management, extending both to national assets and to public money, guaranteeing at the level of the Fundamental Law that it can be known by the public, including by classifying the data relating to these as public-interest data”. The classification is therefore tied not to the legal status of the managing organisation but to the character of the assets. Article 41, in parallel with this, describes the guarantees of central bank independence, and records the counterweight in the same structure: according to the reasoning, the proposal “gives effect, through the annual reporting obligation, to the responsibility of the Magyar Nemzeti Bank towards the National Assembly”. In the case of the central bank, then, by the logic of the constitutional text, independence and accounting come as a package. In the legal dispute that has just taken place, the MNB’s argument was built on the scope of the annex to the Infotv., that is, on a technical rule at a lower level; the classification under the Fundamental Law stands independently of this — and this is precisely the contradiction that in MIAK’s view has to be resolved by legislation, not by case-by-case data requests.

📖 Source: National Assembly: Fundamental Law of Hungary

6.4.2 John Locke: Second Treatise of Government

Locke’s argument on the nature of delegated public power is still today the most precise description of the difference between autonomy and exemption. In his view even the supreme power is “only a fiduciary power to act for certain ends”, and there remains in the community that gave the trust “a supreme power to remove or alter the legislative, when they find the legislative act contrary to the trust reposed in them” — because “all power given with trust for the attaining an end, being limited by that end”. The essence of the thought is not the withdrawal of power but a rule for interpreting competence: the trustee may not extend its own autonomy beyond the bounds of the purpose of the trust. In the case of central bank independence the purpose of the trust is precisely defined — price stability and the protection of monetary policy from political cycles. Buying a conference centre or awarding a communications commission does not fall within this circle, and therefore the secrecy of the data relating to it cannot be derived from independence. Within this frame the central bank foundation construction is exactly the structural fault Locke describes: autonomy received under a trust was used detached from the purpose of that trust.

📖 Source: John Locke: Second Treatise of Government

6.4.3 Joseph E. Stiglitz: Globalization and Its Discontents

A recurring observation in Stiglitz’s book is that the transparency demanded by financial institutions and their own practice regularly diverge. In his own formulation, he was glad to see the emphasis on transparency at the time of the 1997–98 financial crisis, but was saddened by the hypocrisy that the institutions which demanded it of others were “among the least transparent that I had encountered in public life”. Elsewhere he writes that at the institution he examined “the prevailing culture of secrecy was so strong” that part of the negotiations and agreements were kept even from the staff of the partner institution. The pattern arises not from personal bad faith but from institutional incentives: for an organisation with expert autonomy, publicity is always a cost in the short run, while its benefit is indirect and delayed — which is why, if transparency remains voluntary, it usually underperforms. In the Hungarian central bank case this proposition is directly applicable: the value of the present voluntary undertaking depends not on how well-intentioned it is, but on whether it remains binding for the next leadership too.

📖 Source: Joseph E. Stiglitz: Globalization and Its Discontents

6.5 International comparison

The regulation of central bank accountability in Europe typically solves the problem not by keeping contracts secret but by differentiating publicity. In the practice of the European Central Bank and the national central banks it is established to separate monetary policy operations from institutional operating expenditure: the detailed data of the former appear with a delay or in aggregated form, while the latter — procurement, property, consultancy — remain under the ordinary public procurement and publication regime. The EU public procurement directives also fit this logic: it is not the legal status of the organisation but the subject matter and value of the procurement that determines the extent of publicity. This is the international model for the delimitation contained in point 3.1 of MIAK’s proposal, and at the same time a refutation of the argument that central bank independence would also require the secrecy of operating expenditure — if that were so, the majority of European central banks would be infringing their own independence.

On the institutional side of enforcing document publicity, the Hungarian solution — turning to the data protection authority, then the judicial route — formally corresponds to European practice, but is slow in practice: in the present case the time elapsed from the July data request to the September data release was roughly two months, and the release finally happened not on the basis of an official decision but of a voluntary resolve. This is precisely the situation to which Stiglitz’s observation applies: where enforcing publicity is costly and uncertain, goodwill takes the place of obligation.

Transparency and anti-corruption policy

  • A1 — Public money dashboard
  • A2 — Public procurement transparency
  • A6 — Strengthening checks and balances

Economy

  • G1 — Data-driven budget
  • G19 — Radical transparency in economic decision-making

Public administration and e-government

  • KI8 — Drucker-style efficiency measurement in public administration

Suggested new programme point: Source-based definition of the publication obligation — for the Transparency and anti-corruption policy area: the classification as public-interest data should be tied to the origin of the assets, not to the legal status of the managing organisation.

6.7 List of sources

Press sources (MIAK press monitor, 4 September 2026 — topic 1):

Knowledge base references (specialist books):

  • 📖 National Assembly: Fundamental Law of Hungary
  • 📖 John Locke: Second Treatise of Government
  • 📖 Joseph E. Stiglitz: Globalization and Its Discontents

MIAK internal materials:

  • MIAK policy area: Transparency and anti-corruption policy (programme points; programme point ID: A1, A2, A6)
  • MIAK policy area: Economy (programme points; programme point ID: G1, G19)
  • MIAK policy area: Administration of justice (background material)
  • MIAK policy area: Public administration and e-government (programme points; programme point ID: KI8)
  • MIAK press monitor, 4 September 2026 — topic 1, score: 95/100

Supplementary public data sources:

  • Magyar Nemzeti Bank contract register (on a quarterly basis, according to the September 2026 announcement)
  • Reports of the State Audit Office on the MNB foundations
  • The public-interest data request practice of the National Authority for Data Protection and Freedom of Information

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