Part I — Situation overview

According to public company records, in August the Portuguese financial investor Pedro Vargas, owner of Alpac Capital, was registered at the head of the companies behind the Serbian news televisions N1 and Nova S; the previous directors were removed on the same day. The transaction took place ahead of the necessary regulatory approvals: Luxembourg — where the acquiring vehicle is registered — did not approve the change of control, and competition law questions also remained open in Serbia and in Montenegro. At Luxembourg’s request the European Board for Media Services is already examining the concentration under the EU media freedom regulation (EMFA). All this happened a few weeks before an election: the Serbian President called an early parliamentary election for October, according to the pro-government press for 25 October, while cancelling his rally in Novi Sad. In the preceding week there were clashes between protesters and the police in Užice, in the course of which members of media crews were also assaulted. The Hungarian thread lies in the buyer’s past: according to a reconstruction published in the opinion section of EUobserver, in the 2022 Euronews purchase journalists at Direkt36, Le Monde and Expresso traced 45 million euros back to the state-backed Hungarian Széchenyi Funds. The Portuguese financial supervisor later fined the fund for deficiencies in anti-money-laundering safeguards; and in 2017, by a Hungarian government decision, the management of a fund launched with state Eximbank, OTP and MOL funds went to Alpac Capital; Vargas also sat on the board of 4iG between 2021 and 2025.

Hungarian readers know the antecedents of the story, only so far in a domestic frame. The reshuffling of ownership in the Hungarian media market after 2010 took place largely not through official bans but through sales: the redirection of state advertising spend, access to preferential loans and friendly takeovers together reshaped the structure of the public sphere — without a single decision banning a newspaper. What is now visible in the region is the same method stepping out of its original political frame: the technique takes the form of a market transaction, and therefore sets in motion not media freedom law but competition law and company law — and there the response is slower and harder to see.

MIAK’s reading begins with two delimitations, because without them the topic becomes imprecise. The first: it cannot be claimed that “the Hungarian state bought” the Serbian channels. According to the public facts, the Luxembourg vehicle of a Portuguese fund manager was the buyer; the connection to Hungarian state funds is documented in earlier transactions, while the financing of the present purchase is unknown — and that is precisely the problem. The second: the purchase of media by a Luxembourg investment vehicle is in itself entirely ordinary within the internal market; cross-border ownership is not suspicious. What is out of the ordinary is the sequence: the removal of the directors preceded regulatory approval, and the operation accelerated a few weeks before the election. For MIAK the actual policy question follows from this: not who is buying, but whether the approving authorities learn where the money came from before or after their decision.

Part II — Foundations in the literature

The interpretive frame is given by three sources. Manufacturing Consent by Edward S. Herman and Noam Chomsky (American economist, and linguist and media critic respectively) describes a model of five filters through which news passes before it reaches the audience — and the first and strongest of these is the ownership structure: the size, concentrated ownership, owner wealth and profit orientation of the dominant media firms. It follows that changing the content requires no editorial instruction; a change of owner is enough. Spin Dictators by Sergei Guriev and Daniel Treisman (Russian-born economist and American political scientist respectively) places this mechanism within the toolkit of modern authoritarian systems: in their account today’s leaders — including, named explicitly, with a Hungarian example — typically do not ban privately held media but acquire their goodwill with money, exclusive information and state advertising, and turn to open censorship only when funds run short. And Propaganda by Edward L. Bernays (Austrian-born American public relations practitioner, one of the developers of modern techniques of influence) is the earliest systematic description of how the shaping of the public sphere can also be carried out through apparently independent private actors — for him this is “invisible government”. Together the three sources lead to the same place: if influence takes the form of a market transaction, then the legal toolkit built against censorship does not reach it. 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 in this case Hungary is not an outside observer but an affected party — and this is not a disadvantage but the source of credibility: the Hungarian proposal does not lecture others, it puts on the table data about its own past role.

3.1 Disclosure of the source of financing as a precondition of approval (in the ongoing procedures, immediately)

The Hungarian government should initiate that the Serbian and Montenegrin competition authorities and the Luxembourg financial supervisor require, as a precondition of approving the change of control over media ownership, the disclosure of the actual source of financing of the purchase price and of the beneficial owners — rather than as an ex post check. The legal basis for the request exists: the ownership transparency and media market concentration assessment provisions of the EU media freedom regulation were made precisely for this situation, and the European Board for Media Services is already examining the case. To this Hungary should offer the relevant, lawfully transferable data of the domestic asset tracing now under way — data exchange between authorities already works today through the financial supervisory and anti-money-laundering cooperation channels; no new institution needs to be created. The proposal is a concretisation of programme points A7 (Media pluralism as an institutional guarantee) and A14 (International institutional participation and accountability).

3.2 A statutory prohibition on the use of state funds to acquire media undertakings (in the 2027 spring session)

The National Assembly should adopt a provision excluding state asset management, export credit or state-owned corporate funds — whether directly, through a fund management construction, or via an indirect ownership chain — from being used to finance the acquisition of a stake in a media undertaking. The rule requires three elements. One: the prohibition should be tied to the origin of the funds, not to the direct contractual relationship, otherwise it can be circumvented with a single interposed fund manager. Two: mandatory, public conflict-of-interest screening should extend to the management mandates of state-backed funds, examining also the overlaps between the officers of the manager and those of the portfolio companies — in the present case such an overlap demonstrably existed. Three: breach of the rule should entail not only a sanction but also the reclaiming of the financing. This is not a matter of an ethical recommendation but of a statutory prohibition; the relevant MIAK programme points are A7 and A2. Herman and Chomsky’s proposition of the ownership filter (see 6.4.1) explains precisely why the formal guarantee of editorial independence is not enough: if the owner’s financing is of political origin, the protection of editorial autonomy is an ex post and weak instrument.

3.3 Measuring and publishing annually the cross-border dimension of asset recovery (from the first annual report onwards)

Today we describe the effectiveness of domestic asset recovery work with domestic indicators, while part of the constructions under examination sit in foreign corporate structures from the outset. MIAK proposes that the annual public report on asset recovery should contain a separate chapter on cross-border cases: how many requests affecting foreign jurisdictions were launched, how many received an answer, with what average turnaround time, and how large is the asset value identified in a foreign structure but not yet secured. The figures need not identify individual cases — even in aggregated form they show where the process gets stuck. Publishing the data makes two things possible: at home it makes visible that recovery does not stop at the national border, and outwards it lends credibility to the initiative proposed in point 3.1. MIAK’s programme point A1 prescribes the regular publication of public money data; and KP3 (Transparent foreign policy) prescribes that we give public reasons for our international steps.

The three measures are bound together by a single principle: the market form does not extinguish the public money character. If state funds stand indirectly behind a purchase, then from the point of view of publicity the transaction is not a private matter, however many legal persons it passes through and however many national borders it crosses. This proposition has been a recurring theme in Hungarian domestic politics in recent months; what the present case adds is that the same question also arises across the border — and there the Hungarian side has the role not of accuser but of data provider. Guriev and Treisman’s account (see 6.4.2) warns precisely that the method is at its most effective when it breaches no formal rule at all.

Part IV — Expected effects and risks

Dimension Expected effect Risk
Foreign policy Offering its own data creates a credible, non-lecturing Hungarian position in the enlargement and rule-of-law debates The step burdens relations with the Serbian government in the short term; the initiative has to be pursued through official, not political, channels
Media market Enforcing ownership transparency creates a precedent for future transactions of a similar structure Too broad a regulation may also obstruct legitimate, politically neutral investments — the prohibition has to be tied to the state origin of the funds, not to foreign ownership
Asset recovery Publishing cross-border indicators makes expectations more realistic and the obstacles visible Public partial results may prejudice ongoing procedures — they have to be disclosed in aggregated form that does not identify cases
Domestic politics Separating state funds from media ownership applies equally to every future government Reading the rule as a political instrument weakens its legitimacy, if it is formulated as a targeted measure rather than as a prohibition with retroactive effect

The main question for consideration is the standard of proof. Part of the public facts currently available is journalistic reconstruction, another part is analysis published in an opinion section — the findings on the money flows of earlier transactions rest on the concurring investigations of several newsrooms, while the financing of the present Serbian purchase is unknown. Two things follow from this. One: MIAK cannot claim, and does not claim, that the Serbian purchase was made out of Hungarian public money — there is no such data. The other: precisely for that reason disclosure before approval is warranted, because an ex post examination after the election can no longer restore the structure of the public sphere. The proposal tips to the risk side if we formulate as a political assertion what is a question for the authorities: the right form is a factual question put in the approval procedure, not a public accusation.

Part V — Measurability and summary

5.1 What is worth following? (suggested KPIs)

The performance indicators (KPIs) below will show over six to twenty-four months whether the Hungarian action was substantive.

  • Disclosure condition: whether any of the authorities concerned made the disclosure of the source of financing and of the beneficial owners a condition of approval — yes or no, and when.
  • Data exchange performance: the number of requests addressed by the Hungarian authorities to foreign supervisory and anti-money-laundering bodies and the average response time, published annually.
  • Cross-border asset indicator: whether the annual asset recovery report shows the aggregated value and procedural status of cases affecting foreign jurisdictions.
  • Media ownership transparency at home: how many of the service providers operating on the Hungarian media market comply with full, machine-processable publication of ownership data — the suggested benchmark is the annual measurement of media pluralism monitoring.

5.2 Summary

MIAK’s request in a single sentence: the Hungarian government should initiate, through official channels, that disclosure of the origin of the money be a precondition of approval for media ownership changes, and should offer for this its own data now coming to light — while at home it should exclude by law the acquisition of a media undertaking out of state asset management or export credit funds. The two work together: an external initiative is credible only if it is backed at home by a rule rather than a promise.

Two MIAK foundational values are in play here. Transparency, because the case fails precisely at the point where publicity ought to work: the approving authorities today learn where the money came from after their decision, if they learn it at all. And universal representation, because the structure of a country’s public sphere is not merely a private matter for those who live there: if independent news provision ceases next door, Hungarian public opinion too receives less verifiable information about the region — media pluralism is therefore, in MIAK’s reading, not a cultural but an institutional question, and it does not stop at the national border.

Part VI — Reasoning and further sources

6.1 The framing of the press by spectrum

The Brussels specialist press connected the Hungarian thread with the EU regulatory toolkit. The analysis published in EUobserver’s opinion section — an important formal note: this is not investigative reporting but an opinion piece built on earlier investigations carried out by several newsrooms — carries the proposition that the media takeover method has detached itself from the political actor who developed it, and has become an independent, exportable technique. It closes with a concrete regulatory proposal: the Luxembourg, Serbian and Montenegrin authorities should withhold approval until the source of financing is disclosed, and the Hungarian authorities should ask what became of the public money. This band therefore objects not to the fact of the takeover but to the procedural sequence.

The European public policy band carried the sequence of events. Euractiv reported on the Serbian President’s cancelled Novi Sad rally and the calling of the October election, noting that the pro-government press gave 25 October as the date, and that analysts expect a referendum-like mood between the governing party and the student movement. The same band also carried the announcement about the spyware targeting.

The regional investigative band worked up the surveillance thread in detail. According to Balkan Insight’s report, a civil organisation spoke of at least fourteen targeted persons, while the Citizen Lab research group of the University of Toronto confirmed in at least one case the Pegasus infection of a student movement member’s phone; both Serbian intelligence and the President denied involvement. This band is the only one that treats the technical proof of the case item by item — and the distinction matters: the fact of the infection is confirmed by expert examination, the identification of the perpetrator is not.

In the Hungarian press the topic did not appear as a separate item alongside the day’s domestic political focus. That in itself is a signal: a case in which an actor linked to Hungarian state funds features in the pre-election media reshuffle of a neighbouring country remained essentially invisible in the domestic public sphere.

6.2 Facts and data

Fact Data Nature of the source
The Serbian news televisions concerned N1, Nova S company data, press report
Registered seat of the acquiring vehicle Luxembourg company data
Timing of the change of directors ahead of the regulatory approvals, in August press report
EU procedure the European Board for Media Services is examining the concentration at Luxembourg’s request press report
Sum traced in the 2022 Euronews transaction 45 million euros, to funds with Hungarian state backing concurring investigations of three newsrooms
Portuguese supervisory sanction fine imposed for deficiencies in anti-money-laundering safeguards press report
Fund management mandate with Hungarian state backing 2017, a fund launched by a state export credit institution, a commercial bank and an energy company press report
Board membership at a Hungarian telecommunications company 2021–2025 company data, press report
Announced date of the Serbian election 25 October report of the pro-government Serbian press
Spyware targeting at least 14 persons concerned in 2026; at least one confirmed Pegasus infection civil organisation’s announcement, and expert confirmation respectively
Starting point of the wave of protests the 2024 collapse of the railway station canopy in Novi Sad, 16 fatalities press report

The third column of the table is deliberate. The level of proof of the facts differs in this case: company data, the concurring investigations of several newsrooms, a one-sided announcement and expert confirmation are mixed together. MIAK’s proposals rest exclusively on the first two categories; there is no public data on the financing of the present Serbian purchase, and the blog does not claim any.

6.3 Policy dimensions

  • Transparency and anti-corruption policy (programme points) — measuring media ownership concentration as an institutional guarantee, conflict-of-interest screening of state-backed fund management mandates (programme point ID: A7, A2, A9, A14);
  • Culture (programme points) — public measurement of media market concentration and of the ownership structure of the advertising market (programme point ID: KU2);
  • Foreign policy (programme points) — supporting regional institutional resilience and issue-based coalition building for the implementation of EU media regulation (programme point ID: KP10, KP17, KP3);
  • Administration of justice (background material) — the legal instruments and limits of cross-border asset tracing.

6.4 Literature in detail

The essence of Herman and Chomsky’s model is that news acquires its final shape not through a single decision but through a series of filters. In their own summary, the book “traces the routes by which money and power are able to filter out the news fit to print, marginalise dissent, and allow the government and dominant private interests to get their messages across to the public”; the first of the five filters is “the size, concentrated ownership, owner wealth, and profit orientation of the dominant mass-media firms”. The explanatory power of the model here lies in the fact that it assumes no bad-faith editorial instruction: a change of owner in itself changes what counts as a commercially acceptable risk in a newsroom — and from the owner’s point of view a critical report is always a risk. In the Serbian case this proposition is directly applicable: N1 and Nova S were uncomfortable from the government’s point of view because they broadcast the protests and gave a platform to the opposition; in friendly ownership hands the same capacity can be turned in the opposite direction, without a single prohibiting decision. The same filter logic also explains why declaring editorial independence is not a sufficient answer: the new owner’s statement about impartial information provision is formally impeccable, but the filter does not operate at the level of statements.

📖 Source: Edward S. Herman – Noam Chomsky: Manufacturing Consent

6.4.2 Guriev and Treisman: Spin Dictators

Guriev and Treisman’s volume is about how modern authoritarian leaders have exchanged violent repression for information manipulation — and one of the central instruments of this is acquiring media instead of banning it. It is particularly instructive for Hungarian readers that the authors also discuss the Hungarian example by name: in their account certain leaders “bribed the owners of privately held media outlets with money, exclusive information and state advertising”. To this they add the observation that is key from the point of view of the present situation: “when spin dictators are short of money, however, they set about censoring informed citizens” — that is, buying up and banning are not two separate systems but two operating modes of the same strategy, depending on cost. Two conclusions follow from this for MIAK. One is that protecting media pluralism requires financial and competition law instruments rather than free speech ones: where influence travels through purchase, ownership transparency is the effective antidote. The other is that, in the authors’ account, the technique belongs to the system rather than to the person — so it is not surprising that it outlives the political arrangement in which it developed, and can be applied in another country, with other actors.

📖 Source: Sergei Guriev – Daniel Treisman: Spin Dictators

6.4.3 Edward L. Bernays: Propaganda

Bernays’s 1928 text is most interesting today because the author did not want to expose the mechanism but wrote a user’s manual for it — which is why he puts it more openly than any of his critics. His central claim is that in modern society the shaping of public opinion is necessarily carried out by a narrow circle: “we have consented to let an invisible government sift the data and high-spot the outstanding issues so that our field of choice shall be narrowed to practical proportions. From our leaders and the media they use to reach the public, we accept the evidence and the demarcation of issues.” An important element of the formulation is that Bernays attributes this role not to state officials but to private actors — advertisers, consultants, owners. This is precisely the structural core of today’s case: influence does not appear in the form of an official act but as an acquisition of ownership, and for that reason it falls under a legal assessment that protects competition and the movement of capital rather than the structure of the public sphere. MIAK’s proposal therefore places the regulatory intervention exactly where the mechanism actually operates: at the disclosure of the source of the financing and of the beneficial owner, before approval.

📖 Source: Edward L. Bernays: Propaganda

6.5 International comparison

The EU media freedom regulation was made precisely for cases like this: it prescribes ownership transparency requirements for media service providers, and gives a procedural frame for assessing media market concentrations when these may affect media pluralism and editorial independence. One of the openly stated reasons for the regulation’s creation was Hungarian media market experience — in the present situation this is not an embarrassment for the Hungarian side but an argument: few countries have more direct experience of how the ownership reshuffling of a public sphere takes place through a series of market transactions.

The practical instruments are already well established in other fields. Beneficial ownership registers under anti-money-laundering regulation, data exchange between financial supervisors and capital market authorisation procedures are all capable of clarifying the financing background of a transaction before approval — the difficulty is not the absence of instruments but that in media transactions these are rarely connected with the pluralism perspective. In the case of candidate countries the enlargement conditionality framework provides a further handhold: media pluralism and freedom of expression are part of the rule-of-law chapter, so the question is not outside interference but the accession process’s own yardstick. This is the point at which, in MIAK’s view, Hungarian foreign policy has to decide: whether it carries the Serbian relationship forward according to the logic of earlier regime solidarity or of the enlargement conditionality framework — in this case the two cannot be reconciled.

Transparency and anti-corruption policy

  • A2 — Public procurement transparency
  • A7 — Media pluralism as an institutional guarantee
  • A9 — Spin dictatorship prevention index
  • A14 — International institutional participation and accountability
  • A1 — Public money dashboard

Culture

  • KU2 — Media pluralism monitoring

Foreign policy

  • KP3 — Transparent foreign policy
  • KP10 — Regional resilience building
  • KP17 — Issue-based coalition building in the EU

Suggested new programme point: Separation of state funds and media ownership — for the Transparency and anti-corruption policy area: a statutory prohibition on state asset management, export credit or state corporate funds — directly or through a fund management construction — financing the acquisition of a stake in a media undertaking.

6.7 List of sources

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

Knowledge base references (specialist books):

  • 📖 Edward S. Herman – Noam Chomsky: Manufacturing Consent
  • 📖 Sergei Guriev – Daniel Treisman: Spin Dictators
  • 📖 Edward L. Bernays: Propaganda

MIAK internal materials:

  • MIAK policy area: Transparency and anti-corruption policy (programme points; programme point ID: A7, A2, A9, A14)
  • MIAK policy area: Culture (programme points; programme point ID: KU2)
  • MIAK policy area: Foreign policy (programme points; programme point ID: KP3, KP10, KP17)
  • MIAK policy area: Administration of justice (background material)
  • MIAK foreign press monitor, 4 September 2026 — topic 1, score: 89/100

Supplementary public data sources:

  • The Serbia and Hungary chapters of the Media Pluralism Monitor (European University Institute)
  • Reporters Without Borders press freedom index
  • The registers of the Serbian competition authority and the Luxembourg financial supervisor
  • The media market concentration assessment provisions of the EU media freedom regulation

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