Part I — Situation overview

On 7 September the calling to account of cases affecting state assets started or continued along four separate threads. István Kapitány, the minister for the economy and energy, announced that the ministry is filing a criminal complaint against an unknown perpetrator on suspicion of misappropriation of funds and abuse of office in connection with the earlier financing of Waberer’s. The Hungarian Development Bank (MFB) subscribed to the company’s bonds to the value of 111 million euros in 2022 and a further 100 million euros in 2026 — some 77 billion forints in all. In the second round, according to the minister, below its own cost of funds, with the difference financed through the interest equalisation system funded from the budget. In the minister’s view the construction may over the full term impose a burden of up to 10 billion forints on the budget. The company rejected in a statement every assertion that it had acted unlawfully or received an unlawful advantage, and indicated: it does not know the content of the complaint, the issues took place in compliance with capital market rules, and it used the funds for purposes announced in advance — fleet renewal, then a development programme.

On the same day the National Tax and Customs Administration (NAV) detained two further persons in the case surrounding the National Cultural Fund (NKA), worth more than 17 billion forints. On the suspicion, a company applied for support of more than 80 million forints for a documentary film, then covered the production, not completed by the April accounting deadline, with invoices of untrue content. At the Budapest Environs Regional Court the corruption trial with 54 defendants, affecting some 25 billion forints and more than a hundred EU tenders, continued after ten months. The new leadership of the Hungarian National Bank (MNB) filed a criminal complaint over the impairment of five properties, on suspicion of misappropriation of funds, negligent handling of funds, fraud and abuse of office. György Matolcsy, the former central bank governor, responded in a video, saying that he “will face all the investigations”. He also took the position that the assets that passed into the central bank foundations remained public money, and that their scrutiny is therefore the task of the State Audit Office.

MIAK’s reading: the four threads are grave each on its own, but together they pose another question. Accountability will be successful if the ratio of announcements to final judgments improves — not if the number of announcements grows. The counter-example was provided by the same day: according to HVG’s report the police for the second time terminated the investigation into the property sales involving the Hungarian Chamber of Court Bailiffs, entailing a loss of assets on the scale of hundreds of millions. The first reasoning held that the loss of assets is not a criminal offence; the second that it could even be so, but on the basis of the available evidence it cannot be established. A case uncovered, a consequence not following. The public law frame has to be held precisely here: a ministerial criminal complaint is not a procedural decision but the initiation of one — the fate of the proceedings is decided by the investigating authority and the prosecution service, not by the ministry; and the prosecution service is not part of the administration of justice but an autonomous constitutional body. The State Audit Office likewise audits and reports, but does not impose sanctions. This is not a formality: the credibility of accountability stands or falls on whether the process runs its course according to its own rules.

Part II — Foundations in the literature

Today poses three questions, and there is a classic answer to all three. Robert Klitgaard, the American economist and one of the founders of the economic analysis of corruption, sets out in his work Controlling Corruption the formula that has since become the starting point of the field: corruption flourishes where a monopoly position and discretionary power meet an absence of accountability. In MFB lending precisely these three elements stand together, since what was at issue was a state resource assessed case by case and without a competitor. At the same time Klitgaard does not deny the role of large, spectacular cases: at the establishment of the Hong Kong anti-corruption commission in 1974 the strategic question was precisely that the commission’s credibility required a few “big fish”, for otherwise in the eyes of the system it turns into the persecution of the little people. Susan Rose-Ackerman, the American lawyer-economist and the other defining figure of corruption research, adds in her volume Corruption and Government the most important qualification: structural reform, and not criminal law, is the primary instrument. An anti-corruption campaign that does not reduce the underlying incentives easily turns into a witch hunt, and is aimed disproportionately at the political opponents of the day. Lee Kuan Yew, Singapore’s first prime minister, names the third condition in his memoir From Third World to First: accountability works if it is applied without exception, to one’s own camp as well. 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.

3.1 A public case-status register for proceedings affecting public assets (within 90 days)

MIAK proposes that within ninety days a public, machine-readable register be set up that follows the status of proceedings in cases affecting public assets with a value above one billion forints. The register should show five statuses per case: complaint or investigation launched ex officio; investigation in progress; indictment; final judgment; the assets actually recovered, in forints. The data should be published on the basis of data supplied by the acting authorities, respecting the presumption of innocence — in the phase before indictment anonymised, only by subject matter and amount. The aim is not a public pillory but measurability: today we cannot say what percentage of announcements turn into indictments, and how many of those into final judgments. Without this figure the debate about accountability remains a matter of belief. The proposal builds on the data logic of MIAK’s programme point A1 (public money dashboard) and on the court transparency module of programme point I1; the latter in any case prescribes public tracking of turnaround times by case type and of appeal rates. In Klitgaard’s frame (see 6.4.1) this strengthens the factor of accountability — the single element that appears in the formula with a negative sign.

3.2 A procedural capacity expansion plan for large asset cases (by the submission of the 2027 budget)

The size of the cases now running is not that of ordinary criminal cases. In the trial concerning 25 billion forints the investigation examined more than 300 tenders from the period between 2015 and 2022, the documentation runs to 100,000–120,000 pages, the indictment alone is some 400 pages — and the court’s IT system froze when they tried to upload the material. The questioning of the first defendant continued after a break of ten months. MIAK therefore proposes that by the submission of the 2027 budget a public capacity plan be prepared quantifying three items: (1) how many specialised investigator, prosecutor and judicial posts are needed in the economic and corruption branch alongside the present caseload; (2) what the cost is of the IT development needed to handle cases with large volumes of documents; (3) what forensic expert capacity — auditing, property valuation, IT — is available, and how much is missing. Without the plan, growth in the number of announcements does not speed the system up but slows it down: incoming cases pile up, the risk of limitation grows, and the public will attribute the delay to political intent. The proposal is connected to the turnaround-time targets of programme point I1 and to the establishment schedule of A10 (independent corruption investigation authority).

3.3 Narrowing the space for discretion in state development lending (by the adoption of the next MFB strategy)

Irrespective of the facts of the Waberer’s case — on which the investigating authority and the prosecution service will decide — MIAK formulates a regulatory question: why could it be a matter of individual discretion at all that the state development bank should subscribe to the bond of a competitive market player below its own cost of funds, with the budget bearing the difference. MIAK proposes that by the adoption of the next MFB strategy, recourse to the interest equalisation system be tied to a public eligibility rule fixed in advance: (1) in which sectors and in connection with which public policy objective it may be used; (2) what the upper limit of the aid content is per transaction and per beneficiary; (3) whether prior screening of the ultimate ownership structure and of relations with politically exposed persons is compulsory. Programme point G10 supplements this from the institutional side: half of the MFB’s board should be independent experts, with a five-year mandate, and lending should remain market-based with a longer term rather than at a preferential interest rate. And the rent-seeking index of programme point G6 makes measurable the systemic question of in which sectors regulation grants a privileged market position.

The three proposals are bound together by the same principle: accountability is not an event but a process. The case-status register shows where the process stands; the capacity plan ensures that the process is able to run its course; and narrowing the lending rule reduces the number of cases for which accounting will later have to be demanded. The order matters: the third is on its own worth as much as the first two together, because an abuse that has not happened carries no procedural cost.

Part IV — Expected effects and risks

Dimension Expected effect Risk
Transparency The case-status register makes the complaint-to-judgment conversion measurable for the first time; the eligibility rules of state lending reduce the space for case-by-case assessment The publicity of status data in the phase before indictment may violate the presumption of innocence if it is not anonymised; the register may itself turn into a political scoreboard
Justice The capacity plan quantifies the bottleneck invisible today: the expert and IT background; shorter turnaround times reduce the risk of limitation Capacity expansion is expensive and slow; a rapid growth in the number of announcements increases congestion in the short run, which may appear as a failure of the system
Economy A predictable eligibility rule for state development lending reduces the competition-distorting effect of state aid and improves the quality of the loan portfolio A stricter rule may also slow financing genuinely serving public policy aims; uncertainty among market players may temporarily grow because of the proceedings in progress

The main tension of the package runs between speed and procedural cleanliness. The public expects a quick result, while criminal proceedings are slow — and it is precisely their slowness that provides their guarantees. The proposal tips towards the risk side if the register makes the number of complaints, rather than the final judgment, the yardstick of result: then the system’s incentive becomes the announcement, not the proof. MIAK therefore proposes that the register’s principal indicator should not be the number of open cases but the conversion rate and the sum of assets recovered. The second question for consideration is the relationship between publicity and personality rights: anonymisation in the phase before indictment reduces the news value of the register, but without it the instrument would violate precisely the rule-of-law standard on whose protection it relies. The third is that of the lending rule: every tightening also takes away room for manoeuvre, and in a year burdened with power plant outages and industrial transition the role of the development bank grows rather than shrinks — which is why MIAK proposes an eligibility rule and not a ceiling on amounts.

Part V — Measurability and summary

5.1 What is worth following? (suggested KPIs)

MIAK proposes four performance indicators (KPIs, in full: Key Performance Indicators) from which it will be visible in 12 and 24 months whether accountability has brought a policy result:

  • The complaint-to-indictment conversion rate: in what percentage of complaints filed in cases affecting public assets above one billion forints an indictment was brought within 18 months. It is worth following because this figure is not known today, and without it the size of the “wave” cannot be interpreted.
  • The sum of assets actually recovered: in forints, annually, from cases closed with final effect. The suggested reference point is the combined asset value of the cases in progress.
  • The average court turnaround time of large asset cases: by the yardstick of programme point I1. The present example — a ten-month break between two hearing phases — shows that the bottleneck is not at the investigation stage.
  • The proportion of terminated investigations and the reasons: with a separate breakdown of terminations relying on the lack of proof. The case involving the bailiffs’ chamber indicates that this proportion is in itself policy information: if it is high, the problem lies with the means of proof and with expert capacity.

5.2 Summary

MIAK’s request in a single sentence: let the measure of accountability be not the number of criminal complaints but final judgments and the assets recovered — and for this let there be a public register, sufficient procedural capacity and a narrower space for discretion in state lending. Concretely: ninety days for the case-status register, a capacity plan by the submission of the 2027 budget, and a public eligibility rule for the interest equalisation system by the next MFB strategy.

Two MIAK foundational values are in play here. One is accountability, but not in the sense in which everyday political language uses it: this is not about demanding that people be held responsible, but about the process being traceable and open to being called to account afterwards — including where proceedings end in termination, and the reason for that is public. The other is being ideology-free: MIAK applies to today’s four cases the same yardstick it applied to the cases of the previous government, and will apply the same to the present government’s own cases. This is not neutrality towards the facts; it means that procedural guarantees do not depend on who stands on the other side of the proceedings. Whoever gives this up today for the sake of speed gives up their own protection tomorrow.

Part VI — Reasoning and further sources

6.1 The framing of the press by spectrum

The liberal-left band carried the four threads separately from one another, documenting case by case. In the Waberer’s case Telex immediately placed the company’s rebuttal alongside the minister’s announcement, in a separate article — this is the editorial decision that frames the news as a procedural situation and not as a judgment. On the NKA thread 444.hu gave the most detailed prior history: from the case becoming public in April 2026, through the June arrests, to the seizure affecting Fidesz servers that was later classified as irregular — the framing here is that of systemic character, that is, that the individual case is part of a larger pattern of support. In its report on the 25 billion trial the same paper pushed the emphasis towards the procedural obstacles: the removal of the defendant from the courtroom, the disputed circumstances of the appointment of defence counsel and the unmanageable size of the documentation entered the text, not the facts alleged in the indictment.

The economic band put the market consequence in focus: on the Waberer’s news Portfolio put the six-month low of the share price in the headline, and on the NKA thread the sentencing range. This framing brings in the consideration that is missing from the other two bands: accountability announcements have an immediate, measurable market effect, which is in itself an argument for discipline in communication.

The conservative band did not pass over the cases in silence, but carried them with different weighting. On Waberer’s, Magyar Nemzet put the company’s answer in the headline, and on the NKA thread used a fact-reporting tone. Mandiner carried the MNB thread in the most detail, and — unlike the other papers — gave space to the former central bank governor’s full argument, including the position that the central bank foundation assets remained public money, and that their examination is therefore within the competence of the State Audit Office. This is a substantive professional consideration, and by MIAK’s yardstick of being ideology-free it does not become less so because it is formulated by the person concerned. The public law clarification nonetheless belongs here: the State Audit Office audits and reports, but does not impose sanctions and does not conduct criminal proceedings — the two instruments may run in parallel, neither substitutes for the other.

6.2 Facts and data

Data Value Source
Waberer’s bonds subscribed by MFB 2022: 111 million EUR; 2026: 100 million EUR — some 77 billion HUF in all Telex, 24.hu, 7 September 2026
The estimated budgetary burden of the construction over the term up to 10 billion HUF (according to the minister’s statement) Telex, 24.hu, 7 September 2026
The subject of the suspicion in the complaint misappropriation of funds and abuse of office, against an unknown perpetrator Telex, 7 September 2026
The full scale examined in the NKA case 1,079 funding decisions, more than 17 billion HUF 444.hu, 7 September 2026
The subject of the detention on 7 September more than 80 million HUF of support for a documentary film that was not completed Portfolio, Telex, 7 September 2026
The expected sentencing range on the NKA thread 5–15 years’ imprisonment (budget fraud, use of a false private document) Portfolio, 7 September 2026
The size of the corruption trial 54 defendants, some 25 billion HUF, 108 EU-funded and 8 domestically funded tenders 444.hu, 7 September 2026
The documentation of the trial 100,000–120,000 pages; the indictment some 400 pages; the period examined 2015–2022, more than 300 tenders 444.hu, 7 September 2026
The subject of the MNB complaint the impairment of five properties; suspicion of misappropriation of funds, negligent handling of funds, fraud, abuse of office Mandiner, 7 September 2026
Earlier MNB complaint over the renovation of the headquarters, in October 2025; the proceedings are at the investigation stage Mandiner, 7 September 2026
The case involving the bailiffs’ chamber the sale of two properties in the autumn of 2021; the Váci út property sold for 142 million HUF, the expert estimate was 199.5 million HUF HVG, 7 September 2026
The outcome of the investigation in the same case terminated for the second time, this time relying on the lack of proof HVG, 7 September 2026

One item in the table requires a separate note: the budgetary burden of 10 billion forints in the Waberer’s construction is an estimate contained in the ministerial announcement, not an official finding — clarifying the extent of the actual financial detriment is precisely the subject of the proceedings. In the company’s position the issues took place in compliance with capital market rules.

6.3 Policy dimensions

  • Transparency and anti-corruption policy (programme points) — the case-status register and the institutional background: A1 (public money dashboard) provides the data infrastructure, A10 (independent corruption investigation authority) the organisational frame, and A3 (machine processability of asset declarations) the instrument of scrutiny that is missing from today’s read-only asset declarations;
  • Justice (programme points) — procedural capacity and turnaround time: the indicators of I1 (court transparency) provide the basis of the capacity plan, and I3 (legislative impact assessment) the subsequent evaluation of the asset recovery rules;
  • Economy (programme points) — the rule-boundness of state lending: G6 (programme against rent-seeking and regulatory capture) and G10 (state development bank) together provide the background in principle of the third proposal.

6.4 Literature in detail

6.4.1 Robert Klitgaard: Controlling Corruption

Klitgaard sums up the structural conditions of corruption in a single relation, which has since become the basic formula of the field:

“CORRUPTION = MONOPOLY + DISCRETION − ACCOUNTABILITY”

The author adds that corruption flourishes where a monopoly position and discretionary power meet an absence of accountability; the rule that creates a monopoly itself becomes the instrument of corruption, and an over-complex rule grants the official actual discretionary power by the fact that the client does not understand it.

At the same time Klitgaard does not regard large, spectacular cases as superfluous. In his analysis of the establishment of the Hong Kong anti-corruption commission in 1974 he addresses separately the fact that the head of the new organisation needed quick successes for strategic reasons too, and with high-ranking persons involved — because the public measures the effectiveness of the commission by the status of those it brings proceedings against. And speaking of the Singapore anti-corruption bureau he highlights that the bureau works because it demonstrated that it has the political weight to pursue big cases and very small ones simultaneously — from ministers through lawyers to postal employees.

In today’s Hungarian situation this duality is the essence. On Klitgaard’s reading the four cases running with wide publicity are legitimate and necessary — credibility cannot be built without them. But the other two terms of the formula do not move because of this: the monopoly position of MFB lending and the discretionary space of an individual interest equalisation decision remain just the same if a judgment is delivered in the individual case. MIAK’s third proposal — the eligibility rule — narrows precisely the discretion term, and the case-status register increases the accountability term.

📖 Source: Robert Klitgaard: Controlling Corruption

6.4.2 Susan Rose-Ackerman: Corruption and Government

Rose-Ackerman puts the elements of anti-corruption strategy in order, and the order is itself the claim:

“Structural reform should be the first line of attack in an anti-corruption campaign. If a public programme serves no legitimate public purpose, the bottlenecks and constraints it creates do nothing but create opportunities for corruption. Here the solution is elimination, not reform.”

The author regards criminal law as the second, not the first element of the strategy, and adds: anti-corruption policy can never aim at complete probity, because the absolutist approach builds constraints so rigid and cumbersome that they end up increasing the incentives for corruption. The aim is rather to isolate the systems that cause the greatest harm, and to organise deterrence so that the marginal cost of corruption rises.

She also has a warning that bears directly on today’s situation: reformers must not respond to scandals merely by punishing the guilty, for otherwise anti-corruption campaigns easily turn into witch hunts aimed disproportionately at the political opponents of the system. In Rose-Ackerman’s view a scandal is primarily an occasion: an occasion to win support for institutional changes that are not in themselves spectacular.

This is the sentence on which MIAK’s package of proposals is built. The four threads of 7 September are precisely such an occasion — but they become a policy result only if the attention of the public can be turned towards the case-status register, the capacity plan and the lending rule, that is, towards the steps out of which no front page can be made.

📖 Source: Susan Rose-Ackerman: Corruption and Government

6.4.3 Lee Kuan Yew: From Third World to First

Lee Kuan Yew, Singapore’s first prime minister, describes anti-corruption policy not as a programme but as a basic condition of governance, and MIAK’s programme point A10 is likewise built on the model of the bureau he created. The key sentence of the memoir is about the absence of exceptions:

“It is easy to begin with high moral standards, but difficult to live up to them unless the leaders are strong enough to deal with all transgressors, without exception.”

In practical implementation Lee regards two elements as decisive: the bureau’s direct subordination to the head of government, alongside operational independence, and the verifiability of financial position — in Singapore property, motor vehicle and shareholding ownership is registered, and public officials make regular asset declarations whose data can be cross-checked.

The Hungarian lesson is twofold. On the one hand the test of the absence of exceptions is only now beginning: the credibility of accountability will be decided not by the cases of the previous government but by the first case that touches the present government’s own circle. On the other hand the question of comparability points to a concrete gap: the news about Péter Polt’s asset declaration became news on this day precisely because an asset declaration is an event, not continuously analysable data. The machine-readable, automatically comparable asset declaration system of programme point A3 would eliminate exactly this difference.

📖 Source: Lee Kuan Yew: From Third World to First

6.5 International comparison

Case-status tracking is not a theoretical proposal. The annual report of the European Public Prosecutor’s Office (EPPO) publishes its results broken down by case numbers, indictment rate, assets frozen and confiscation awarded, by member state too — that is, the set of indicators MIAK proposes for domestic cases already works at Union level. The European Anti-Fraud Office (OLAF) follows a similar logic: its reports treat separately the number of investigations closed and the sums actually recovered in their wake, and the gap between the two is in itself policy information.

The Hong Kong and the Singapore models yield two different lessons. In Hong Kong the trigger for creating the anti-corruption commission was a concrete case: the unexplained wealth of a senior police officer, then his flight — and the public outrage that arose from the “big fish” having escaped. The commission’s success depended on its quickly demonstrating that the power to freeze assets and to seize documents and travel papers works against high-ranking persons too. In Singapore, by contrast, the system was built not on individual cases but on continuous data matching: linking the ownership registers and the regular asset declarations made scrutiny routine.

The Hungarian situation can learn from both. The present cases resemble the Hong Kong starting point — big cases, wide publicity, credibility still under construction. For a lasting result, however, the Singaporean element is missing: machine-readable, automatically comparable asset and ownership data, without which every case remains an individual investigative achievement. This difference explains why MIAK proposes a register and a data infrastructure alongside the announcements, rather than further announcements.

Transparency and anti-corruption policy

  • A1 — Public money dashboard
  • A3 — Publicity of asset declarations
  • A5 — Whistleblower system
  • A10 — Independent Corruption Investigation Authority

Justice

  • I1 — Court transparency
  • I3 — Legislative impact assessment

Economy

  • G6 — Programme against rent-seeking and regulatory capture
  • G10 — State development bank

Suggested new programme point: A case-status register for proceedings affecting public assets — for the Transparency and anti-corruption policy area: public, machine-readable status tracking from the criminal complaint to the assets recovered, anonymised in the phase before indictment.

6.7 List of sources

Press sources (MIAK press monitor, 8 September 2026 — topic 2):

Knowledge base references (specialist books):

  • 📖 Robert Klitgaard: Controlling Corruption
  • 📖 Susan Rose-Ackerman: Corruption and Government
  • 📖 Lee Kuan Yew: From Third World to First

MIAK internal materials:

  • MIAK policy area: Transparency and anti-corruption policy (programme points; programme point ID: A1, A3, A5, A10)
  • MIAK policy area: Justice (programme points; programme point ID: I1, I3)
  • MIAK policy area: Economy (programme points; programme point ID: G6, G10)
  • MIAK press monitor, 8 September 2026 — topic 2, score: 94/100

Supplementary public data sources:

  • European Public Prosecutor’s Office (EPPO) annual report; OLAF annual report
  • Transparency International Corruption Perceptions Index; World Bank Worldwide Governance Indicators
  • The Hungarian chapter of the European Commission’s rule of law report
  • The collection of anonymised court decisions (birosag.hu)

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