Part I — Situation overview

On 3–4 October 2026 the Government held a two-day off-site meeting in Erdőbénye. According to a Facebook post on 3 October by László Gajdos, the minister responsible for the living environment, the draft climate law was also on the agenda (Portfolio, HVG). The minister called the legislation the “bible” of domestic environmental protection. He named as its primary aims retaining water resources, saving lakes that are drying up and restoring natural habitats. The Government would like to submit the draft to the National Assembly this year; the law is adopted by the National Assembly. According to the minister, civil society organisations were involved, and a “public consultation” also took place in September. Portfolio put this expression in quotation marks. According to the paper, the formal consultation stage could not even have started, because the official draft had not been published. A few days earlier nearly 200 civil society organisations had proposed that they be given at least four weeks to comment instead of the minimum 8 days. In the same week, on 1 October, the level of the Danube on the Budapest gauge sank to a historic low of −1 centimetre. The next day Népszava was already reporting −2 centimetres, and the General Directorate of Water Management (OVF) forecast −8 centimetres for the weekend (24.hu).

In July MIAK already asked for accountable adaptation targets in the climate law. In August it proposed a national water-balance dashboard and an ex-post impact assessment of the Paks bed sill. On drought damage it asked for a budget line and an agricultural damage data platform, and in September for rule-based damage relief. The new element now is the legislative moment. The climate law is no longer a distant plan but an item on the government meeting’s agenda, with the intention of submission. It is now being decided by what procedure and with what content the draft goes before parliament.

MIAK’s reading: water retention as the main statutory aim is the right direction. The agricultural, energy and municipal consequences of this year’s drought stem from the same shortage. But a law becomes accountable where it lays down numbers, responsible parties and deadlines. If the draft goes before the National Assembly without public debate and with general aims, the “bible” will remain symbolic. The four-week consultation is therefore not a delay. It is the only point at which the data of farmers, local governments and the water-management profession can still be built into the text.

Part II — Foundations in the literature

The topic gets an interpretive framework from three classic works. Nicholas Stern, British economist and former chief economist of the World Bank, argues in his 2006 report on the economics of climate change commissioned by the British government (The Economics of Climate Change — The Stern Review) that adaptation is held back by market failures. The most important of these is the lack of information about the future climate. It is therefore the state’s task to provide high-quality climate information and a long-term policy framework. This is a direct argument for a law prescribing numerical targets and an annual report. Elinor Ostrom, American political scientist, winner of the 2009 Nobel Memorial Prize in Economics and researcher of common-pool resources, shows in her work Governing the Commons, through the example of Californian groundwater basins and Spanish irrigation communities, that water users are themselves capable of creating lasting rules if everyone receives accurate, regular data on the state of the water. In his work Democracy in America (1835–40), the French political thinker Alexis de Tocqueville regards local community assemblies as the school of liberty. This is the conceptual basis of broad public consultation and of local water forums. The detailed treatment of the literature — by author, with quotations — is in section 6.4 Literature in detail.

Part III — MIAK’s concrete proposal

MIAK proposes three measurable steps. The first concerns the legislative procedure, the second the content of the law, and the third the link between the law and drought data.

3.1 A public draft, at least 28 days of consultation and a public response table (publication by 15 October 2026)

MIAK proposes that, after the government meeting, the submitting minister publish the full draft of the climate law on the Government’s website by 15 October. The public consultation should start together with the publication, with a commenting deadline of at least 28 days. Act CXXXI of 2010 on public participation in the preparation of legislation makes consultation mandatory for ministerial drafts. According to Portfolio, its minimum duration is 8 days. For a framework law affecting several sectors, this is not enough for meaningful analysis by the water-management, agricultural and local-government professions. The draft should be accompanied by a short preliminary impact assessment: what it solves, whom it affects, what it costs (I3). At the same time as submitting the bill, the Government should publish a response table. It should contain a summary of every comment received, stating whether it was accepted and, if not, why not. This is the application of the A11 civil consultation programme point. The digital commenting interface could follow the logic of the D10 participation platform. The 28 days do not endanger the committed timetable of submission “this year”: with publication on 15 October, the consultation closes in mid-November. Tocqueville’s argument (see 6.4.3) is practical here: participation in the debate is what makes the law the local communities’ own as well.

3.2 Numerical water-retention targets, designated responsible parties and an annual report in the text of the law (in the bill as submitted)

MIAK proposes that the law should not merely lay down principles but four mandatory elements. First: a national water-retention target value, for example the amount of water retained in the landscape each year in million cubic metres, with a fixed base year and interim targets for 2030 and 2035. Second: water-level or stock indicators for priority standing waters and for groundwater, designated item by item in the law’s implementing decree. Third: a clear order of responsibility, i.e. the minister responsible for the policy, OVF and the regional water directorates for implementation, and local governments for local interventions. Fourth: an annual report to the National Assembly, and a mandatory corrective plan within 90 days if an indicator falls behind its trajectory. MIAK cannot give the concrete target figures, because the baseline water-balance data are not public. That is precisely why the law must prescribe the publication of the base-year data. The press chief of the Ministry for the Living Environment told ATV that the Government is preparing a national water-retention concept and action plan, but this can only start from next year. The law can give it an accountable framework. This is an extension of the K1 measurable climate targets programme point to water retention. So far K1 has prescribed an annual accountability report for emission reduction. According to Stern’s argument (see 6.4.1), the state must provide a long-term, predictable framework for adaptation; without numbers there is no such framework.

3.3 An annual water-balance report with drought, yield and cooling-water data, with community water-management pilot regions (first report by 31 May 2027)

MIAK proposes that the annual report under 3.2 contain a single national water-balance indicator with five components. First: the discharge of the critical sections of the Danube and the Tisza compared with the threshold values. Second: the state of groundwater and priority lakes. Third: irrigation and industrial water abstraction. Fourth: the Paks cooling-water reserve. Fifth: the arable yield loss compared with the five-year average, with a damage estimate in forints. At Paks the balance has real stakes. According to the nuclear energy expert Attila Aszódi, interviewed by ATV, the design basis of the bed sill was a discharge of 600 m³/s, and 612 m³/s was measured on 4 October. According to Portfolio, 603 m³/s is expected for the coming days. The agricultural part of the report could build on the drought module of the K9 climate-economic model and on the MG2 agricultural data platform. The second element is community water management. According to ATV’s report, in Délegyháza the current regulations prohibit replenishing the lakes from another river or lake. Civil groups, the anglers’ association and the local government are therefore forced to seek a permit for a one-off emergency plan. The law should create a legal form and an accelerated permitting route for such local water-management communities. Five pilot regions should start by the end of 2027 under the MG5 and G28 Ostrom-style common-pool resource management programme points. Ostrom’s Californian case (see 6.4.2) shows precisely that a shared water resource can be managed if a neutral body reports accurately on the state of the water every year.

The three proposals are linked by one principle: water retention is a common cause, so its rules must be made in public, and its results must be accounted for measurably every year. The public draft is the procedure, the numerical target is the content, and the annual water balance is the feedback. According to Stern, the main obstacle to adaptation is the lack of information; according to Ostrom, a common-pool resource stands or falls on the publicity of data. The climate law can fill both gaps if it not only proclaims a goal but also provides a measuring instrument.

Part IV — Expected effects and risks

Dimension Expected effect Risk
Legislation Professional and local comments are built into the text of the law; the response table reduces the likelihood of later amendments Because of the 28-day consultation and its processing, the National Assembly will probably only be able to adopt the law in early 2027
Environment and water management A measurable trajectory for water retention; the state of lakes and groundwater becomes public every year The baseline data may be incomplete; with a badly chosen base year the target value is too easy or unattainable
Agriculture Yield loss and drought damage are recorded in a single, official data series; adaptation and damage relief become more predictable Water-retention targets may involve land-use restrictions, which may provoke resistance from farmers
Energy The Paks cooling-water reserve becomes part of public risk management Making reserve data public may raise market and security sensitivities
Economy and budget The need for water-retention investment is foreseeable rather than arising in a crisis Numerical targets create spending obligations in a budget with little room for manoeuvre
Local communities A faster, legal route for intervention in situations similar to Délegyháza Without community rules, local water replenishment may increase one municipality’s water resources at the expense of another

The most important question to weigh is time. The Government’s political commitment is that the draft should go before the National Assembly this year. The four-week consultation does not rule this out, but it will probably push adoption into 2027. In MIAK’s view this is an acceptable price. According to the ministry, water-retention interventions can in any case only start from next year. A badly prepared framework law that is later amended several times costs more than a few weeks. The proposal could become risky if the numerical targets are fixed without baseline data, on the basis of political bargaining. It is therefore crucial that, alongside the target values, the law also prescribes the publication of the baseline data.

There is also a connection with food prices. On 2 October in Kisvárda, Prime Minister Péter Magyar said that the phase-out of the margin cap — the state limitation on the retail margin of basic foodstuffs in force since 2023 — must be considered (444.hu). According to Portfolio, exchange prices of basic foodstuffs have risen to levels not seen for three years. Yield loss due to the drought may reinforce this pressure from the domestic side as well. MIAK’s analysis of 28 September made a detailed proposal on the conditions of the phase-out. This analysis records only this much: in the long run, water retention is also one of the conditions of food-price stability.

Part V — Measurability and summary

5.1 What is worth following? (suggested KPIs)

MIAK suggests the following key performance indicators (KPIs). These are suggested indicators, not government commitments.

  • The commenting period for the draft climate law in days, and the publication of the response table. Target: at least 28 days, with the response table public at the same time as submission.
  • Numerical water-retention targets tied to a base year in the promulgated law. It is worth following whether there is at least one national quantitative target value, a designated responsible party and an annual reporting deadline.
  • Submission of the first annual water-balance report to the National Assembly. Target: by 31 May 2027, with the five-component water-balance indicator and an estimate of yield loss in forints.
  • The number of community water-management pilot regions and the processing time of local water-replenishment permits. Target: 5 pilot regions by the end of 2027; the processing of Délegyháza-type emergency permits measured in days.

5.2 Summary

MIAK’s request is addressed to the Government and consists of three steps. By 15 October: publication of the full draft of the climate law, with at least 28 days of consultation. On submission: a response table, and a bill containing numerical water-retention targets, designated responsible parties and an annual reporting obligation. By 31 May 2027: the first annual water-balance report with data on the Danube, lakes, groundwater, yield loss and the Paks cooling water. And in the general debate on the bill, the National Assembly would do well to ask whether the targets are measurable.

Of MIAK’s foundational values, openness and accountability are at stake here. Openness, because water retention affects everyone from farmers to anglers’ associations: the rules can be made well together with them, in public debate. Accountability, because after this year’s drought society rightly expects the law not only to make a promise, but to show every year how much water has actually been retained.

Part VI — Justifications and further sources

6.1 Press framing by spectrum

In the business press, Portfolio was the most critical of the process. Already in its headline it wrote of a “misunderstanding” between the minister and the civil groups, and put the September “public consultation” in quotation marks. In a separate paragraph it explained what mandatory consultation means legally. The paper also covered the water situation from the energy side: citing a statement by István Kapitány, Minister for Economy and Energy, it highlighted that the bed sill has so far saved electricity generation worth some 30 billion forints. On its agricultural podcast, the president of the Hungarian Grain Growers’ Association (GOSZ), Tamás Petőházi, called this year the worst year of all time for Hungarian agriculture. Its subscription analysis projected the end of the era of cheap food (based only on the public lead).

In the public-affairs segment, 24.hu was data-centred. It published the yield estimate of the European Commission’s Joint Research Centre (JRC), the Danube record and the Prime Minister’s announcement in Paks. It also summarised the interview given to Népszava by Szabolcs Bóna, minister responsible for agriculture and the food economy: according to the minister, maize will not be the crop of the future in a large part of the country. ATV took the human angle. In Délegyháza it showed the drying lakes, the residents’ petition and the mayor’s emergency plan. In Paks a nuclear energy expert and a ship’s captain spoke. The latter warned that if winter precipitation falls as snow, even more extreme water levels may come next summer.

In the left-liberal segment, HVG highlighted the double agenda of the government meeting: the 2027 budget and the climate law. According to Finance Minister András Kármán, the budget bill will go before parliament in October. Telex explained the technical operation of the Paks bed sill and recalled the August shutdown. Instead of the climate law, 444.hu carried the Prime Minister’s statement on the margin cap. Népszava reported the −2 centimetre water level in Budapest (title-level reference only). The conservative segment did not put the climate law in focus on this day. Magyar Nemzet framed the possible phase-out of the margin cap as a burden on families. The paper quoted the estimate of a Fidesz economic-policy politician, according to which the return of pre-cap margins would mean an extra 180–360 thousand forints of annual spending for an average family. At the same time the article also listed the agricultural and food-industry interest groups, among them the Hungarian Chamber of Agriculture (NAK), that are calling for an immediate phase-out.

6.2 Facts and data

The procedural status of the climate law (3–4 October 2026):

Item Content Source
Agenda the draft climate law at the two-day off-site government meeting in Erdőbénye statement by László Gajdos — Portfolio, HVG
Main aims retaining water resources, saving lakes, protecting and restoring natural habitats and landscapes Portfolio, HVG
Planned timetable before the National Assembly “this year” statement by László Gajdos — HVG
The official draft not published; the formal consultation stage has not started Portfolio
Civil initiative nearly 200 organisations: at least four weeks of consultation instead of the minimum 8 days Portfolio
National water-retention concept in preparation, to start from next year press chief of the Ministry for the Living Environment — ATV

The Danube and the Paks cooling water (1–4 October 2026):

Data Value Source
Budapest water level, 1 October −1 cm, the historic low of measurements (the zero point of the gauge is the lowest water level measured in 1834) 24.hu
Budapest water level, 2 October −2 cm Népszava (title-level reference only)
Forecast for the weekend −8 cm OVF — 24.hu
Paks water level, 4 October −118 cm ATV
Design basis of the bed sill / measured discharge 600 m³/s / 612 m³/s Attila Aszódi — ATV
Expected discharge at Paks / previous negative record 603 m³/s / 630 m³/s statement by István Kapitány — Portfolio
The power plant’s margin 21 cm, a further expected fall of 3 cm; three units in operation, planned maintenance on the fourth statement by István Kapitány — Portfolio
Generation protected by the bed sill electricity worth some 30 billion forints (ministry estimate) Portfolio
August shutdown seven of the eight turbines of the four units had to be shut down Telex

The two discharge figures are not contradictory. ATV reported a measured value for 4 October, Portfolio a forecast made on 2 October. Together they show that the discharge came within a few cubic metres per second of the design basis of the bed sill.

Drought and agriculture:

Data Value Source
Expected yield loss in Western and Central Europe compared with the average of the past five years soya −15%, silage maize −14%, sugar beet −11%, grain maize −8%, potatoes −7% JRC — 24.hu (after Időkép)
Maturing of maize in the most severely affected areas up to three weeks earlier JRC — 24.hu
Domestic maize sown area from the earlier level of over one million hectares to under 600 thousand hectares this year Szabolcs Bóna — Népszava, 24.hu
Winter wheat / winter barley harvest 4.1 million tonnes (1 million tonnes less than last year) / 1.5 million tonnes (300 thousand tonnes less) Tamás Petőházi, GOSZ — Portfolio
This year’s loss in arable crop production 500–600 billion forints; 150–200 thousand forints per hectare (around 100 thousand in 2022) Tamás Petőházi, GOSZ — Portfolio
Summer discharge of European rivers the lowest values in the data series of the European Flood Awareness System (EFAS), launched in 1992; record-low or near-record discharge on the Danube too Copernicus — Portfolio

The JRC data are European, not Hungarian, estimates. MIAK did not find official, crop-by-crop data on domestic yield loss in the sources. It therefore proposes that the annual water-balance report publish these, building on the crop estimate of the Hungarian Central Statistical Office (KSH).

Délegyháza as a local case (ATV, 3 October): a lake system of six lakes of some 200 hectares, about 6,000 residents. The jetties stand one and a half to two metres above the water, and some 1,700 people signed the petition. The current regulations prohibit replenishment from another river or lake. According to the emergency plan adopted at the local consultation on 2 October, some 390 thousand cubic metres of water can be pumped over from a quarry lake. After permitting, this could mean a rise in water level of at least 0.5 metres. The local government is working with the Hungarian University of Agriculture and Life Sciences (MATE) on a long-term rehabilitation concept.

6.3 Policy dimensions

  • Environment and climate (programme points) — numerical water-retention targets accounted for annually in the climate law (programme point ID: K1); modelling of drought damage in the climate-economic model (programme point ID: K9); the Paks cooling-water risk as an energy-market shock factor (programme point ID: K7);
  • Agriculture (programme points) — yield and damage estimates on a public data platform (programme point ID: MG2); pilot regions of local water-management communities (programme point ID: MG5);
  • Economy (programme points) — the legal framework of Ostrom-style common-pool resource management (programme point ID: G28);
  • Transparency and anti-corruption policy (programme points) — mandatory civil consultation and a public response table (programme point ID: A11);
  • Justice (programme points) — preliminary, public regulatory impact assessment (programme point ID: I3);
  • Digitalisation and AI regulation (programme points) — an online commenting interface for draft legislation (programme point ID: D10).

6.4 Literature in detail

6.4.1 Nicholas Stern: The Economics of Climate Change — The Stern Review

Stern’s report treats adaptation as a policy task in its own right alongside emission reduction. It finds that in many countries it is pushed into the background. The benefits of adaptation are local and quick, so part of it happens by itself. According to the report, however, it is held back by market failures, above all by the lack of information about the future climate. It summarises the role of governments as follows:

“Governments have a role in providing a policy framework to guide effective adaptation by individuals and firms in the medium and longer term. […] High-quality climate information and risk-management tools help markets to function efficiently.” (MIAK’s own translation)

Among the further tasks of the state, the report mentions the protection of climate-sensitive public goods, including natural resources, and emergency preparedness. A climate law laying down water-retention targets is exactly such a framework. Farmers, local governments and energy companies can plan ahead if they know what water balance and what state intervention they can count on. The annual water-balance report (3.3) is the domestic, institutionalised form of “high-quality climate information”; and the numerical target (3.2) is the predictable long-term framework.

📖 Source: Nicholas Stern: The Economics of Climate Change — The Stern Review (Cambridge University Press / HM Treasury, 2007)

6.4.2 Elinor Ostrom: Governing the Commons

One of Ostrom’s cases analysed in detail is the overused groundwater basins of Southern California. Because of the falling water level, the water abstractors eventually asked themselves for a neutral expert, a court-appointed “watermaster”, to survey the basin’s water resources and past water use. They shared the cost of the survey. In one of the basins the rights holders agreed on a proportional, 20 per cent reduction in abstraction and on common operating rules. Ostrom emphasises that the watermaster reports annually. From this every participant gets an accurate picture of compliance with the rules and of the state of the water, so the report became the basis of trust and voluntary rule compliance. The water tribunal of the Valencian irrigation communities, which has met weekly for centuries, is another model: disputes are settled publicly, before the farmers’ eyes, and quickly. Translated to the Hungarian situation: the civil groups, anglers and local government of Délegyháza already form a common forum today. What is missing, however, is legal recognition and common, reliable data. Proposal 3.3 would supply both: pilot regions with a legal form, and an annual water balance on which local rules can be built. (The work’s rights status is pending clarification, so only a paraphrase appears here.)

📖 Source: Elinor Ostrom: Governing the Commons — The Evolution of Institutions for Collective Action (Cambridge University Press, 1990)

6.4.3 Alexis de Tocqueville: Democracy in America

Examining the self-government of New England townships, Tocqueville concludes that the strength of free nations lies in local citizens’ assemblies:

“Town meetings are to liberty what primary schools are to science: they bring it within the people’s reach and teach men how to use it.” (MIAK’s own translation)

The idea is practical at two points of the climate law. On the one hand, the four-week public consultation (3.1) is the national-level “town meeting”: the law becomes understandable and their own for citizens where they can comment meaningfully. On the other hand, the local consultation in Délegyháza, where civil groups, anglers, water experts and the local government jointly adopted an emergency plan, shows that the local water community already exists. The law only needs to recognise and strengthen it (3.3).

📖 Source: Alexis de Tocqueville: Democracy in America (1835–1840)

6.5 International comparison

The most frequently cited model of an accountable climate law is the United Kingdom’s Climate Change Act of 2008. It prescribes five-year carbon budgets, and an independent committee oversees delivery. The British model is built on emission reduction, but its logic can also be transferred to water retention: a target trajectory laid down in law, independent monitoring, an annual report to parliament. MIAK’s K1 programme point is built on the same structure.

EU water law provides a reference point for the length of public consultation. The Water Framework Directive prescribes a written commenting period of at least six months for draft river basin management plans. The Aarhus Convention on public participation in environmental matters, to which Hungary is a party, also regards early and meaningful public participation as a basic principle. Compared with this, the four weeks requested by civil groups for a framework law is a moderate demand.

Ostrom’s cases provide a model for community water management: the watermaster system of the Californian groundwater basins and the Valencian water tribunal (6.4.2). In both, local water users jointly make and enforce the rules, while the state recognises them and supports them with data. Building on the Hungarian tradition of water associations and commons-holding associations, MIAK’s MG5 programme point proposes similar pilot regions.

Environment and climate

  • K1 — Measurable climate targets
  • K9 — Domestic integrated climate-economic model
  • K7 — Energy-market shock resilience

Agriculture

  • MG2 — Agricultural data platform
  • MG5 — Framework for community resource management (commons-holding 2.0)

Economy

  • G28 — Framework for community resource management (Ostrom CPR)

Transparency and anti-corruption policy

  • A11 — Civil society partnership programme

Justice

  • I3 — Regulatory impact assessment

Digitalisation and AI regulation

  • D10 — Digital democratic participation platform

Proposed new programme point: National water-balance report — a water-retention target trajectory laid down in law, a five-component annual water-balance indicator and a 90-day corrective obligation — for the Environment and climate area.

6.7 List of sources

Press sources (MIAK press monitor, 4 October 2026 — topic 3; 3 October 2026 — topic 6):

Knowledge-base references (literature):

  • 📖 Nicholas Stern: The Economics of Climate Change — The Stern Review (2007)
  • 📖 Elinor Ostrom: Governing the Commons — The Evolution of Institutions for Collective Action (1990)
  • 📖 Alexis de Tocqueville: Democracy in America (1835–1840)

MIAK internal materials:

Supplementary public data sources:

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