Assessing Hungary’s compliance with conditions to access EU funds in November 2025
In December 2022, European Union institutions suspended and tied to conditions Hungary’s access to EU funds under various procedures due to severe breaches of the rule of law and human rights. Ahead of the upcoming re-assessment of the relevant milestones in December 2025, Hungarian civil society organisations looked at the steps the Hungarian government has taken to date to address the deficiencies identified by the Commission and the representatives of Member States in the Council.
As the analysis shows in detail, to date, the Hungarian government has not taken adequate steps in order to fully address the rule of law and human rights concerns raised, and it has not complied with significant conditions established by EU institutions to access EU funds. There are areas where no progress has been made at all, many of the required measures are severely delayed, and flaws in the regulation and the practice undermine the capacity of legal amendments and new measures to effect real change. Certain new developments that have taken place since our previous comprehensive assessment, published in November 2024, further undermine previously achieved progress. In other words, the Hungarian government’s approach suggests that it looks at the conditions set by the EU and Member States as a “ticking-the-box” exercise at best, without a real commitment to restoring the rule of law and respect for human rights in Hungary. Taken together, these factors continue to jeopardise Hungary’s ability to comply with the safeguards that EU law attached to the disbursement of EU funds.
In light of these delays and the continued failure to address the substantive concerns raised by EU institutions, the Hungarian government has, instead of accelerating implementation, prepared a substantial modification of the already adopted Recovery and Resilience Plan. According to the draft amendment, several investments of the original plan would be reduced to zero (mainly in the fields of water management, sustainable green transport, energy, the transition to a circular economy as well as investments in the RePowerEU programme), while a disproportionately large share of the RRF allocation would be redirected to a capital injection for the state-owned MFB Bank (Hungarian Development Bank). This proposed restructuring disregards the reform priorities identified in the European Semester recommendations. Rather than constituting a credible reform effort, the planned amendment appears primarily aimed at reallocating funds in the face of impending implementation deadlines.
Looking at the “ordinary” milestones as well and the measures required in general, the picture is even more bleak. Although the Hungarian government has adopted a number of legislative and administrative amendments, the implementation is slow, inconsistent, and often incompatible with the genuine achievement of the objectives set by EU institutions. In several key areas, such as freedom of information, judicial independence, and the enabling environment for civil society, new amendments, judgments of the Kúria, Hungary’s apex court, and policy initiatives adopted since late 2024 indicate regression rather than progress.
To date, numerous issues related to the anti-corruption framework, competition in public procurement, judicial independence, the predictability, quality and transparency of decision-making, academic freedom, the rights of refugees and asylum-seekers, and the rights of LGBTQI+ persons remain unresolved. These deficiencies are compounded by new measures that either advance instead of reverse already identified breaches of the rule of law or fundamental rights or lead to new, systemic breaches.
The detailed assessment by Amnesty International Hungary, the Hungarian Helsinki Committee, K-Monitor, and Transparency International Hungary is available here.
A traffic-light summary table of compliance with the different milestones is available here.