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19 August 2026
newsletter
hungary

Hungary establishes the National Asset Recovery and Protection Office

On 29 July 2026, Act XXXIV of 2026 on the National Asset Recovery and Protection Office entered into force in Hungary. The Act creates a new, independent state body (the "NVVH") tasked with uncovering historic misuse of public assets and recovering property unlawfully removed from public ownership.

Mandate and core functions

The NVVH's statutory mandate is to uncover matters involving the unlawful management of public assets, even retrospectively, and to locate, identify, secure, preserve the value of and recover assets removed from public ownership in connection with criminal offences.

To carry out these tasks, the NVVH may conduct risk assessments and investigations, place assets under supervision, bring civil claims, initiate proceedings by other bodies and exercise powers in administrative, judicial and criminal proceedings. The NVVH will have extensive powers to request documents and explanations, conduct on-site inspections, copy electronic data and access public registers and, subject to statutory safeguards, obtain information protected by banking, tax or commercial secrecy.

Within the framework of the Criminal Procedure Act, the NVVH may conduct or supervise preparatory proceedings, direct or carry out investigations and act as public prosecutor, representing the charges before courts and exercising the associated rights of appeal.

Institutional status and independence

The NVVH is established as a central budgetary institution with its own budget chapter. Its budget may not be reduced year-on-year without the NVVH's consent (subject to limited exceptions). The Act declares that the NVVH is independent in performing its tasks, subject only to the law and not subject to instruction by any other person or body. Its functions may be established only by statute. Staff must resist improper attempts to influence the NVVH and the president must report serious or repeated incidents to the competent parliamentary committee within five working days.

Leadership

The NVVH will be led by a president, assisted by four deputy presidents responsible respectively for public finance, investigations, prosecution and appeals. The selection process for the president and deputy presidents is currently underway through an open application procedure. They will be nominated and elected by Parliament for a single, non-renewable term by the end of August. 

The president must submit a public annual report to Parliament each year, covering the NVVH's activities, the types, number and outcomes of proceedings conducted, key risks identified and aggregated data on the exercise of criminal procedural powers. The president may also brief the competent parliamentary committees on an ad hoc basis where particularly significant, systemic risks to public asset management arise. The NVVH must also be consulted on draft legislation affecting its status or functions and may propose legislative reforms relating to the protection of public assets.

Practical implications

While the core legislation took effect on 29 July 2026, specific provisions – including the full criminal procedural powers of the NVVH – will take effect in stages through August and September 2026.

For companies involved in public procurement, concessions, subsidised projects or EU-funded programmes, the establishment of the NVVH significantly increases the risk of retrospective scrutiny of public asset flows, beneficial ownership structures and contractual arrangements involving the State or municipalities. 

Companies operating in these areas should therefore review their exposure proactively and ensure that relevant transactions, ownership structures and contractual arrangements are properly documented and legally defensible. Where an NVVH review is initiated, early involvement of experienced legal counsel will be critical to managing the process, protecting the company's procedural rights and ensuring that responses to information requests, on-site inspections and other investigative measures are handled appropriately. Individuals who obstruct NVVH proceedings may face fines of up to HUF 50m, while organisations may be fined up to HUF 5bln.

Márk
Kovács

Attorney at Law

hungary