In a fresh report, Amnesty International Hungary, the Hungarian Helsinki Committee, K-Monitor and Transparency International Hungary assess compliance with the 17 conditionality measures, the 27 super milestones under the RRP, a further 45 milestones and targets under the RRP that were due to have been complied with by the third quarter of 2025 as per the deadline the Hungarian government has set itself, and compliance with the horizontal enabling condition “Effective application and implementation of the Charter of Fundamental Rights” in the 4 areas identified by the European Commission.
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. The present paper, prepared by Hungarian civil society organisations ahead of the upcoming re-assessment by the European Commission and the Council of the European Union in the framework of the conditionality mechanism in December 2025, looks at the steps the Hungarian government has taken to date to address the deficiencies identified by the European Commission and the representatives of Member States in the Council as an obstacle to the country’s access to EU funds. 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.
Our review is based on legislative steps and other publicly available information and data, and on experiences of some of the authors in the Anti-Corruption Task Force and the monitoring committees tasked with the monitoring
of the use of EU funds, as well as on experience accumulated by the authors in relation to the practical implementation of amended access to information regulations by courts and by the National Authority for Data Protection and Freedom of Information. After presenting and assessing the steps taken by the Hungarian authorities, we provide, in certain areas, recommendations aimed at tackling the various rule of law and human rights deficiencies identified. Our recommendations are constrained to the steps needed to comply with the conditions set by EU institutions (except for the area of judicial independence, where a number of new developments accelerating the regression are addressed by the assessment). Therefore, the recommendations cannot be taken as an exhaustive list of desired steps in a given area from a rule of law, anti-corruption or human rights perspective.
According to our assessment, out of the 27 super milestones (which all would have been due by the end of 2022), 1 has not been achieved, 9 have been achieved only partly, and only 17 can be considered as fully achieved to date. This shows a regression compared to November 2024. 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 isproportionately 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.
The detailed analysis can be found here.
A table with the milestone assessment is available here.
Forrás: Fortepan
