Act XXXIV of 2026 on the National Office for Asset Recovery and Asset Protection places particular emphasis on the financial and accounting transparency of organisations managing public assets, public funds, government grants and European Union funding, as well as their affiliated enterprises.
The summary below presents the provisions of the Act that directly or indirectly affect accounting, taxation and financial reporting activities.
I. High-Risk Threshold and Mandatory Investigation
Sections 33–34
One of the most significant provisions for accounting professionals is the requirement to monitor and calculate the 75% revenue threshold.
Conditions of the 75% Rule and Definitions of Revenue Sources
A business entity is considered to present a high risk if, during any of the five completed financial years preceding the investigation, revenue derived from the sources listed below reaches or exceeds 75% of the combined net sales revenue of the business entity and its affiliated enterprises as defined by the Corporate Income Tax Act (TAO).
1. Revenue Derived from Public Procurement or Concession Procurement Procedures under the Public Procurement Act (Kbt.)
Public Procurement Procedure
A legally regulated competitive procurement procedure that contracting authorities—such as state bodies, municipalities or public utility providers—are required to conduct when, at a value reaching or exceeding the statutory threshold, they:
purchasing goods,
procuring services,
or commissioning construction projects.
Revenue generated from contracts awarded through such procedures falls within this category.
Concession Procurement Procedure
A special form of public procurement in which the State or a municipality does not directly pay for a project or service, but instead:
grants the right to carry out an economic activity,
and to collect the resulting revenues.
Examples include motorway operation and waste management services.
The concession holder recovers its investment through market-generated revenues while assuming the associated business risks.
2. Revenue Derived from Procedures Conducted under Act XXX of 2016 on Defence and Security Procurement
This is a special procurement procedure that constitutes an exception to the standard public procurement regime.
It covers procurement procedures conducted by military and law enforcement bodies, as well as national security services, including, for example, the procurement of:
military equipment,
telecommunications systems,
defence infrastructure,
services involving classified or security-sensitive information.
Revenue derived from contracts awarded under these procedures falls within this category.
3. Revenue Derived from Competitive Procurement Procedures Conducted under the Internal Procurement Rules of a Public Authority
This category includes procurement procedures initiated by state bodies, municipalities or other public authorities, that:
fall below the statutory public procurement thresholds,
or are exempt from the Public Procurement Act due to a statutory exemption, such as national security or emergency exemptions.
In such cases, the contracting authority selects the successful bidder in accordance with its own internal procurement and competitive bidding rules. Nevertheless, the funds received under these contracts continue to constitute revenue originating from public funds.
4. Public Funds Received in the Form of Grants
A non-reciprocal monetary contribution that is not paid as consideration for a market-based service provided in return.
The grant is provided from the subsystems of public finances, for example:
the central government budget,
municipalities,
and earmarked state funds.
The grant may be provided for the implementation of a specific task or objective, for example:
operating grants,
development grants,
and purpose-specific grants.
5. State or European Union Funding and State-Guaranteed Loans
This is the broadest category and includes:
non-repayable grants financed from the European Union's structural, investment or other funds,
direct financial support channelled through Hungarian state institutions or European Union institutions,
financial instruments financed by the State or the European Union,
funding provided under the EU Recovery and Resilience Facility,
direct European Commission grant programmes,
and the full amount of loans guaranteed by the Hungarian State.
Editorial note: The original source document contains the separate phrase "mi/EU-s forrásból származó bevétel", which appears to be incomplete or the result of a typographical error. Since the original wording cannot be determined with certainty, it has not been interpreted beyond the source text.
The original document also separately lists the amount of state-guaranteed loans.
Consequence: If the above condition is met, the Office is required to initiate a Public Asset Protection Investigation pursuant to Section 34 (1) of the Act.
Accounting Calculation Rules
Topic | Rule / Requirement |
Net Sales Revenue under the Accounting Act | For entities preparing financial statements under the Hungarian Accounting Act, the net sales revenue reported in the annual financial statements shall be used. |
IFRS and Other Financial Reporting Frameworks | Entities applying IFRS shall use revenue from ordinary activities, or the equivalent revenue category under the applicable financial reporting framework. |
Elimination of Intra-group Transactions | When calculating combined net sales revenue, revenue generated from transactions between affiliated enterprises must be eliminated in a manner equivalent to consolidation adjustments. |
II. Data Provision, Record-Keeping and Cooperation Obligations
Sections 40–46
During investigations conducted by the Office, accountants, auditors and financial managers assume a direct role in providing information and cooperating with the authorities.
Documents and Data Subject to Investigation
The Office may request access to, among others, the following documents and records:
contracts,
invoices,
accounting vouchers,
financial performance certificates,
accounting records,
general ledger extracts,
analytical records,
decision-supporting documentation,
submissions prepared for decision-making bodies,
minutes of meetings,
grant settlement documentation,
concession-related documentation,
asset management documentation,
electronic data files,
databases,
data stored in invoicing systems and Enterprise Resource Planning (ERP) systems.
On-site Inspections and Access to Data
Sections 43–44 and 60
Authorised representatives of the Office are entitled to:
inspect documents on the premises,
extract data from electronic systems,
or request direct electronic access to data.
This may include access to:
document management systems,
financial systems,
accounting systems,
and contract management and contract registration systems.
Departments responsible for accounting must ensure:
the integrity of electronic data,
the retrievability of records,
and the transparency of modification histories (audit trails).
Protection of Tax and Business Secrets vs. Disclosure Obligation
Section 46
The Act expressly provides that any person or organisation required to cooperate with an investigation may disclose, to the extent necessary for the investigation:
business secrets,
banking secrets,
tax secrets,
and any other information protected by law.
Neither tax secrecy nor business confidentiality may be invoked as grounds for refusing disclosure to the Office.
III. Public Asset Protection Supervision – Financial and Countersignature Restrictions
Sections 50–52
Where a business entity is placed under Public Asset Protection Supervision by the Office, the organisation's day-to-day financial and accounting processes are fundamentally affected.
1. Mandatory Countersignature
Any commitment involving assets or financial obligations must be countersigned by the supervisor appointed by the Office.
In the absence of such countersignature, the commitment is null and void pursuant to Section 52 (6) of the Act.
Accordingly, commitments that have not been duly countersigned may not be lawfully recognised in the accounting records.
2. Review of Bank Accounts and Cash Holdings
The appointed supervisor is authorised to examine directly:
the entity's payment accounts,
cash holdings,
financial assets,
and contracts.
3. Requests for Information
The appointed supervisor may request information directly from:
the company's statutory auditor,
executive officers,
and finance and accounting personnel.
IV. Practical Tasks for Accountants – Compliance Checklist
To ensure compliance with the Act, accountants and financial service providers are advised to incorporate the following measures into their internal processes.
1. Separate Analytical Records of Revenue from Public Funds
Revenue generated from the following sources should be tracked separately, either through dedicated general ledger accounts or detailed analytical records:
public procurement contracts,
grants,
European Union funding,
and concession agreements.
2. Affiliated Enterprise Network and the 75% Test
At least once a year, businesses should calculate the consolidated proportion of revenue derived from public funds for the previous five completed financial years, taking into account all affiliated enterprises.
When performing the calculation, the following must be eliminated:
duplications,
i.e. transactions between affiliated enterprises.
3. Document Logging and Auditability
The digital and physical archives of accounting vouchers, certificates of performance and contracts must be prepared to fulfil any potential requests for information from the Office.
According to the original document, preparations must be made for such requests for information with a response deadline of at least five days.
4. Implementation of Countersignature Controls
For business entities under supervision, strict controls must be introduced to ensure that the supervisor's countersignature is in place:
before processing payment instructions,
and before processing contracts.
If you have any further questions regarding this topic,
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