Hungarian Parliament Establishes The National Asset Protection And Recovery Office

August 2026 – On 28 July 2026, the Hungarian parliament adopted the Act Establishing the National Asset Protection and Recovery Office (Nemzeti Vagyonvisszaszerzési és Vagyonvédelmi Hivatal, “NVVH”).

The newly established authority has broad investigative and prosecutorial powers in relation to the management and recovery of public assets. Notably, even before a freezing order is issued in criminal proceedings, the NVVH may place a company under public asset protection supervision, where specified property-related commitments require the countersignature of an appointed supervisor.

A new enforcement authority

The NVVH is expected to become a key enforcement body overseeing the management of public assets in Hungary. Once operational, it will conduct general risk assessments, and based on the results, initiate investigations into the use and management of public assets.

The authority will be required to launch an investigation where a company’s aggregate proceeds, together with those of its affiliates, from public procurement procedures, concession awards, government tenders, subsidies, state or EU funding, or state-guaranteed loans amounted to least 75% of its total revenue in any of the preceding five financial years. As a result, enhanced scrutiny is expected, particularly in sectors that rely heavily on public funding, including defence and civil engineering.

Broad investigative powers

The NVVH will be vested with extensive investigatory powers. During the investigation, it may:

• conduct unannounced and announced onsite inspections;
• request information and documents;
• interview individuals; and
• examine the activities and transactions of companies.

Companies and individuals subject to an investigation will be required to cooperate with the authority. Failure to do so may result in significant fines, including penalties of up to HUF 5 billion (approx. EUR 14 million) for companies.

Importantly, the investigation itself does not qualify as an administrative proceeding. Except for decisions imposing a fine, the NVVH’s investigative activity cannot be directly challenged in administrative court.

Available enforcement measures

Based on its findings, the NVVH may take a range of enforcement actions. In particular, it may:

• launch criminal proceedings where it has jurisdiction, or refer suspected offences to the competent authorities and request measures to preserve relevant assets;
• bring civil claims to have contracts declared null and void and to reverse their legal and financial effects;
• join civil proceedings already brought by another claimant where the NVVH could have brought the claim itself;
• require the competent authorities responsible for overseeing the use of state or EU funds to initiate administrative proceedings; and
• request tax audits and challenge unlawful administrative or tax decisions, as well as failures by the competent authorities to act.

Additionally, even before a freezing order is issued in criminal proceedings, the NVVH may place a company under public asset protection supervision where this is necessary to safeguard public assets. Within the scope of the supervisory decision, the appointed supervisor may monitor the company’s operations, countersign its property-related commitments, and decide matters falling within the competence of the company’s supreme decision-making body. Any property-related commitment made without the required countersignature will be null and void.
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