Executive summary
Hungary is taking steps to improve its anti-corruption framework and to promote public integrity. The adoption of the Medium-Term National Anti-Corruption Strategy for 2023-2025 (NACS) and the Action Plan for its implementation, within the framework of the conditionality mechanism triggered by the European Commission and the negotiations over Hungary’s Recovery and Resilience Plan (RRP) in 2022, is a significant part of that process. Based on an assessment of the current performance of Hungary’s anti-corruption framework, the NACS sets a series of strategic objectives that it then translates into eight priority intervention areas and six groups of actions in the Action Plan. It also describes a monitoring and evaluation process and comments on the budgeting requirements of the planned activity.
Nonetheless, Hungary could strengthen its strategy, in line with international good practices, with a view to producing tangible improvements in its anti-corruption framework. This report provides an assessment of the NACS and its Action Plan, looking both at the form and substance of the draft strategy and providing recommendations for improvement.
The assessment of the NACS has identified both challenges and opportunities for Hungary as it develops its strategy ahead of adoption:
The NACS would benefit from clarification throughout about how it will produce tangible improvements in Hungary’s integrity framework. This would help to build trust in the framework with evidence and meet Hungary’s objectives in remedial measure No.3 and the RRP. The adoption of the NACS is not an end in itself. Rather, the NACS presents an opportunity for Hungary to strengthen its public integrity framework at all levels – at the highest political levels, through all tiers of government, and into the private sector and wider society.
The NACS has undergone some useful intra-governmental and external consultation which has informed the objectives, prioritisation and actions in the current draft. Although the development of the NACS is subject to significant time pressure, there is scope to undertake a more thorough consultation process to help build a common vision, increase the legitimacy of and support for the strategy, and ensure the relevance and effectiveness of the proposed activities.
The NACS follows a similar structure to the Strategy Against Fraud and Corruption for European Union Funds, but the NACS could better articulate the challenges it is seeking to overcome, why these challenges have been prioritised, how it will overcome them and by when, and how it will measure success.
The NACS sets out a broad range of objectives, based on Hungary’s commitments in remedial measure No.3 and its Recovery and Resilience Plan, and sets a high-level goal of fighting corruption across the whole of society. Clearer framing to demonstrate how the different sections of the NACS build on each other would make it easier to understand the underlying logic and theory of change.
The Action Plan contains a range of actions across six of the intervention areas set out in the NACS for improving Hungary’s ability to fight corruption. Actions for two of the intervention areas appear to be missing. Overall, the actions could be more detailed, setting out what specific steps will need to be taken and when, and, ultimately, what outcome those steps are designed to produce. These improvements could be made to ensure the NACS produces the changes which it is intended to produce.
The NACS sets out a process for monitoring and evaluating (M&E) the implementation of the strategic objectives and actions, which is a vital component of all anti-corruption strategies. These M&E processes could be clarified, however, with more detail about how they will work, how they will ensure the NACS can effectively address implementation challenges, and, ultimately, how they will ensure the NACS achieves its aim of strengthening the anti-corruption framework in Hungary.
Communicating progress and results to internal and external stakeholders enables accountability, increases the credibility of integrity efforts by the government, and fosters support for the strategy. The NACS currently does not contain a plan for communications about its implementation.
The following recommendations would strengthen the NACS and Action Plan (AP):
Undertake a broader consultation process, both internally and outside of government, to promote ownership and improve transparency before adoption.
Strengthen, clarify and streamline the problem analysis underpinning the six intervention areas of the Action Plan.
Set out how the NACS complements other strategies to address gaps, enhance coherence and avoid duplication in Hungary’s anti-corruption framework.
Link each objective with the corresponding actions, outputs and milestones in the Action Plan to show how the objectives will be realised through relevant activity.
Make the Action Plan more detailed, setting out clearer expectations of implementing authorities and clarifying timings and delivery milestones, outputs, and indicators for tracking progress.
Draft some measures in the Action Plan more clearly to ensure they are actionable, and some measures could be added to improve coverage and make sure the Action Plan is effective.
Clarify who owns co-ordination mechanisms for the Action Plan, how activity will be funded, and how indicators will be used to promote implementation of the NACS and AP.
Include in the monitoring a methodology allowing for flexible adjustments of the NACS.
Clarify the methodology for evaluation, defining indicators and including evaluations in the Action Plan.
Plan measures to engage relevant stakeholders and civil society in monitoring implementation and develop a communications strategy to involve and inform citizens and businesses.