Part I — Situation overview

In its communiqué of 26 August 2026 the Ministry of the Interior ordered an investigation in connection with the circumstances of the preparations and the procurement process of the Budapest state events of 20 August, “in order to clarify in full the information that has appeared in the press”. In the same communiqué the ministry called the series of programmes outstandingly successful, and indicated that it had been carried out on about a quarter of last year’s costs, under a tight deadline. The trigger of the investigation was the article published by G7 on 20 August, which, on the basis of correspondence that had come into its possession, described how the head of the eventual winner of the tender, Hardrock Kft., had already been in contact with the Lounge group weeks before the official invitation to tender, and had requested and received information about the planned budget of the event, about its subcontractors and about the main elements of the production. The three companies invited to tender were officially notified on 7 July. According to the correspondence, in mid-June the former events director of the Tisza Party, Miklós Zelcsényi, thanked the managing director of Lounge for a personal meeting, at which he had requested information about the advance payments “at the request of government commissioner Márk Radnai”.

The background to the procedure is known: in recent years the Saint Stephen’s Day events were organised by the Lounge group, but after the accounts of Gyula Balásy’s companies were frozen, the company was unable to perform its contracts. A new organiser had to be found, but there was no time left for a normal open procedure, so a negotiated procedure without prior publication followed. On 26 August the former independent member of parliament Ákos Hadházy published six screenshots from the correspondence — according to him Márk Radnai appears on five of them as addressee or as a party copied in — and stated that the problem was not the absence of an open procedure but that the invitation procedure had been manipulated in a manner restricting competition. In his response Márk Radnai wrote that after the formation of the government he had not dealt with the organisation of state events, that he had only assisted in developing the creative concept, that he had not read the letters referred to and had learned of their content from the press, and that he had neither a task nor a competence in state event organisation. The head of the organising company, Dániel Besnyő, stated that he had not conducted the procurement procedure and that he was taking legal steps because of the accusations. In the matter Mi Hazánk filed a criminal complaint on suspicion of an agreement restricting competition, and the Fidesz parliamentary group made a public interest disclosure to the Public Procurement Authority.

Without two clarifications of competence this case cannot be understood. The first: the investigation ordered by the Ministry of the Interior is an internal, administrative procedure — the ministry is reviewing the decision preparation conducted within its own organisational system. It is not criminal proceedings, nor is it a remedies procedure of the Public Procurement Authority; the three threads run alongside each other, independently of one another. On the question of criminal liability only a court decides, and only the prosecution service may bring charges. The second: the “government commissioner” is not the same as the contracting authority. The legally responsible party in a procurement procedure is the contracting organisation and its head; what role a government commissioner played in the decision preparation is precisely the subject of the investigation, not its starting point.

MIAK’s reading: this case is graver than an inherited burden because here the new government is examining its own decision chain. The question of credibility is not whether a government uncovers the affairs of its predecessor — in that it has a strong interest. The question is whether it applies the same standard to its own. And there is a lesson even more uncomfortable than this: the fact that the correspondence came to light at all was not the working of the system but a press report. That is, public procurement publicity in Hungary is today retrospective and accidental — decision preparation is the phase in which competition is decided, and it is precisely this phase that falls outside the scope of mandatory publication.

Part II — Foundations in the literature

Before turning to the proposals, it is worth setting out the conceptual framework in which the examination of “one’s own affair” can be interpreted. In his work The Theory of Moral Sentiments Adam Smith (Scottish moral philosopher and economist, author, alongside The Wealth of Nations, of the theory of moral sentiments) describes the figure of the impartial spectator: we evaluate our own conduct as an unbiased outsider would see it — except that this self-examination is at its most partial exactly when it would be most important to be objective. Smith’s remedy is not better intentions but the general rule laid down in advance. Kautilya (ancient Indian author of state theory, to whom the Arthashastra is attributed) lists forty ways of embezzling public money, and lays down the rule that every actor in the payment chain — the depositary, the prescriber, the receiver, the payer and the person who caused the payment — must be examined separately. This approach is directly applicable to the delimitation of the actors of a correspondence chain. In his case study of Korean procurement for the American army, Robert Klitgaard (American economist, the author who established the practical methodology of corruption prevention) shows what collusive bidding means in practice: the participants agree in advance on the price level and on who will be the lowest bidder. The detailed treatment of the literature — author by author, with quotations — can be found in section 6.4 Literature in detail.

Part III — MIAK’s concrete proposal

MIAK proposes three measurable measures, each of which also binds the present government — and it is precisely this that gives them their credibility.

3.1 Mandatory subsequent publication of decision-preparatory communication for state event procurements above 500 million forints (by the start of the 2027 budget year)

The present regulation makes the document public — the call, the tenders, the contract — but not the process. The case of 20 August shows precisely that the fate of competition is decided before the call is issued, in the phase about which no mandatory publication rule provides anything. MIAK proposes that in every procurement aimed at state event organisation with an estimated value exceeding 500 million forints, the contracting authority should publish, within 30 days of the conclusion of the contract, the full written communication of the decision preparation — the market consultations, the enquiries used to determine the estimated value and the correspondence conducted with the government actors concerned — with itemised, reasoned redaction of business secrets and personal data. The addressee of the rule is the contracting authority, its legal form is a supplement to the implementing decree of the public procurement act, and the date of entry into force is the essential point: from the 2027 budget year, that is, for the entire remaining term of the present government. This is exactly the function of the general rule described by Smith — it does not leave the judgement of the individual case to the person concerned, but states in advance what has to be done.

3.2 A pre-established reasoning template for urgent procedures without prior publication (within 60 days)

The negotiated procedure without prior publication is a lawful instrument if there really is no time for an open procedure because of an unavoidable cause — in the case of 20 August the insolvency of the previous organiser may have been such a cause. The problem is that urgency is difficult to verify after the fact: the invocation takes place, the demonstration does not. MIAK proposes that the Public Procurement Authority should issue a mandatory reasoning template requesting four items of data in numerical form: when the unavoidable circumstance became known, how much time was left until performance, what alternative procedural route the contracting authority considered and why it rejected it, and how many market actors it approached and on the basis of what selection criterion. The completed template should become public at the same time as the call. This does not narrow the possibility of a lawful urgency procedure — it merely makes it verifiable whether the urgency really existed. The chain-examination principle of Kautilya is the structural equivalent of this: it makes not the final outcome but the individual links of the decision chain separately assessable.

3.3 Publication of the findings of the interior ministry investigation even if it finds no irregularity (within 15 days of the closure of the investigation)

The outcome of the internal investigation now ordered can be of two kinds: it finds an irregularity, or it does not. According to MIAK the same consequence is required in both cases: a public, itemised list of findings. If the investigation establishes an irregularity, publicity is self-evident. If it does not, then publicity is even more important — for without it the statement “we have examined it, everything is in order” is no more verifiable than the original suspicion. The published material must contain which documents the investigation reviewed, whom it heard, and on which questions it reached no finding. This is the application of the logic of the A2 procurement transparency programme point to official self-examination, and at the same time the precondition of the A5 whistleblowing system: it is worth making a report only where the fate of the report is visible.

The three proposals are linked by a single principle, and for MIAK this principle is not a rhetorical turn: a rule is a rule if it also binds the one who makes it. A publication obligation announced in advance and independent of the government is worse for any government in the short run and better for every government in the long run — because it takes out of its hands that discretion whose exercise always remains suspect after the fact.

Part IV — Expected effects and risks

Dimension Expected effect Risk
Public finances The publicity of decision preparation narrows the space for prior coordination; according to international experience a transparent procedural order carries a substantive price effect The administrative burden of publication falls disproportionately on smaller contracting authorities — this is why the 500 million forint threshold is needed
Public administration The reasoning template makes the urgency procedure verifiable, and standardises the practice which at present differs from contracting authority to contracting authority If the template is too rigid, it causes delay in genuinely urgent cases; in event organisation this is a performance risk
Culture and the events sector Itemised cost publication also improves the comparability of state expenditure for cultural purposes The events market is concentrated; if the predictable actors drop out and there is no new entrant, competition remains formal — publicity does not in itself create supply
Political trust If the present government extends the rule to itself as well, it creates a precedent which can be invoked in the next term If the rule brings only retrospective tightening, it becomes an instrument, and at the next change of government it will be used in the same way — this is the most real risk

The key question is the timing of entry into force. The proposals tip to the risk side if the rule tightens retrospectively but does not bind prospectively: for then it becomes not an instrument of transparency but the procedural weapon of the majority of the day. The second question of judgement arises from the structure of the sector. In the events market — as the government commissioner himself put it in an earlier radio interview — there are few substantive actors, and the concentration that has developed in recent years will not disappear because of one rule. Publicity shows the lack of competition, but does not eliminate it; for that, the breaking down and standardisation of the subject of procurement is needed, which the approach discussed in subsection 6.4.3 recommends as an operational instrument.

Part V — Measurability and summary

5.1 What is worth following? (proposed KPIs)

MIAK proposes the following performance indicators (KPIs, Key Performance Indicators) for monitoring — these are proposed measures for the public, not government commitments:

  • The publication time of the findings of the interior ministry investigation — proposed target: within 15 days of the closure of the investigation, with an itemised list of findings, irrespective of the outcome.
  • The share of negotiated procedures without prior publication within state event procurements — proposed target: publication of an annual, public time series; in the A2 programme point MIAK proposes a target below 15 per cent for the share of single-bid procedures.
  • The publication coverage of decision-preparatory communication for event procurements above 500 million forints — proposed target: 100 per cent from the 2027 year, with itemised reasoning of the redactions.
  • Itemised cost publication for state ceremonial events — proposed target: by 30 September of every year, in an itemised breakdown, in a structure comparable with the previous year (for the year 2026 the ministry has already made a comparative claim about a quarter of last year’s costs; it is worth supporting this with a verifiable data series).

5.2 Summary

MIAK’s request: let the Ministry of the Interior publish the findings of the investigation irrespective of the outcome, and let the legislator extend the publication obligation to the phase of decision preparation — with an entry into force announced in advance which also binds the present government. What is at stake is not the price of one event. What is at stake is whether public procurement publicity remains accidental — that is, dependent on whether a body of correspondence reaches an editorial office — or becomes a rule.

Two MIAK foundational values are in play. Non-ideological judgement, because the assessment of this question cannot depend on which side is in power: an analysis which would have judged this same set of facts strictly four years ago cannot judge it more leniently now. And accountability, because decision preparation is the phase in which the real decision is born — if this remains outside publicity, then accountability will always examine what has already been decided. The case of 20 August is important not because it concerns a large sum, but because it is the first occasion on which the new government meets its own standard.

Part VI — Justifications and further sources

6.1 The framing of the press, spectrum by spectrum

This topic is one of those rare matters which the entire political spectrum carried as a lead item — the framing, however, differed sharply. The liberal-left band reconstructed the set of facts and the chain of responsibility: Telex set out the chronology of the correspondence in detail in two articles (the relation between the official call of 7 July and the discussions weeks earlier), and published the responses of both persons concerned in full. 444.hu carried the same thread, supplemented with the background of the earlier change of organiser and with Miklós Zelcsényi’s earlier case. It is striking that this band did not make the matter side-independent: Telex placed the government commissioner’s response and the sentence uttered in the radio interview, “there is no such thing as building something up from zero”, next to each other — that is, the reporting is itself evaluative in structure.

The public affairs band chose the frame of official inaction. The article of 24.hu highlighted that in response to their earlier enquiry not a single authority had launched an investigation, and presented the present interior ministry step in relation to this background. This frame asks about institutional reaction time, not about individual responsibility.

The conservative band approached from the direction of personal responsibility. Magyar Nemzet carried the news with the label “sleaze”, while Mandiner devoted two separate articles to the matter: one reported the ordering of the investigation, the other put Ákos Hadházy’s claims about the government commissioner’s role in the correspondence into the headline. In this frame the case is primarily a test of the credibility of the present government; the general problem of the procedural order without prior publication — which was a recurring question in earlier terms as well — does not appear. ATV carried the question (“was it fixed already before the tender?”) in video form, leaving it open.

The three bands together trace an absence: none of the framings posed the regulatory question, namely why decision-preparatory communication does not belong to the range of data that must be published. The case thus runs as a dispute about persons, while the pattern is recurrent.

6.2 Facts and data

Data Value Source
The day the investigation was ordered 26 August 2026 Communiqué of the Ministry of the Interior, Telex / 444.hu / 24.hu, 26 August 2026
The official date of the invitation to tender 7 July 2026 (three invited companies) Telex, after G7, 26 August 2026
The start of the documented prior discussion mid-June 2026 (Zelcsényi–Lounge meeting) Telex, after G7, 26 August 2026
The type of procedure negotiated without prior publication Telex, 26 August 2026
The number of published screenshots 6, on 5 of which Márk Radnai is addressee or copied in Telex / 444.hu, 26 August 2026
The ministry’s cost claim about a quarter of last year’s costs Communiqué of the Ministry of the Interior, 24.hu, 26 August 2026
Parallel procedures criminal complaint of Mi Hazánk (suspicion of an agreement restricting competition); public interest disclosure of the Fidesz parliamentary group to the Public Procurement Authority Telex, 26 August 2026

The table makes a single connection vivid: roughly three weeks elapsed between the documented prior discussion and the official invitation to tender. This is the time window about which the public procurement publicity rules in force require no data whatsoever — and in which the outcome of the procedure is largely decided. The cost ratio communicated by the ministry (a quarter of last year’s costs) neither refutes nor supports in itself the suspicion of a restriction of competition: a lower price may also derive from narrowed competition, if the basis of comparison was itself distorted. This is why MIAK proposes itemised cost publication in a comparable structure going back several years.

6.3 Policy dimensions

  • Transparency and anti-corruption policy (programme points) — the A2 procurement transparency point prescribes machine-readable publication of procedural data and anomaly flagging; the A5 whistleblowing system is concerned because the present case started from correspondence that reached the press, not from a reporting channel; the A6 checks and balances point relates to the verifiability of official self-examination.
  • Public administration and e-government (programme points) — the KI3 measurable reduction of bureaucracy provides the framework for ensuring that the proposed publication obligation is not a new administrative layer: the decision-preparatory correspondence is an already existing document, only its publication is missing.
  • Culture (programme points) — the KU5 open culture financing programme point proposes itemised publication of the cost of state events; the event of 20 August is its largest annual item by volume.

6.4 Literature in detail

6.4.1 Adam Smith: The Theory of Moral Sentiments

Smith distinguishes two points in time for self-examination: before we act, and after we have acted. In both we are partial, but his diagnosis is sharper than this.

“Our views are apt to be very partial in both cases; but they are apt to be most partial when it is of most importance that they should be otherwise.”

According to Smith this self-deceit causes “half the disorders of human life”. The essence of the argument, however, is not moralising but the conclusion: since self-judgement becomes distorted precisely at the decisive moment, nature — in Smith’s formulation — has not left us without a remedy, but we form general rules about what is proper and what is to be avoided out of our continual observations of the conduct of others. In the case of 20 August precisely this structure can be observed. The responses of those concerned — “I did not conduct the procurement”, “I did not read the letters”, “I only assisted in the creative concept” — are all individual, retrospective self-judgements, and all of them may be entirely reasonable seen from within. MIAK’s proposal is not about their sincerity. The question is whether the system is built on the general rule or on individual self-judgement: if the publication of decision-preparatory correspondence is an obligation announced in advance, then no one has to make a statement afterwards about their own impartiality.

📖 Source: Adam Smith: The Theory of Moral Sentiments

6.4.2 Kautilja: Arthashastra

The Arthashastra lists forty ways of embezzling public money, and attaches a sanction to each. For the reader of today, however, the most interesting thing is not the list but the procedural rule that follows it.

“the persons concerned, such as the treasurer (nidháyaka), the prescriber (nibandhaka), the receiver (pratigráhaka), the payer (dáyaka), the person who caused the payment (dapaka), the ministerial servants of the officer (mantri-vaiyávrityakara) shall each be separately examined.”

The essence of the structure is that payment is not a single decision but a chain — and the examination of responsibility takes place link by link, including the person who caused the payment, not only the one who signed it. In the case of 20 August this distinction decides what the relevant question is. Most of the arguments voiced in the debate are about who had formal competence in the procedure: according to the head of the organising company he did not conduct the procurement, according to the government commissioner he had no competence in state event organisation. In Kautilya’s framework this does not close the question, it merely places it: the role of each actor in the chain is to be examined separately, and the category of “the person who caused the payment” covers precisely the one who has no formal right of signature but nevertheless sets the decision in motion. MIAK’s proposal 3.2 — the separate documentation and publicity of the individual steps of the decision chain — is the present-day equivalent of this two-thousand-three-hundred-year-old procedural principle.

📖 Source: Kautilja: Arthashastra

6.4.3 Robert Klitgaard: Controlling Corruption

In his case study of Korean procurement for the American army, Klitgaard documents how collusive bidding works in practice. The local suppliers did not develop their price offers independently of one another but decided at prior meetings the price to be announced, who would be the lowest bidder, and also how they would divide the profit arising from the cooperation among themselves — recording their decisions on a standard form. The lesson is not that every prior contact is collusion; market consultation is a lawful and in many cases necessary instrument. The lesson is that the chronological relation between the prior exchange of information and the formal competition is in itself a diagnostic piece of data — which is why it has to be documented.

Klitgaard sees the solution not primarily in sanctions. He recommends redefining the objective of the organisation and the subject of procurement: if an office purchases a service tailored to an individual need, the purchasers cannot establish the competitive price, and this difficulty in itself increases the chance of abuse; if the same office purchases a standardised service with a known price, the procurement fits its needs less well, but the corruption risk falls drastically. In the case of state ceremonial events this can be translated into a concrete proposal: “full-scale event organisation” as a single procurement with an individual subject can be broken down into independently priceable, comparable elements — stage technology, security service, pyrotechnics, sound — for which the market price can be established. MIAK proposes that this breakdown be considered in the planning of the 2027 event cycle.

📖 Source: Robert Klitgaard: Controlling Corruption

6.5 International comparison

The Ukrainian ProZorro system is the most frequently cited example: alongside the online, public documentation of the entire procurement process the share of single-bid procedures fell substantially, and the system brought significant annual savings — the A2 programme point uses this case as a basis of comparison. The Korean KONEPS achieved a double-digit cost reduction with a fully electronic procedural order. The common feature of both systems is that they did not strengthen the sanction but the availability of data — the risk of breaking the rules grew because the deviation became visible.

From the point of view of the Hungarian situation the lesson of the Slovak e-Zmluvy contract register is the more direct: there publication is not a subsequent report but a condition of validity — a state contract that has not been made public does not enter into force. This solution is interesting from the point of view of the present case because it does not entrust enforcement to supervision but ties it to the legal effect of the contract. In the case of decision-preparatory communication MIAK does not propose such a radical solution — there the 30-day subsequent publication is proportionate — but in the field of contracts the adoption of the Slovak model is part of the A1 programme point.

Transparency and anti-corruption policy

  • A1 — Public money dashboard
  • A2 — Procurement transparency
  • A5 — Whistleblowing system
  • A6 — Strengthening checks and balances

Public administration and e-government

  • KI3 — Measurable reduction of bureaucracy

Culture

  • KU5 — Cultural participation index and open culture financing

Proposed new programme point: Decision-preparation publicity — for the Transparency and anti-corruption policy area: mandatory subsequent publication of the written communication preceding the issue of the call in state procurements above the threshold value, with itemised, reasoned redaction.

6.7 List of sources

Press sources (MIAK press monitor, 27 August 2026 — topic 2):

Knowledge base references (literature):

  • 📖 Adam Smith: The Theory of Moral Sentiments
  • 📖 Kautilja: Arthashastra
  • 📖 Robert Klitgaard: Controlling Corruption

MIAK internal materials:

  • MIAK policy area: Transparency and anti-corruption policy (programme points; programme point ID: A1, A2, A5, A6)
  • MIAK policy area: Public administration and e-government (programme points; programme point ID: KI3)
  • MIAK policy area: Culture (programme points; programme point ID: KU5)
  • MIAK press monitor, 27 August 2026 — topic 2, score: 93/100

Supplementary public data sources:

  • Electronic Public Procurement System (EKR) — procedural data
  • Public Procurement Authority — annual report and remedies statistics
  • European Commission — Single Market Scoreboard, public procurement indicators
  • OLAF — annual report

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