Part I — Situation overview

On behalf of the Government, Ruff Bálint, the minister heading the Prime Minister’s Office, submitted to Parliament on 24 October 2026 the bill on the conflict-of-interest rules for participation in organisations operating in the field of sport (Telex, HVG). The bill covers ministers, state secretaries and other senior political officials, members of the Hungarian and European Parliament, party leaders, presidents of county assemblies, and the executives of majority state-owned companies. During their term of office and for four years after it ends, they may not be presidents, vice-presidents, board members or senior employees of a sports club, sports federation or sports company (HVG, 24.hu). This personal incompatibility applies only to organisations that had at least 500 registered athletes in the previous year. The bill also introduces an objective integrity exclusion: for four years, nobody may be a sports executive if, during their leadership, irregularities were found at the organisation in the use of state support for sport, regardless of whether they were personally responsible (HVG). The law would enter into force on the 45th day after its promulgation (24.hu). According to Kálnoki-Kiss Attila, State Secretary for Sport, the general debate may take place in early November and the final vote at the end of November.

The background is the overhaul of sport financing. The tao — the tax benefit allowing part of corporate tax to be offered for sports purposes — ends on 1 January (24.hu). The state secretariat examined the 2022–2026 accounts of the six spectator team sports: in this period some HUF 500.8 billion went to nearly 2,500 sports organisations, and in more than 500 cases the amount reclaimed was not repaid (Telex). Prime Minister Magyar Péter announced the rule on 18 September, saying that sport had been “turned into a zone of political influence” (444.hu, Index). In July MIAK called for transparent accounting of sport financing (Reshaping sport financing) and for a cooling-off period after political office (the revolving-door phenomenon and the missing cooling-off period), and in October for a public allocation rule for the HUF 150 billion replacing the tao.

The bill is weak on one important point. According to HVG’s summary, the exclusion applies only to new elections and appointments after entry into force, so the office of an incumbent leader does not end because of it. Ferencváros is holding its board-election general meeting on 27 October, before entry into force, where Kubatov Gábor, who has led the club since 2011, has been nominated again (24.hu). In MIAK’s reading, the principle is right, but today the rule spares precisely those for whom it was made: a well-timed re-election can push back its effect by years.

Part II — Grounding in the literature

Three sources provide a framework for assessing the bill. Susan Rose-Ackerman, professor at Yale University and one of the leading researchers of the economic analysis of corruption, argues in Corruption and Government that a conflict of interest is dangerous even without bribes. If a politician has an interest in an organisation that receives state money, the risk of favouritism is the same as with bribery. Montesquieu, the 18th-century French legal philosopher and classic author of the separation of powers, writes in The Spirit of the Laws that a person entrusted with power tends to abuse it. Power must therefore be checked by power. The Fundamental Law of Hungary, for its part, both protects freedom of association and lays down that a fundamental right may be restricted only to the extent strictly necessary and in proportion to the aim. This standard determines both the breadth of the exclusion rules and the transitional situation of incumbents. The detailed discussion of the literature — 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. The first closes the loophole of re-election before entry into force, the second aligns the scope of the rule with the amount of public money, and the third makes implementation public.

3.1 Closing the re-election loophole: a uniform deadline for incumbent leaders (by amendment in the detailed debate, before the final vote)

According to the text summarised in the press, the office of an incumbent sports executive does not end merely because of the new ground for exclusion (HVG). Yet the bill’s explanatory memorandum speaks of providing “adequate time” to end the conflict of interest. There is tension between the two statements, and the practical consequence is already visible: at Ferencváros’s board-election general meeting on 27 October, the club’s current president has been nominated again, because the law cannot enter into force before November (24.hu). According to Rose-Ackerman’s analysis (see 6.4.1), the risk of favouritism exists not on election day but throughout the entire term of office. A fresh, multi-year mandate therefore maintains the very risk the law seeks to eliminate. MIAK proposes that Parliament, by amendment in the detailed debate, clearly lay down that the office of a leader who is in a conflict-of-interest situation at entry into force ends at the end of a uniform, reasonable grace period (for example, six months after entry into force), unless they resign from their political office by then. This period is enough for the organisation to elect a successor. A re-election held after the bill’s submission, that is, after 24 October 2026, should not grant an exemption. The proportionality standard of the Fundamental Law (see 6.4.3) supports this solution: a grace period is gentler than immediate termination, but it does not postpone achieving the aim by years. The proposal applies programme point G6 against regulatory capture, that is, ensuring that regulated organisations cannot fall within the sphere of interest of decision-makers.

3.2 Supplementing the threshold with a public-money criterion, with a public impact assessment (before the general debate, by the first days of November 2026)

Personal incompatibility applies only to organisations with more than 500 registered athletes. Headcount is a good proxy for an organisation’s weight, but not for the amount of public money. An organisation with few registered athletes but large state or municipal support, such as a priority academy or a sports company, may fall outside the rule. Municipal mayors are also missing from the list summarised in the press, even though the municipality is often an important supporter of local clubs. MIAK proposes two steps. First: personal incompatibility should also cover every sports organisation that received at least HUF 100 million in state or municipal support in the previous year, regardless of headcount. Second: the Government should publish the bill’s impact assessment before the general debate. It should show how many organisations reach the 500-athlete threshold, how many would be covered by the financial criterion, how many current leaders the ban affects, and how many organisations would have to hold board elections. The impact assessment should also address whether including mayors is justified for organisations supported by the municipality they lead. A restriction on freedom of association is proportionate only if the legislator knows whom it affects and why the line is drawn exactly there (see 6.4.3). The proposal applies programme point I3 on legislative impact assessment.

3.3 A public register of declarations and a list of exclusions (from entry into force, with the implementing rules)

Under the bill, candidates must declare before taking office, and incumbents at entry into force, whether a conflict of interest or ground for exclusion applies to them (HVG). If these declarations are kept only in the organisation’s files, nobody outside can check compliance with the rule. MIAK proposes that the ministry responsible for sport publish the declarations and the final integrity exclusions by organisation, by name, in machine-readable form. They should include the reason for the exclusion, its start and end, and which funder’s decision it was based on. The register should be comparable with the support data, so that it is visible which organisations receive public money and who leads them. Montesquieu’s thesis (see 6.4.2) applies here from the side of publicity: the power of sports executives is checked by the public and by the funder’s capacity to scrutinise. The objective, fault-independent exclusion is a legitimate tool, because the board is jointly responsible for how the money is used. The implementing rules should, however, lay down that an exclusion may be entered in the register only after a final funder’s decision or judicial review. The proposal extends to sport the machine-readable, comparable declaration logic of asset-declaration programme point A3 and the principle of the public-money dashboard of A1.

A common principle links the three proposals: the credibility of a conflict-of-interest rule comes not from its strictness but from the fact that it cannot be circumvented. According to the literature, the risk of political influence exists throughout the entire term of office, power can be checked only by other power or by publicity, and the restriction must be proportionate and justified.

Part IV — Expected effects and risks

Dimension Expected effect Risk
Sports organisations The choice of leaders shifts towards professional suitability; support does not depend on the leader’s political connections Leadership uncertainty may arise during the grace period; some organisations may retain the old influence through front men
Public money The financial threshold also brings in high-support, low-headcount organisations; the register compares support and leadership A new loophole may open below the 100-million limit if support is split across several organisations
Legal certainty and fundamental rights The impact assessment and the uniform grace period make the restriction of freedom of association more proportionate Terminating incumbents’ offices may trigger a constitutional dispute if the grace period is too short
Public administration A public list of declarations and exclusions makes checking simple The ministry’s data-management burden grows; publication by name requires a careful data-protection rule

The most important trade-off lies in proposal 3.1. Ending incumbents’ offices is a stronger intervention in the autonomy of sports organisations than restricting future elections. It therefore meets the proportionality standard of the Fundamental Law only with a justified, uniform grace period. If, however, the rule applies only to the future, nothing changes for years at some of the organisations funded by public money, and the purpose of the law is hollowed out. MIAK considers the grace period the balance between the two. The risk of proposal 3.2 is that with any numerical threshold there will be someone who stays just below it. This is mitigated if the financial criterion counts together the support of organisations belonging to the same group, for example a club and the company it has founded. For proposal 3.3, the key is the balance between publication by name and personality rights. MIAK therefore proposes publishing only final decisions.

Part V — Measurability and summary

5.1 What is worth tracking? (proposed KPIs)

MIAK proposes tracking the following key performance indicators (KPIs):

  • Impact assessment: whether the impact assessment is public before the general debate, with the number of organisations and leaders affected, broken down by headcount and support.
  • Transitional rule: whether the text adopted at the final vote contains a uniform grace period for incumbent leaders and rules out exemption for re-elections held after submission.
  • Leaders affected: at the end of the grace period, how many sports organisations reaching the 500-athlete or the financial threshold are still led by a person who holds, or has held within four years, political office (target value: zero).
  • Register: whether a machine-readable list of declarations and final exclusions is available six months after entry into force.

5.2 Summary

MIAK supports the aim of the sports conflict-of-interest bill and asks Parliament to strengthen it on three points before the final vote. It should close the loophole of re-election before entry into force with a uniform grace period, add a public-money criterion alongside the headcount threshold, and the Government should publish the impact assessment before the general debate. In implementation, the declarations and final exclusions should be public. Two of MIAK’s foundational values are at stake. Accountability, because the leader of an organisation funded by public money must answer to the funder and the public, not to their political connections. And transparency, because a conflict-of-interest rule protects only if it can be checked from the outside who leads the supported organisations.

Part VI — Reasoning and further sources

6.1 Press framing by spectrum

Liberal-left band. Telex highlighted the fact of submission and the state secretary’s statement, and in a separate article published his post denying rumours of his resignation, along with the data on reclaiming tao accounts. HVG was the most detailed: it listed whom the bill excludes and from which positions, presented the objective integrity exclusion, and pointed out that incumbents’ offices do not end merely because of it. 444.hu put the emphasis on the personal side: in its headline it named Kubatov Gábor and Deutsch Tamás as the bill’s main targets.

Public-affairs band. Alongside the state secretary’s quotes, 24.hu highlighted the date of entry into force and the exclusion based on irregularities in support, and in a subscriber article discussed the phasing out of tao in the frame of “the fear of chaos replacing the hopes of regime change” (only the introduction of the article was publicly available). Index followed the MTI report and listed which well-known politician club presidents the rule affects. In the material processed, ATV did not cover the topic.

Economic band. In the material processed, Portfolio did not deal with the bill.

Government-critical conservative band. In the material processed from Magyar Nemzet, no separate article on the submission appeared; material from Mandiner and Népszava was not in the processed set.

6.2 Facts and data

Item Value Source
Submission 24 October 2026, by the minister heading the Prime Minister’s Office on behalf of the Government Telex; HVG
Offices covered minister, state secretary and other senior political official, government commissioner, ministerial commissioner, member of the Hungarian Parliament and MEP, party leader, county assembly president, executive of a majority state-owned company HVG; 24.hu; Index
Excluded sports executive positions president, vice-president, board member, senior officer, senior employee, trustee of a youth-development foundation HVG; 24.hu
Cooling-off period 4 years after the end of office HVG; 444.hu
Headcount threshold at least 500 registered athletes in the previous year (for personal incompatibility) HVG
Integrity exclusion 4 years from delivery of the notice establishing the irregularity, regardless of headcount and fault HVG
Entry into force the 45th day after promulgation 24.hu
Timetable general debate in early November, final vote at the end of November Kálnoki-Kiss Attila, quoted by Telex, HVG
Tao support in the six spectator team sports some HUF 500.8 billion, nearly 2,500 organisations, 2022–2026 Telex, 24 October 2026
Reclaimed tao more than HUF 21 billion, of which more than HUF 7 billion could not be recovered; more than 500 cases at the National Tax and Customs Administration (NAV) Telex, 24 October 2026
FTC board-election general meeting 27 October 2026 24.hu, 19 October 2026

6.3 Policy dimensions

  • Transparency and anti-corruption policy (programme points) — a machine-readable register of declarations (A3), comparability of sports support and leaders (A1), institutional checks (A6);
  • Justice (programme points) — the bill’s impact assessment and the proportionality of restricting freedom of association (I3);
  • Economy (programme points) — the logic of regulatory capture and the revolving-door ban (G6);
  • Public administration and e-government (background material) — the register-keeping and oversight tasks of the ministry responsible for sport.

6.4 Literature in detail

6.4.1 Susan Rose-Ackerman: Corruption and Government

In the section on elected politicians, Rose-Ackerman starts from the premise that in modern democracies the main danger is no longer dependence on the ruler but the use of public office for private interest. In her argument, a conflict of interest always exists if a politician or their circle has an interest in an organisation that receives money from the state or benefits from state decisions. In such cases no bribe or campaign donation needs to change hands: the risk of favouritism is the same. The author also shows that in some countries ministers chair the boards of state-owned enterprises, which weakens the autonomy of those organisations. She also warns that in new democracies dealing with conflicts of interest rarely gets priority, even though, unchecked, it undermines the legitimacy of government just as much as the influence of large donors. Applied to Hungarian sport: a politician leading a club does not necessarily do anything unlawful, yet the risk stems from the position, so the rule must address the position, throughout the entire term of office (3.1).

📖 Source: Susan Rose-Ackerman: Corruption and Government — Causes, Consequences, and Reform (1999), section on political conflicts of interest (paraphrase)

6.4.2 Montesquieu: The Spirit of the Laws

Montesquieu links political liberty to moderate governments, and holds that liberty exists where power is not abused. He describes the condition for this as follows:

“Constant experience shows us that every man invested with power is apt to abuse it, and to carry his authority as far as it will go. […] To prevent this abuse, it is necessary from the very nature of things that power should be a check to power.” (MIAK’s own translation from the Hungarian rendering)

The idea is the basis of the separation of powers, but it also applies to sports governance. If the same person decides on, or influences, the allocation of public money and also leads the organisation receiving the money, the two roles do not check each other. The conflict-of-interest rule creates this separation. The public register of declarations (3.3) is the tool of external oversight.

📖 Source: Montesquieu: The Spirit of the Laws (De l’esprit des lois, 1748), Book XI, Chapter 4

6.4.3 Fundamental Law of Hungary

Under Article VIII(2) of the Fundamental Law, “Everyone shall have the right to establish and join organisations.” Sports clubs and sports federations are based on this freedom of association, and electing their leaders is the right of their membership. The exclusion rules restrict this right. Article I(3) is therefore the standard:

“A fundamental right may only be restricted to allow the effective use of another fundamental right or to protect a constitutional value, to the extent absolutely necessary, proportionate to the objective pursued and with full respect for the essential content of that fundamental right.” (MIAK’s own translation from the Hungarian rendering)

The fair use of public money and the functioning of the sports sector free from political influence are legitimate aims. Proportionality, however, requires knowing whom the restriction affects (3.2), and the situation of incumbents must be settled with a gentle but real grace period (3.1).

📖 Source: Fundamental Law of Hungary (text in force, 17 April 2026), Article I(3), Article VIII(2)

6.5 International comparison

International sports organisations. The ethical rules of the International Olympic Committee treat the political neutrality and autonomy of sports organisations as a fundamental principle. The Hungarian bill enforces this at national level, by legislative means.

Cooling-off periods in other fields. Several European countries require members of government and senior officials to observe a cooling-off period before they can take on a leading role at an organisation on whose matters they previously decided. The four-year cooling-off period in the Hungarian bill is stricter than this, which is why it is especially important that the transitional rule be clear too.

The practice of EU member states. According to Rose-Ackerman’s summary (see 6.4.1), almost all EU member states require members of parliament to declare their financial interests, but there are significant differences in whether the declarations are public and whether there are sanctions. The lesson for proposal 3.3: a declaration is effective only together with publicity and sanctions.

Transparency and anti-corruption policy

  • A1 — Public-money dashboard
  • A3 — Publicity of asset declarations
  • A6 — Strengthening checks and balances

Justice

  • I3 — Legislative impact assessment

Economy

  • G6 — Programme against rent-seeking and regulatory capture

Proposed new programme point: A uniform conflict-of-interest standard for leading organisations funded by public money — a headcount- and support-based threshold, a uniform grace period for incumbents, a public, machine-readable register of declarations — for the Transparency and anti-corruption policy area.

6.7 List of sources

Press sources (MIAK press monitor, 25 October 2026 — topic 4):

Supplementary press source:

Knowledge-base references (literature):

  • 📖 Susan Rose-Ackerman: Corruption and Government — Causes, Consequences, and Reform (1999)
  • 📖 Montesquieu: The Spirit of the Laws (De l’esprit des lois, 1748)
  • 📖 Fundamental Law of Hungary (text in force, 17 April 2026)

MIAK internal materials:

  • MIAK policy area: Transparency and anti-corruption policy (programme points; programme point ID: A1, A3, A6)
  • MIAK policy area: Justice (programme points; programme point ID: I3)
  • MIAK policy area: Economy (programme points; programme point ID: G6)
  • MIAK policy area: Public administration and e-government (background material)
  • MIAK press monitor, 25 October 2026 — topic 4, score: 71/100

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