Part I — Situation overview

On Monday, 26 October, the price of natural gas per megawatt-hour on the Dutch TTF (Title Transfer Facility, the benchmark exchange of European gas trading) rose above EUR 97. It last traded at this level almost four years ago. According to OTP Global Markets, quoted by 24.hu, the market expects Qatari LNG deliveries (LNG: liquefied natural gas) to be missing entirely this winter. According to data for 22 October, European storage is 75 per cent full, compared with an average of 86 per cent over the previous five years. On the same day MOL announced on the Budapest Stock Exchange that, together with its subsidiaries, it is reclaiming some HUF 133 billion in carbon-dioxide emission-quota tax and interest. According to HVG, the Tisza government abolished this tax retroactively as of the end of July. Earlier, in April, the Court of Justice of the European Union took the position in the Nitrogénművek case that the tax may be contrary to EU law, and the European Commission launched infringement proceedings.

The third strand is Paks. According to an HVG analysis of 26 October, on 21 October one of the turbine generators of Unit 1 tripped because of a protection action, and the plant immediately lost 242 MW of capacity. The completion date of the overhaul of Unit 4 has been changed nine times since 14 October. According to HVG, the budgetary burden of the utility price cut is HUF 800–900 billion a year. Portfolio puts the 2027 allocation at HUF 1,165 billion. On 3 October (consumption-banded utility support) MIAK asked for the support to be targeted. On 2 October (a public infringement case list) it asked for transparency on the legal disputes with Brussels, and on 24 October (household energy programmes) for the renovation programme to be measurable.

The new element of the current situation is the timing: the shock comes at the start of the heating season, before the restructuring planned for the spring. In MIAK’s reading, the risk is not a single price jump. The gas price, the refund of unlawful special taxes inherited from the previous term and the outages of domestic power generation burden the budget in the same month, without decision rules fixed in advance.

Part II — Grounding in the literature

Three sources provide a framework for assessing the situation. The March 2026 interim report of the Organisation for Economic Co-operation and Development (OECD) analyses the current Middle East energy-price shock. According to its recommendation, crisis measures should be fast, targeted at those most in need, preserve the incentive to save energy and contain a clear expiry rule. Its adverse scenario assumed a TTF price of EUR 77; Monday’s price is higher still. The 2023 World Economic Outlook of the International Monetary Fund (IMF) summarises the lessons of European energy subsidies and warns that fiscal buffers have been depleted in many countries, so attention must be paid to managing fiscal risks. According to the report by Nicholas Stern (British economist, former chief economist of the World Bank), commissioned by the UK Treasury, energy security is strengthened by efficiency, the diversification of sources and a clear, long-term regulatory framework for investors. 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 steps. The first fixes in advance what happens when the gas price rises, the second makes the refund of inherited special taxes visible and covers it, and the third improves the transparency of outages in domestic power generation.

3.1 A threshold-based winter gas-price protocol and a monthly cost-sensitivity table (government resolution by 15 November 2026)

On a proposal from the Ministry of Economy and Energy, the Government should lay down in a government resolution which step follows which market signal during the winter season. MIAK proposes three stages. Monitoring: if the 30-day average of the TTF is above EUR 80, or domestic storage filling falls 10 percentage points (pp) short of the five-year average, the ministry issues a weekly public situation report on storage, procurement and the expected cost of utility-price protection. Alert: if the price stays above EUR 100 for ten consecutive trading days, targeted compensation in the lower income bands starts automatically, under conditions and with an expiry date defined in advance in accordance with programme points G25 and K7. The method of targeting is described in MIAK’s proposal of 3 October, so this proposal does not go into it. Crisis: in the event of an actual supply disruption, the protocol follows the crisis levels of the EU gas security-of-supply rules. Each of the three stages should be accompanied by a monthly table showing how much a EUR 10 price move changes the annual cost of utility-price protection. In the OECD framework (see 6.4.1), this is the precondition of a “timely, targeted, expiring” measure: the rule is not made in the middle of winter.

3.2 A refund reserve and a public risk statement on special taxes conflicting with EU law (with the 2027 budget bill)

According to HVG, the companies concerned could reclaim the abolished emission-quota tax within 90 days, with interest two percentage points above the central bank base rate, and MOL expects payment still in 2026. MOL’s 133 billion is therefore not a distant risk but an item in this year’s or next year’s budget. The amount of other companies’ claims is not publicly known. MIAK proposes that the Ministry of Finance publish, as an annex to the 2027 budget bill, how many refund claims have been received for the emission-quota tax, for what amount and with what interest, and in which year payment is expected. The bill should contain a separate reserve line for this, rather than covering it from the general reserve. The statement should cover every special tax from the previous term that is subject to infringement proceedings or court litigation. This is the financial counterpart of the case list of 2 October. Since the interest grows every month, payment must be made without delay once the decisions become final. In the IMF framework (see 6.4.2), this makes the fiscal risk visible (G1, G23).

3.3 A Paks outage-reporting rule and a quarterly security-of-supply report (by 31 December 2026)

According to HVG, in the outage of 21 October the plant’s data release retroactively placed the start of the event at midnight, and changed the expected time of restoration six times in six hours. A notice appeared on the plant’s own website only at noon. This is not a safety issue but an information issue — yet the market and the system operator plan on its basis. MIAK proposes that the Ministry of Economy and Energy initiate a rule that unplanned shutdowns at Paks must be announced within one hour, with a fixed timestamp and a revision log, on top of the existing EU energy-market disclosure obligations. A quarterly security-of-supply report should be published on unplanned outages, lost generation, the estimated cost of replacement and winter reserves, cross-checked against the data of MAVIR (the operator of the Hungarian electricity system). In Stern’s framework (see 6.4.3), predictable, public information is part of energy security (K7, K2).

The three proposals are linked by one principle: winter risks must be managed in advance, with rules and public figures, not with ad hoc decisions. The lesson of the OECD and the IMF is the same. The crisis measures of 2022–2023 were often untargeted and expensive, because the rules were written when the damage had already been done.

Part IV — Expected effects and risks

Dimension Expected effect Risk
Economy a more predictable budget; the market can foresee the government’s reaction; the emission-quota tax refund does not cause a surprise on the deficit path public thresholds may in themselves create expectations; part of the reserve line has to be taken from other spending
Society households in need get help faster if the gas price stays high for long if the thresholds are too high, help starts late; if too low, too often
Public administration clear owners and deadlines; fewer improvised decisions weekly and monthly data reporting is an extra burden for the ministry and the power plant
Security of supply the system operator and the market plan on more accurate information fast reporting may be inaccurate at first; hence the need for a revision log

The main question to weigh is the balance between flexibility and predictability. A protocol fixed in advance leaves the Government less room for manoeuvre, but reduces the risk of rushed decisions and untargeted spending. The proposal tips over to the risk side if the thresholds are not reviewed: the protocol must therefore be evaluated after every heating season. The refund reserve narrows the budgetary room for manoeuvre in the short term. Payment, however, cannot legally be avoided, so the only question is whether the item will be foreseeable or come as a surprise.

Part V — Measurability and summary

5.1 What is worth tracking? (proposed KPIs)

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

  • Protocol: whether the three-stage winter gas-price protocol appears in a government resolution by 15 November 2026, with thresholds, owners and an expiry rule.
  • Cost sensitivity: whether, in every month of the heating season, it is published how much a EUR 10 gas-price move changes the annual cost of utility-price protection.
  • Refund statement: whether the 2027 budget bill contains a separate reserve line and a claim-by-claim summary of refunds of the emission-quota tax and the other disputed special taxes.
  • Paks reporting: whether the first quarterly security-of-supply report appears by 31 January 2027, and whether notices of unplanned shutdowns appear within one hour.

5.2 Summary

MIAK asks the Government to lay down by mid-November which step follows which gas-price and storage signal, and to show every month how much utility-price protection costs at prevailing prices. The Ministry of Finance should cover the refund of special taxes conflicting with EU law in a separate line of the budget bill and report it publicly, and at Paks one-hour, logged outage reporting should be the rule.

Two of MIAK’s foundational values are at stake. Data-drivenness, because winter decisions are tied to measures set in advance, not to the mood of the moment. Transparency, because the refund obligation and the loss of power generation are public-finance risks that the public must know about before the decision.

Part VI — Reasoning and further sources

6.1 Press framing by spectrum

Liberal-left band. HVG approached the topic in three articles, from three directions. It framed the MOL case as the responsibility of the previous government (“because of an unlawful move by Orbán and his team”), and presented the refund as the consequence of an unlawful tax. The Paks analysis put the emphasis on contradictions in the data releases and on the power-exchange cost of the outage. The article on the energy state secretary’s resignation on 13 October interpreted the situation as a malfunction of the government’s energy policy, and in this context named the HUF 800–900 billion annual burden of the utility price cut. Telex brought in the environmental side of the topic with the case of biomass power plants and protected forests (the article could not be downloaded publicly).

Public-affairs band. 24.hu discussed the gas price from the angle of the forint exchange rate: it presented the four-year high as one of the reasons for the currency’s weakening, with market analysts’ comments, without budgetary or utility-price-protection conclusions. In Index’s latest news feed, the three strands were not among the main topics in the processed material.

Economic band. Portfolio was the most critical of the utility price cut. Within a “sacred cow” frame, it calculated that with 30,000 renovated homes a year, the renovation need of 2.6 million homes would be met in almost 87 years, so replacing utility-price protection with renovation is a long-term path. In another analysis, on the diesel market, it wrote that with the retail price unchanged since 17 September, the margin reserve has disappeared, which is already a security-of-supply issue.

Conservative band. In Magyar Nemzet’s latest news feed, the gas price, the emission-quota tax refund and the Paks outage were not among the main topics in the processed material. The day’s output of Mandiner and Népszava could not be assessed.

6.2 Facts and data

Item Value Source
TTF natural gas price, 26 October 2026 above 97 €/MWh; it had not been this high for almost four years 24.hu (based on Economx), 26 October 2026
Filling of European gas storage 75% (22 October), five-year average 86% 24.hu (OTP Global Markets), 26 October 2026
Euro–forint exchange rate 367.3 on Monday morning (0.2% weakening), 366.7 in the late morning 24.hu, 26 October 2026
MOL’s emission-quota tax refund claim approx. HUF 133 billion (USD 405 million), including interest MOL BSE announcement, quoted by HVG, 27 October 2026
Refund conditions abolished at the end of July, retroactively; 90-day claim deadline; interest: central bank base rate + 2 pp HVG, 27 October 2026
Expected payment after the decision becomes final, according to MOL’s expectation still in 2026 HVG, 27 October 2026
Paks Unit 1, 21 October turbine-generator trip due to protection action, −242 MW; more than 3 GWh less generation that day HVG, 26 October 2026
Paks Unit 4 under repair since mid-September; the completion date has been changed nine times since 14 October HVG, 26 October 2026
Budgetary burden of the utility price cut HUF 800–900 billion a year HVG, 26 October 2026
2027 allocation for utility-price protection HUF 1,165 billion Portfolio, 27 October 2026
Residential properties needing renovation 2.6 million (according to the National Energy and Climate Plan); almost 87 years at a pace of 30,000 a year Portfolio, 27 October 2026
Diesel margin reserve January: HUF 88/l; August: HUF 17/l; September: HUF 2.6/l Portfolio, 26 October 2026
OECD adverse scenario TTF price of 77 €/MWh in the second quarter of 2026 OECD Economic Outlook, Interim Report, March 2026

6.3 Policy dimensions

  • Environment and climate (programme points) — energy-market shock resilience, automatic compensation and reserves (K7); the security-of-supply and storage element of the energy transition (K2); the building energy-efficiency programme as the long-term replacement for utility-price protection (K6);
  • Economy (programme points) — an energy-price shock preparedness plan (G25); machine-readable publication of the refund obligation (G1); risk items of the deficit path and debt sustainability (G23);
  • Construction (programme points) — the pace of the renovation programme, which according to Portfolio’s calculation will not on its own replace utility-price protection for decades (EP3).

6.4 Literature in detail

6.4.1 OECD: Economic Outlook, Interim Report (2026)

The OECD’s March 2026 report analyses the energy-market impact of the Middle East conflict. In its view, persistently high energy prices raise corporate costs and consumer inflation, and weaken growth. Its adverse scenario assumed a TTF price of EUR 77 for the second quarter of 2026; the current market price is higher. For the government response, the report gives a clear rule:

“Government measures to cushion the impact of higher energy prices should be timely, well-targeted on households most in need and viable firms, preserve incentives to lower energy use and have clear expiry mechanisms.”

The report also records that a large part of the 2022–2023 measures were poorly targeted and expensive, and in many places remained in force even after prices fell. In the Hungarian winter situation, “fast” and “targeted” can only be reconciled if the conditions are written down before the shock. This is what the threshold system of proposal 3.1 serves.

📖 Source: OECD: Economic Outlook, Interim Report — Testing Resilience (March 2026)

6.4.2 IMF: World Economic Outlook 2023

The IMF’s October 2023 report examines the effect of euro-area energy subsidies in a box. According to the model calculation, price subsidies and price caps reduced inflation by 0.9 percentage points in 2022 and by half a percentage point in 2023. After they expire, however, inflation rises relative to the path without subsidies, so the effect is spread over time rather than disappearing. According to the report’s general assessment, fiscal buffers have been depleted in many countries:

“This leaves many countries more vulnerable to crises and demands a renewed focus on managing fiscal risks.”

The Hungarian emission-quota tax refund is a textbook example of fiscal risk: an earlier revenue turns into an expenditure for legal reasons, with interest. Proposal 3.2 therefore does not ask for new spending, but for this already existing obligation to be foreseeable in the budget.

📖 Source: IMF: World Economic Outlook — Navigating Global Divergences (October 2023)

6.4.3 Nicholas Stern: The Economics of Climate Change

The Stern Review is about the economics of climate change, but it also discusses energy security. According to its finding, national energy-security goals are compatible with climate goals:

“Energy efficiency and diversification of energy sources and supplies support energy security, as do clear long-term policy frameworks for investors in power generation.”

In the Paks case, one element of a “clear framework” is reliable, timely information: if the start and end of an outage at a large generator remain uncertain for hours, the system operator and the market plan with more expensive reserves. Proposal 3.3 responds to this gap.

📖 Source: Nicholas Stern: The Economics of Climate Change — The Stern Review (Cambridge University Press / HM Treasury, 2007)

6.5 International comparison

The OECD’s 2026 report highlights two contrasting examples from the crisis management of 2022–2023. Canada’s measures targeted vulnerable households well, but did not encourage saving energy. Germany preserved the incentive to save, but its support was generally untargeted. The Hungarian utility price cut meets neither condition: everyone is entitled to it, and below the regulated-price consumption cap it sends no signal to save. Proposal 3.1 aims to combine the two virtues: a threshold fixed in advance, a targeted group, an expiry date.

EU regulation already provides for multi-stage gas-supply crisis levels and requires mandatory market disclosure of outages at large power plants. MIAK’s proposal would not replace these, but build on them, settling the winter response in a way tied to Hungarian budgetary decisions.

Environment and climate

  • K7 — Energy-market shock resilience
  • K2 — Energy transition plan
  • K6 — Building energy-efficiency programme

Economy

  • G25 — Energy-price shock preparedness plan
  • G1 — Data-driven budget
  • G23 — Public-debt sustainability framework

Construction

  • EP3 — Energy-efficiency renovation programme

Proposed new programme point: A refund reserve and risk statement on taxes conflicting with EU law — for the Economy area.

6.7 List of sources

Press sources (MIAK press monitor, 27 October 2026 — topic 3):

Knowledge-base references (literature):

  • 📖 OECD: Economic Outlook, Interim Report — Testing Resilience (March 2026)
  • 📖 IMF: World Economic Outlook — Navigating Global Divergences (October 2023)
  • 📖 Nicholas Stern: The Economics of Climate Change — The Stern Review (2007)

MIAK internal materials:

  • MIAK policy area: Environment and climate (programme points; programme point ID: K7, K2, K6)
  • MIAK policy area: Economy (programme points; programme point ID: G25, G1, G23)
  • MIAK policy area: Construction (programme points; programme point ID: EP3)
  • MIAK press monitor, 27 October 2026 — topic 3, score: 82/100

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