The last report called 31 August the largest single scheduled event on the calendar. Enough has moved since then to look at those 27 milestones on their own.
The headline is that the question has changed. Two months ago it was whether the government could pass the legislation. It has. What remains is a subtler question: does a law on the statute book count as a milestone met?
What the 27 actually are
They are the list of things the EU required Hungary to fix before any money moves. The Council set them when it approved Hungary's recovery plan, and not a euro is paid until all 27 are fulfilled.
They fall into three groups:
- Anti-corruption — this absorbs all 17 remedial measures agreed under the conditionality procedure: competition and transparency in public procurement, conflict-of-interest rules, stronger audit and control requirements, use of the Commission's Arachne risk-scoring tool, and ensuring the European Anti-Fraud Office (OLAF) can actually run investigations in Hungary
- Judicial independence — widening the powers of the independent National Judicial Council, reforming how the Supreme Court operates to limit political influence, removing the Constitutional Court's role in reviewing final judicial decisions at the request of public authorities, and ending the Supreme Court's ability to vet questions judges intend to refer to the European Court of Justice
- Transparency of public money — traceability and disclosure of how funds are used
All 27 were originally due by the end of 2022. They are three and a half years late.
The starting point, just before the change of government
One number matters here. As assessed in December 2025, only 17 of the 27 were fully met; 9 were partly met and 1 was not met at all.
That assessment came from civil society and it describes the position before the April election — it is the previous government's scorecard, not the current one's. The distinction matters, because everything that follows happened on top of that baseline.
What happened in two months
The new government moved quickly on legislation.
- 9 June — the government submits the bill transposing the milestones into Hungarian law
- 23 June — Parliament adopts it; promulgated 26 June (Act XVIII of 2026)
- 2 July — the Sovereignty Protection Office is abolished
- 10 July — a bill to establish an asset-recovery office is submitted
- 13 July — the 17th amendment to the Fundamental Law passes, with all 139 governing-party MPs in favour
The amendment creates the National Asset Recovery and Protection Office (NVVH), an independent prosecutorial body with nationwide jurisdiction over major corruption cases involving public officials and state assets. It can investigate, prosecute, bring civil claims to recover assets, and temporarily take control of companies suspected of holding improperly obtained public wealth.
As a pace of legislating, that is striking. Pace is not the problem.
The real issue: some provisions take effect after the deadline
The July legislation does not enter force all at once. Most of it applies the day after promulgation, the justice-system amendments generally on the 61st day, and specified provisions are staged for 26 August, 1 October, and 1 January 2027.
The deadline is 31 August. So the provisions dated 1 October and 1 January 2027 are not yet in force when the milestones fall due.
This is where it splits:
- If a milestone asks whether the legal framework has been adopted → this is fine
- If it asks whether the institution is demonstrably working → some of it cannot be shown on 31 August
The RRF is performance-based. The Commission's consistent line has been that it looks at effectiveness rather than paperwork. That is the sharpest uncertainty in the whole file.
One more dependency sits alongside it. Parliament must elect the NVVH's president and four deputies within 30 days, which from 13 July means roughly 12 August. An office that exists on paper with nobody in it is hard to call operational. In its favour: this needs only a governing majority, so it is within the government's control.
What civil society flagged and did not get
The Hungarian Helsinki Committee and Transparency International Hungary fed into the design of the anti-corruption body, and much of it landed — supervision, civil litigation, reporting obligations, data governance, Ombudsman oversight.
Some of it did not: direct judicial review, a clearly bounded jurisdiction, and comprehensive external supervision. Whether those are decisive for milestone assessment is a separate question, but if the Commission finds fault, this is the likeliest place.
A caveat worth stating plainly. Civil-society groups told the Commission's 2026 Rule of Law Report that Hungarian authorities had implemented none of the 2025 recommendations and that some areas had gone backwards. Strong language — but that submission dates from January, before the election. It should not be read as a verdict on the current government.
Assessment
| Outcome | Probability | Reasoning |
|---|---|---|
| Payment request filed in September | 65% | The legislation is done. What is left is appointments and procedure, all within a governing majority |
| Partial acceptance, some slippage | 30% | The Commission takes issue with provisions not yet in force. Disbursement moves into 2027 |
| Substantive failure | 5% | The political direction is already set toward disbursement; this path is narrow |
Why 65%. First, the hard part — legislating — is finished. Second, the Council already approved the revised plan in July, so the political will points at paying. Third, most of what remains can be done by the governing party alone.
Why 35% is still on the other side. The entry-into-force problem is not a technicality. The RRF was designed so that saying a thing is done is not the same as having done it, and the Commission has been burned on Hungary before, which does not incline it to a generous reading.
What this means for the forint
As set out in the last report, the EUR 16.4bn was priced in May. A good outcome here does not give the forint a reason to rally by that amount again; it confirms what buyers already paid for.
The asymmetry is the point. Success is in the price; failure is not. 31 August is an event risk because the downside is open, not because the upside is large.
What to watch
- Around 12 August — whether the NVVH leadership is elected. Slippage here is the first warning sign
- 26 August — the first tranche of provisions enters force
- 31 August — the deadline, and specifically how the Commission words its finding. "Met" and "broadly met" are not the same thing
- End of September — whether the payment request is actually filed
This is a judgement based on public information, and the probabilities are not a model output. Nothing here is investment advice or a recommendation to buy or sell any currency. How the index is built is on the methodology page; the previous analysis is in the July report.