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After the era of emergency decrees — expected legislative reorganisation in the private sector

One hundred ninety-five emergency decrees in force await termination. We review which areas are most affected within the TaxHungary readership.

After the era of emergency decrees — expected legislative reorganisation in the private sector
Hungarian economic regulation has, since 2020, increasingly relied on the legal instrument of emergency government decree. These decrees in force broadly affect the everyday operations of the private sector, and in the first four months of 2026 alone, nearly thirty new decrees were published — covering taxation, energy, construction, insolvency, employment and general corporate matters. The new political cycle following spring 2026 foreshadows a return of weight to parliamentary legislation. In the medium term it promises a more predictable regulatory environment, while at the same time bringing a substantial volume of concrete legislative changes. This article reviews which areas are most affected and where it is worth focusing attention in the second half of 2026.

The weight of emergency-decree regulation

In the Hungarian legal system, the emergency government decree was originally an instrument designed for the constitutional system's exceptional situations. Its essence is that it enters into force immediately upon publication, has the force of statute, and does not require the long preparation and debate procedure of parliamentary legislation. Owing to the pandemic that began in 2020, and then the energy crisis and wartime environment that has persisted since 2022, this exceptional regulatory channel has become the defining instrument of economic regulation directly affecting the private sector. The imposition and modification of special levies, the introduction and removal of price caps, the in-year adjustment of tax legislation, and the reshaping of construction and tender conditions have all reached the affected enterprises in this form, often with short preparation time and on a schedule not always aligned with the financial year.

The number of emergency decrees currently in force amounts to one hundred ninety-five, and in the first four months of 2026 alone nearly thirty new decrees were published. The new political cycle following spring 2026 foreshadows the gradual retreat of this regulatory pattern. On the one hand, a portion of the emergency decrees in force will likely be elevated to statutory level, codified and in some cases with refined content. On the other hand, a significant volume of rules expressly meant to be transitional will be phased out or substantially restructured.

Taxation and special levy package

The area with the greatest economic weight is occupied by the special levies. In the practice of recent years, sector-specific surtaxes have been introduced for the banking sector, insurers, retail trade, energy companies, telecommunications providers and pharmaceutical distributors, mostly with content renewed or modified annually. The government decree governing the divergent application of the Advertising Tax Act, which entered into force in April 2026, illustrates the dynamics of this area well — yet another transitional modification of an already existing tax type became part of corporate planning within days of its publication.

These tax types significantly impaired corporate predictability, since the tax obligation for the current year often only became unambiguously clear in the closing months. In the regulatory reorganisation expected for the second half of 2026, several outcomes are equally conceivable. In the case of certain sectors — particularly retail and banking — full phase-out may also be on the agenda, as the competitiveness considerations of the affected industries may outweigh short-term budgetary arguments. In other cases, modification of rates and brackets is the main direction, retaining the underlying tax type. From the perspective of corporate financial planning, the most important development would be if special levies were definitively fixed at the start of the given year, and in-year modification ceased.

The KATA (small-taxpayers itemised tax) has been undergoing significant transformation for years and is also on the agenda of the next cycle. The 2022 tightening substantially rewrote the small-business taxation environment, and in the coming period further refinements or partial reversals may also occur. For the KIVA, no substantive restructuring is expected — rather a fine-tuning of entry and continued-eligibility conditions and a gradual broadening of the eligible group.

Energy regulation

The energy pillar showed intensive decree activity in the first months of 2026 as well. In March, two decrees on the security of natural gas supply and storage obligations were published, and a third on the divergent application of the Electricity Act. In April the international energy security data-reporting decree joined the line. The cost structure of private-sector industrial enterprises, logistics companies and trade depends directly on these rules, so every new decree publication requires immediate financial modelling. The reorganisation expected in this area presumably points toward clarification of price-cap arrangements, establishment of longer-term frameworks for energy-investment support, and statutory codification of supply-security data reporting.

Construction, real estate, public procurement

The regulation of the construction and real estate sector is also weighted with a significant number of emergency decrees. The February 2026 building-affairs decree refined the framework for energy investments, the home-support decree that entered into force at the end of 2025 set out the framework for housing support, and the housing support available to employees who have not reached their thirty-fifth year of age has been in force since January 2025. The divergent application rules for building-affairs permitting, public procurement structure, and land-registry and building-authority procedures may undergo comprehensive review in the coming months.

We reviewed in detail the current picture of the construction market and the contours of the restart of postponed state investments in a previous analysis. There we showed that the contraction of the first quarter of 2026 may be reversed in the next twelve months by the opening of state investment channels and EU funds disbursement. The regulatory reorganisation that is the subject of the present article is the institutional framework of that process. In the light-frame and modular building market, the fine-tuning of land-registry and building-affairs regulation is already on the agenda. The detailed perspectives of the related VAT assessment have been set out in a separate article. The transformation of the public procurement market points toward stricter transparency criteria, more precise contract-conclusion conditions and a strengthened monitoring system.

Insolvency and corporate procedural package

The wide range of decrees published between 2022 and 2023 governed the divergent application of the Bankruptcy Act, the Company Act, the Civil Code and the Labour Code. The emergency rules on plot adjustment, the handling of contracts of the business company established for the continuation of the debtor's economic activity, and the December 2022 and March 2026 modifications of the Wage Guarantee Fund all belong to this package. One of the most comprehensive reviews is expected in this area. The agenda of the new political cycle is likely to include comprehensive modernisation of the Bankruptcy Act and the Company Act, in approximation to European Union directives — the Hungarian transposition of the EU Restructuring Directive on preventive restructuring procedures is currently supplemented by emergency decrees, and the lasting solution may be a coherent, statutory-level codex. From the perspective of SMEs, this is particularly important, since the insolvency environment directly influences creditworthiness and supplier confidence.

Money market and capital market dimension

In the area of the banking system and the capital market, alongside the special levies, credit-market interventions and retail government-bond regulatory fine-tuning are also relevant. The April 2026 forint strengthening and the post-election yield decline together sketch the direction of the reorganisation in the coming months. The picture of the Hungarian stock exchange, the retail government-bond market and the forint exchange rate in spring 2026 has been reviewed in a separate analysis. The reorganisation of money-market regulation is presumably moving in three directions. The gradual phase-out of special levies improves the pricing and product structure of the domestic banking system. Credit-market interventions enter a lasting statutory framework, reducing in-year regulatory uncertainty. The condition system of the retail government-bond market — particularly the Premium Hungarian Government Bond — will likely receive more lasting, statutory-level regulation.

Employment, wage guarantee, vocational training

The labour and wage-guarantee regulation area is also burdened with a significant number of emergency decrees. The divergent application of the Labour Code, the rules on the Wage Guarantee Fund and the fine-tuning of the vocational-training contribution all fall within this scope. The new political cycle's agenda may include the stabilisation of employment regulation, the extension of the wage-guarantee system, and the comprehensive redesign of vocational-training and dual-training incentives. For private-sector employers this will have a direct impact on workforce planning and the calculation of the human cost structure.

What does this mean for corporate planning?

The transition does not arrive all at once but in waves. The larger packages will become visible in the second half of 2026 and the first half of 2027, and the full reorganisation may extend up to 2028. For private-sector enterprises the practical path in the coming months is dual planning. Both the situation under the current rules and the situation following the expected modification should be calculated, tax planning should be prepared in flexible frameworks, modelling several regulatory outcomes. Larger project decisions — particularly in the construction, real-estate development and energy fields — should be made with knowledge of the contours of the new regulatory situation. Ongoing public procurement tenders should be prepared for changes in the conditions framework, and partner due-diligence processes should also be tightened.

Announced directions of the tax reform

At the centre of the economic policy package announced by the new political cycle stands the substantial restructuring of the taxation system. Some of the changes directly target an increase in the net income of employees, others aim to improve the competitiveness of the entrepreneurial segment and the predictability of planning.

In the structure of personal income tax, the most significant announced modification is the reduction of the tax rate at the level of the minimum wage. The current uniform 15 per cent personal income tax rate would be reduced to 9 per cent at the level of the minimum wage, which alongside the 2026 minimum wage of 322,800 forints would mean a monthly net-income increase of approximately 20,000 forints. The reduction would extend in a banded structure up to around the median wage — the gradual personal-income-tax reduction affecting some 2.3 million employees below the median wage may bring monthly net-income increases of between 5,000 and 15,000 forints at income levels of 420,000 and 625,000 forints. For incomes above the median wage, the uniform 15 per cent rate remains unchanged, and the new political cycle has explicitly committed itself to not raising taxes on wages.

The general value-added tax base rate remains at 27 per cent. The modifications are narrowed to a targeted scope — the VAT exemption for prescription medicines, and the reclassification of firewood and healthy foodstuffs to the 5 per cent reduced rate may bring perceptible relief for households. From the perspective of private-sector actors, this primarily affects the pricing and invoicing systems of the affected sectors — pharmaceutical retail, food retail and the firewood segment.

A new tax type, the wealth tax, also appears. According to the announced regulation, an annual 1 per cent wealth tax would be levied on the portion of private wealth above one billion forints. The affected group covers approximately 25,000 to 30,000 households, and the planned annual revenue is on the order of 160 to 180 billion forints. In the entrepreneurial sphere this may affect ownership planning and wealth-management structures, particularly for private individuals holding higher-value participations, real estate portfolios and financial investments.

In the area of small taxpayers, the broader reinstatement of the KATA regulatory regime, significantly tightened in 2022, appears in the programme — it promises an approximation to the broadly available KATA construction of the pre-2022 period, although the precise parameters and the pace of reinstatement are not yet final.

At the level of general principles of tax policy, two lasting changes appear. The gradual reduction of the number of tax types, and the cessation of in-year tax modification, address the most critical pain points of corporate financial planning. According to the announced commitment, prior substantive consultation with the affected professional actors would take place before any modification of financial and tax rules — this in itself represents substantive qualitative progress on the corporate predictability side.

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