Hungary’s Public-Procurement Exclusion Register: What Foreign Bidders Should Prepare For

September 21, 2026

Hungary has activated a public register for economic operators excluded from public procurement in connection with specified criminal offences. The Integrity Authority has announced the start of the first registration proceedings, while the register itself is maintained in Hungary’s Electronic Public Procurement System (EKR).

For foreign bidders, this is not simply another database to check before submitting a tender. A registration procedure can involve a company and certain people connected with it, including senior officers and beneficial owners. The response window is short, communication is electronic, and a successful “self-cleaning” case requires evidence of remediation—not a general compliance statement.

This guide explains the framework in force as at 18 September 2026 and sets out a practical preparation plan for international companies bidding in Hungary. It is general information, not legal advice. Any live procedure or exclusion issue should be reviewed by Hungarian public-procurement counsel immediately.

The position in brief

The Integrity Authority is responsible for registration proceedings and has stated that it has begun the first proceedings.
The public register is kept in EKR.
The framework concerns final criminal judgments relating to a defined group of offences and specified people connected with an economic operator.
Proceedings begin ex officio: the Authority does not wait for a competitor or contracting authority to apply.
After notification, the operator has eight days to comment and submit evidence of self-cleaning.
The Authority assesses the response within 20 days.
An exclusion period set by the Authority may not exceed four years from the date the relevant court judgment became final.
A listed operator may later apply for self-cleaning during the exclusion period, and a rejection can be challenged before an administrative court.
Absence from this register does not prove that a bidder is free of every exclusion ground under Hungarian procurement law.

What changed in 2026

The idea of a Hungarian public-procurement “blacklist” was initially reported as a future measure. That description is now outdated. The legal and operational steps taken in August 2026 moved the system into implementation.

Date	Development	Practical meaning
7 August 2026	Government Resolution 1246/2026 confirmed that the data required for the register were fully available.	A key condition for the register’s operation was satisfied.
11 August 2026	The ministerial decision cited by the Integrity Authority followed.	The Authority identifies this as part of the basis for starting registration activity.
August 2026 onward	The Integrity Authority announced that it was beginning the first registration proceedings and maintaining the register in EKR.	Companies should treat the framework as operational, not merely proposed.

The public information available does not justify assumptions about how many operators are currently listed. Companies should use the live EKR register for current checks and avoid relying on cached articles or internal screening completed months earlier.

Who operates the register

The Integrity Authority conducts the registration procedure and decides whether an operator should be entered. It also assesses self-cleaning measures. Public register data are made available through EKR, Hungary’s electronic procurement platform.

The process is separate from the ordinary assessment made by a contracting authority in a particular procurement. Registration may nevertheless have a direct impact on tenders because contracting authorities must take the entry into account where the relevant statutory exclusion ground applies.

Who may be entered

Under the current statutory framework, an economic operator may be registered where a final court judgment establishes that the operator itself, or a relevant person connected with it, committed one of the specified offences.

The connected-person categories include:

a senior officer;
a supervisory-board member;
a company manager; or
a beneficial owner.

This matters particularly for international groups. A Hungarian bidding vehicle may have a clean local record but still need a reliable view of judgments affecting directors, management and beneficial owners across jurisdictions. Ownership changes, nominee arrangements or decentralised compliance records can make this mapping difficult unless it is done before a notice arrives.

The offences covered by the new register correspond to the categories in section 62(1)(a), points aa–ag, of Hungary’s Public Procurement Act. In practical terms, they include:

participation in a criminal organisation;
bribery and related corruption offences;
budget fraud and offences affecting the European Union’s financial interests;
terrorist offences;
money laundering and terrorist financing;
human trafficking and forced labour; and
restrictive agreements in public-procurement or concession procedures, commonly associated with bid rigging.

The exact classification of a foreign judgment requires legal analysis. A business should not decide from an English-language label alone that an offence is—or is not—equivalent to a Hungarian statutory category.

What registration means for a bidder

A registered operator cannot participate during the applicable exclusion period in procurements to which the specified exclusion grounds apply. Hungarian procurement rules can affect participation not only as the main bidder but also in other roles, including as a subcontractor or an entity providing capacity.

The commercial effects may therefore extend beyond losing one tender. A registration issue can affect consortium planning, reliance on group credentials, subcontracting structures and representations given to lenders, investors or commercial partners. It may also force rapid changes to a bid team when a deadline is approaching.

The duration is determined by the Integrity Authority, but it may not exceed four years calculated from the date the relevant criminal judgment became final. The period is not automatically four years in every case.

How the procedure works

The procedure begins ex officio. The Authority notifies the economic operator and gives it an opportunity to comment and demonstrate self-cleaning.

Stage	Main rule	Action for the operator
Opening	The Integrity Authority starts the proceeding on its own initiative.	Escalate the notice immediately to legal, compliance and tender leadership.
Notification	The notice is delivered electronically through the official channel applicable to the operator.	Verify receipt, calculate the deadline and preserve delivery evidence.
Response	The operator has eight days from receipt to submit comments and self-cleaning evidence.	File a complete, properly authorised electronic response; do not wait for the final day.
Assessment	The Authority evaluates the response within 20 days.	Keep decision-makers and supporting evidence available for follow-up.
Decision	The Authority may enter the operator, refrain from entry following effective self-cleaning, or later remove an operator after successful self-cleaning.	Review procurement, disclosure and challenge implications immediately.

Electronic form is not a minor administrative detail. The Authority’s guidance says that companies receive communications through their official company gateway, while sole traders use the applicable personal electronic channel. A response must be submitted through the Authority’s official electronic portal. A submission made in the wrong form may be treated as invalid and disregarded.

An operator that does not respond in time does not stop the proceeding. Evidence filed late may be excluded from the initial registration assessment. Foreign groups should therefore ensure that the people monitoring the Hungarian electronic mailbox know whom to contact and have an out-of-hours escalation route.

The three elements of self-cleaning

Self-cleaning is the legal route by which an operator demonstrates that, despite the underlying event, it has restored reliability. The three statutory elements must be satisfied together.

1. Repairing the harm

The operator must have compensated the damage caused by the offence or made a binding commitment to do so that has been accepted by the injured party. Evidence may include settlement documentation, payment records and proof that the relevant commitment is legally effective.

2. Active cooperation

The operator must have actively cooperated with the competent investigating or other authorities to clarify the facts and circumstances comprehensively. A bare assertion of cooperation is unlikely to be enough; the file should show what was disclosed, when, to whom and with what practical effect, subject to legal privilege and applicable restrictions.

3. Effective preventive measures

The operator must have taken technical, organisational and personnel measures capable of preventing further criminal conduct. The Authority considers the concrete circumstances, not only whether policies exist on paper.

Relevant evidence may include:

removal or reassignment of implicated personnel;
changes in management or reporting lines;
strengthened procurement, competition and anti-corruption controls;
beneficial-ownership and third-party due diligence;
redesigned approval thresholds and segregation of duties;
independent audits, monitoring and testing;
documented training tied to the identified failure;
whistleblowing and investigation improvements; and
evidence that the new controls are actually operating.

The burden is on the operator to prove both the measures and their effectiveness. A generic code of conduct, a recently adopted policy or a training attendance list will rarely tell the full story. The strongest file connects the root cause of the offence to specific remedial actions, responsible owners, implementation dates, testing results and continuing oversight.

Self-cleaning after registration

An operator can present self-cleaning during the initial eight-day response period. If it is entered in the register, it may also submit a separate self-cleaning application during the exclusion period. The Authority’s guidance states that this later application is free of charge.

If the application succeeds, the Authority may remove the operator from the register. A self-cleaning decision under the Public Procurement Act is binding on contracting authorities. If an application is rejected, a later application may be possible where the operator has introduced new measures after the rejection. Refiling the same material without a substantive change is unlikely to solve the underlying problem.

Correction, removal and judicial review

The register is updated continuously when the legal conditions for an entry cease to exist, the exclusion period expires, self-cleaning succeeds, or a final judicial or authority decision requires a change.

An operator should distinguish between three situations:

The underlying data are wrong or attributed to the wrong entity or person. The response should identify the error precisely and provide authoritative records.
The underlying judgment falls outside the statutory scope. Hungarian counsel should analyse the offence, finality, relevant person and statutory correspondence.
The event is within scope, but the operator has restored its reliability. The appropriate route is a fully evidenced self-cleaning case.

The Authority’s guidance states that rejection of a self-cleaning application may be challenged by an administrative court action filed within 30 days of receipt of the decision. Because procedural routes and deadlines depend on the decision received, companies should obtain advice on the specific document rather than treating this guide as a filing instruction.

Why foreign bidders face additional risk

International businesses often distribute the relevant information across several systems and countries. Criminal-record checks may sit with legal, beneficial-ownership data with corporate secretarial teams, remediation evidence with compliance, and tender declarations with a local bid manager. An eight-day deadline leaves little time to reconcile inconsistent records.

Translation is another risk. Court judgments, settlement documents and internal investigation reports may need certified or legally reliable Hungarian translations. Powers of attorney and electronic documents must also meet Hungarian e-administration requirements. These are matters to prepare, not discover after notification.

Foreign bidders should also avoid assuming that a clean EKR register search completes the exclusion analysis. The register has a defined scope. The wider Public Procurement Act contains other exclusion grounds and addresses equivalent foreign offences. A tender-specific eligibility review remains necessary.

Integrity-readiness checklist for foreign bidders

Corporate and people mapping

Confirm the precise legal entity that will bid and every consortium participant.
Map senior officers, supervisory-board members, company managers and beneficial owners.
Record changes over the relevant period, not only the current structure.
Reconcile corporate-register, KYC and tender records so that names and identifiers match.

Judgment and investigation review

Ask group legal teams about relevant final criminal judgments in every material jurisdiction.
Classify potential offences with Hungarian counsel instead of relying on local terminology.
Check whether a judgment is final and record the finality date.
Preserve certified copies, translations and proof of the persons and entities affected.

Bid-chain controls

Screen consortium members, proposed subcontractors and capacity-providing entities.
Include prompt-notification duties in teaming and subcontracting agreements.
Identify replacement options for critical partners before bid submission.
Recheck the EKR register at bid gates and before final declarations are signed.

Electronic-notice readiness

Assign named owners to monitor the company’s official Hungarian electronic mailbox.
Test holiday, illness and out-of-hours coverage.
Maintain a written escalation route to management, Hungarian counsel and compliance.
Pre-approve authority and powers of attorney for electronic submissions.

Self-cleaning evidence pack

Prepare a chronology of the event, investigation, judgment and remediation.
Link each corrective measure to an identified root cause.
Collect proof of compensation or accepted commitments.
Document cooperation with authorities.
Retain board approvals, personnel decisions, revised controls, training records, audit results and monitoring data.
Review whether privacy, privilege or secrecy rules limit disclosure and how those limits can be handled lawfully.

A practical 30-day preparation plan

Days 1–5: appoint a cross-functional owner, verify the official electronic mailbox and map all entities and roles used in Hungarian tenders.

Days 6–12: obtain written confirmations from group legal and compliance teams about potentially relevant final judgments. Identify gaps in beneficial-ownership and management records.

Days 13–20: review consortium, subcontractor and capacity-provider onboarding. Add rapid disclosure and cooperation provisions where contracts allow.

Days 21–26: build a self-cleaning evidence index around compensation, cooperation and preventive measures. Do not wait for an active case to organise documents.

Days 27–30: run a tabletop exercise based on an eight-day Authority deadline. Test notification, translation, approvals, evidence collection and electronic filing. Record failures and assign fixes.

What the register does not prove

The register is an important integrity tool, but it should not be overread.

A company’s absence does not certify full procurement eligibility.
An entry does not automatically explain every fact behind the judgment or remediation history.
The register does not replace tender-specific declarations and contracting-authority checks.
A foreign court label should not be mapped to Hungarian law without analysis.
The maximum four-year period is not a statement that every case will receive the maximum.

Reliable procurement compliance combines register checks with ownership verification, criminal-judgment analysis, partner due diligence and bid-specific legal review.

Preparing before the deadline arrives

The most important feature of the Hungarian system is speed. Eight days is a difficult period in which to locate foreign judgments, reconstruct remediation, arrange translations, obtain signatures and submit through the correct electronic channel. Companies that bid regularly in Hungary should prepare the evidence architecture now.

Westbridge Consulting supports international businesses with Hungarian market entry, corporate compliance coordination and practical preparation for regulated procedures. For help organising a Hungary-focused bidder-readiness review, contact our team. Legal submissions and case-specific procurement advice should be handled with qualified Hungarian counsel.

Official sources

Last reviewed: 18 September 2026. This article provides general information and does not constitute legal advice.