A strategy for public integrity is essential for directing and supporting a coherent and comprehensive integrity system. As such, a strategy is not an end but rather a means to an end. Public integrity strategies are also a way of demonstrating commitment to public integrity and can be used to establish institutional responsibilities within the public integrity system. However, if strategies do not lead to visible gains – for example, due to inadequate implementation – they can at best become irrelevant and at worst erode public confidence in national authorities (OECD, 2020[1]).
To effectively serve its cause and be relevant, a strategic approach needs to be underpinned by evidence on integrity risks and drivers of corruption, and by clear objectives and a measurement framework that tracks implementation and ensures an effective accountability and communication to citizens and public officials alike. In this sense, the OECD Recommendation on Public Integrity states that adherents should “develop a strategic approach for the public sector that is based on evidence and aimed at mitigating public integrity risks, in particular through (OECD, 2017[2]):
Setting strategic objectives and priorities for the public integrity system based on a risk-based approach to violations of public integrity standards, and that takes into account factors that contribute to effective public integrity policies.
Developing benchmarks and indicators and gathering credible and relevant data on the level of implementation, performance and overall effectiveness of the public integrity system.”
Within the framework of the conditionality procedure initiated by the European Commission against Hungary on 27 April 2022 on the basis of Regulation (EU, Euratom) 2020/2092 of the European Parliament and of the Council of 16 December 2020 on a general regime of conditionality for the protection of the Union budget, on 22 August 2022 the Hungarian Government proposed the adoption of 17 remedial measures to address the findings set out in the Commission’s notification of 27 April 2022. The Hungarian Government undertook some further commitments on 13 September 2022 as to some of the 17 remedial measures.
Specifically, the Hungarian Government committed in remedial measure No.3 to strengthening the anti-corruption framework, inter alia, by adopting a new Medium Term National Anti-Corruption Strategy for 2023-2025 (hereinafter referred to as NACS) and an Action Plan (hereinafter referred to as AP) for its implementation. The Hungarian Government committed to adopt the NACS and the AP by 30 June 2023, in line with the same commitments made within the conditionality procedure in its Recovery and Resilience Plan (RRP, measure C9.R7: Development and implementation of a National Anti-corruption strategy and action plan; milestone No. 178).1
This report provides a first assessment of the draft NACS and AP and proposes concrete recommendations on how to strengthen the strategy with the aim of achieving the stated expected results and aligning the strategy with national priorities and international good practice.