Five Months of Enforcement: Continuity in Law, a Turn in Visibility

What Chinese investors in Hungary should expect in 2026–2027, and how sanctions can be avoided – Part II

Dr. Balázs Czudar (Czudar DHH Law Firm – Hungary / DHH Budapest Office) – Cheng Tao 程涛 (北京德和衡（青岛）律师事务所 / DHH Qingdao) · Professional article, September 2026

EXECUTIVE SUMMARY

Our study published in July 2026 described what the change of government altered for Chinese investors and which legal response strategy follows from it. Five months after the election, a balance sheet can be drawn rather than a forecast. The balance is unambiguous: in every known case the Hungarian authorities acted on a documented breach of law; the target of the sanctions was the battery industry and heavy industry, not the nationality of the investor; and the amounts of the fines stayed within the frameworks created by the previous government between 2011 and 2025. What has changed is the visibility and consistency of enforcement: decisions are now announced by ministers rather than uncovered through freedom-of-information requests; suspension has moved alongside – indeed ahead of – the fine; and since 1 August 2026 a nationwide inspection programme has been running that extends to the supply chain. The genuine regime change will come with the sanctions regime announced by the government and planned from 1 January 2027 – a HUF 5 billion cap and a “third strike” set at half a percent of turnover. On the basis of the announcement it cannot be excluded that the authority will count this year’s infringements within the five-year window; the lawfulness of that (retroactivity) depends on the text of the bill. The five steps of the July article – compliance self-audit, realistic planning, local embeddedness, EU documentation readiness, a permanent legal partner – have therefore not eased but become more urgent.

I. FIVE MONTHS IN REVIEW: WHAT HAS HAPPENED SINCE APRIL 2026

Part of the Chinese business press writes of a “trap”: the previous government let Chinese factories in, and the new government is now moving against them. That narrative is not supported by the facts. The overview below draws exclusively on authority press releases, government communications and verified press sources; where the company concerned disputes the authority’s findings, this is indicated separately.

Semcorp Hungary Kft. (恩捷股份, Debrecen). A pipeline was damaged at the separator-film plant in February 2026. The water authority of the Hajdú-Bihar County Government Office (hereinafter “Hajdú-Bihar CGO”) found exceedances of the limit values for several metals and metalloids in groundwater samples – according to the government office, roughly 13,000 times the limit value in the case of aluminium – and on 24 June 2026 imposed a procedural fine of HUF 1 million (for late submission of monitoring results), a water-management fine of HUF 1 million and procedural costs of more than HUF 2 million, while ordering the construction of a watertight stormwater reservoir and quarterly monitoring. The environmental authority suspended the activity and ordered remediation and fact-finding. On 3 July the fire authority – citing an inoperable foam-extinguishing pump and irregularities around the acetone and oxygen sensors – imposed a fine of HUF 3 million and prohibited all activities at the site with immediate effect. The police are investigating on suspicion of environmental damage. The company has challenged the procedural fine in court and, relying on independent laboratory tests, disputes that the plant caused any pollution – a position the Chinese ambassador also set out publicly in a September interview.

CATL (宁德时代, Debrecen). After the incident of 5 May involving a metal-containing “green liquid”, the water authority withdrew its consent for the industrial wastewater pre-treatment system, ordered the cleaning of the public sewer and applied the statutory maximum fine of HUF 1 million. On 31 May the state secretary of the competent ministry declared that the government “will not be a partner” in building further plant units in Debrecen. On 5 June the company itself acknowledged that its subcontractors had unlawfully discharged pressure-test fluid into the sewer, and accepted responsibility. On 24 August a HUF 10 million environmental fine for breach of the integrated environmental permit became public: hazardous-waste containers lacked Hungarian-language labelling, the on-site collection point was unmarked, the operating log was missing and the collection point was unattended. The repeat inspection of 9 July found the deficiencies remedied; CATL is paying the fine. On 25 August the occupational-safety authority prohibited work in three plant sections after the company itself reported elevated nickel exposure of nine workers and the inspection found protective equipment inadequately provided; on the same day the government office granted the occupancy permit for the first phase but refused the one for the second phase because of a site-plan error.

BYD Auto Hungary Kft. (比亚迪, Szeged). On 16 June 2026 the Csongrád-Csanád County Government Office (hereinafter “Csongrád-Csanád CGO”) imposed a HUF 10 million environmental fine because topsoil had been removed from the construction site without measurement or notification and the alkylbenzene content of the March samples exceeded the limit value; the authority filed a criminal complaint and ordered the destruction of crops grown on the affected land. The May survey covering 101 sampling points no longer showed any exceedance. The police are conducting several proceedings over two fatal accidents on the site and over working conditions. An important clarification: the HUF 100 million occupational-safety fine announced on 7 August was imposed not on BYD but on the contractor AE Industry Hungary Kft., as the employer of the victim of the February fatal accident; another subcontractor was fined HUF 34.5 million in June. BYD is the subject of the subsidy review announced by the government on 20 July; according to the Hungarian Investment Promotion Agency (HIPA), no signed and effective subsidy agreement exists.

Temu (Whaleco Technology Ltd.). The Hungarian Competition Authority (GVH) – an autonomous authority, in proceedings opened before the election – imposed on 28 April 2026 a fine of HUF 437 million and consumer compensation of at least HUF 882 million for misleading commercial practices; in the same period it fined Romania’s eMAG HUF 225 million and Poland’s Allegro HUF 42.5 million.

Plants not in Chinese ownership. Of the two largest occupational-safety fines of the period, each of HUF 100 million, one was imposed on 13 August on the Iváncsa plant of South Korea’s SK On (no workplace air measurements since August 2024, unreported nickel exposure of 59 workers, inadequate protective equipment), the other on the Szeged contractor. At the Debrecen cathode plant of South Korea’s EcoPro, the industrial-safety authority on 11 September imposed a HUF 2 million fine and suspended the hazardous activity of the NCA building; the company disputes the decision as disproportionate. The tax and environmental package announced by the government on 17 July 2026 defined its addressees generically – polluting companies, large water users, multinationals – and Minister Dávid Vitézy told Bloomberg that the aim is not to dismantle Hungarian–Chinese cooperation but to ensure that everyone fully complies with Hungarian and EU rules.

Company (owner)	Authority	Measure	Amount	Date
Semcorp (CN)	Hajdú-Bihar CGO – water, environment, fire; police	fines; suspension; prohibition of all activities; criminal investigation	HUF 1 + 1 + 3 M, >HUF 2 M costs	24 Jun – 6 Jul 2026
CATL (CN)	Hajdú-Bihar CGO – water, environment, occupational safety, construction	withdrawal of consent; fine; work prohibition in 3 sections; refusal of occupancy permit	HUF 1 M + 10 M	28 May – 25 Aug 2026
BYD (CN)	Csongrád-Csanád CGO; police; government	environmental fine; criminal complaint; subsidy review	HUF 10 M	1 Jun – 20 Jul 2026
AE Industry Hungary (contractor, BYD site)	Csongrád-Csanád CGO – occupational safety	fine (statutory maximum)	HUF 100 M	7 Aug 2026
Temu (CN)	GVH	fine + mandatory compensation	HUF 437 M + ≥882 M	28 Apr 2026
SK On (KR)	Fejér CGO – occupational safety	fine (statutory maximum)	HUF 100 M	13 Aug 2026
EcoPro (KR)	Hajdú-Bihar CGO – industrial safety	fine + suspension of building’s activity	HUF 2 M	11 Sep 2026

II. NOT WITHOUT PRECEDENT: A CHRONICLE OF FINES, 2018–2026

The appearance of a “radical change” is most easily dispelled by the numbers. According to documents released by the Pest County Government Office on 30 June 2026 under a court order, the authority fined the Göd battery plant of South Korea’s Samsung SDI in 61 decisions between 2018 and 2025, for a total of HUF 405.3 million, on construction, environmental, disaster-management, occupational-safety and labour grounds. The then government itself acknowledged this order of magnitude on 23 February 2026 (more than HUF 400 million, of which HUF 146 million occupational safety and HUF 31 million environmental), and as early as the beginning of 2023 a state secretary’s answer to a written parliamentary question reported 39 fire-safety and industrial-safety fines totalling HUF 101 million (2019 – January 2023).

The statutory maxima, too, were first applied by the authorities of the previous government. The HUF 100 million occupational-safety cap was introduced by Government Decree 25/2024 (II. 14.) with effect from 1 March 2024 and was imposed on Samsung SDI in March 2025 for the serious and direct endangerment of 66 workers. In Göd, a construction fine of HUF 91.4 million had been imposed by 2022 for a hall built without a permit; the Bátonyterenye battery-recycling plant of Korea’s SungEel HiTech was suspended indefinitely in August 2023, and the operator of the associated Abasár waste store received a HUF 103 million waste-management fine; SK On’s Iváncsa plant was fined about HUF 14 million in August 2023 on chemical-safety and occupational-safety grounds; and against SK Battery in Komárom the disaster-management authority applied 35 sanctions (21 warnings and 14 fines) in the three years preceding the May 2025 fine. The Chinese plants in Debrecen were also fined before the election: HALMS Hungary in May 2024, Semcorp in August and November 2025 (HUF 1.5 million and HUF 4.5 million), and then in March 2026 – still under the previous government – with a maximum fire-safety fine of HUF 10 million and an equipment prohibition.

Neither criminal proceedings nor judicial limits appeared for the first time in 2026. Four criminal proceedings have been opened against Samsung SDI since 2023, one with an indictment; on the action of a local association, the Budapest Environs Regional Court suspended the environmental permit of the Göd plant by way of interim relief in 2024 and annulled it by judgment in October 2025; on 3 February 2026 the Curia (Supreme Court) set that judgment aside and ordered a new procedure; and in 2023 the Budapest Court of Appeal, in the CATL permit litigation, remitted the question of interim relief to the first-instance court for a new decision.

The difference, then, lies neither in the legal toolkit nor in the level of the fines. The 2026 fines of HUF 1–10 million fall within the frameworks of the sectoral fine decrees in force – fire safety (Government Decree 259/2011 (XII. 7.), up to HUF 10 million), disaster management (Government Decree 208/2011 (X. 12.)), waste management (Government Decree 271/2001 (XII. 21.)) and air quality (Government Decree 306/2010 (XII. 23.), whose rates the previous government tripled from 1 May 2025) – and the procedural fine against a legal person is capped at HUF 1 million under Section 77 of the General Public Administration Procedure Act. The difference lies in publicity: between 2018 and 2025 the decisions became known almost exclusively through freedom-of-information requests and litigation, the authorities routinely refusing to release them; in 2026 the sanctions are announced immediately by members of the government and governing-party MPs. The difference lies in consistency: suspension and activity prohibitions used to be exceptional, and production not infrequently continued despite a prohibition; today this is the first instrument. And the difference lies in systemic inspection: since 1 August 2026 a nationwide programme has been comparing permits with actual operations, extending to suppliers. The number of proceedings per company, however, has not risen: the seven investigations and four fines counted by G7 in the battery industry up to 26 August 2026 do not exceed the frequency represented by the roughly eight decisions a year that a single plant in Göd attracted on average in recent years.

III. THE NEW REGULATORY ARCHITECTURE

Behind the turn in the visibility of enforcement stands a rearrangement of the regulatory framework, whose elements can be identified by legal reference.

• Government Resolution 1144/2026 (V. 14.): comprehensive, accelerated review of investments of national economic priority; termination of priority status where maintaining it entails significant social, infrastructural or environmental risk; linked to this, the Prime Minister’s announcement of 20 July 2026 that all earlier government decisions, negotiations and state commitments relating to BYD – subsidies, tax allowances, fast-track permitting, infrastructure – would be reviewed. Government Decree 140/2026 (IX. 1.) has already terminated the priority status of several – so far non-battery – investments, providing that the repealed special rules may not be applied even in pending administrative cases.
• Government Decree 92/2026 (VI. 5.) (in force from 6 June 2026): no country is designated for new employment under the guest-worker residence permit; the residence permit for employment purposes remains available; existing permits, extensions and pending applications enjoy transitional protection. The decree does not directly affect Chinese and Korean parent-company assignees, who typically do not work under guest-worker permits; the correct choice of permit title is, however, a subject of immigration inspection.
• Government Resolution 1181/2026 (VI. 5.): preparation of an independent national environmental authority and a nationwide inspection programme covering the entire battery chain – anode, cathode, electrolyte, separator film, cell and module manufacturing – with a deadline of 30 September 2026 for the inspections. Government Resolution 1182/2026 (VI. 5.) calls for proposals to strengthen the environmental liability regime and sanctions by 1 October 2026; Government Resolution 1184/2026 (VI. 5.) abolished the minister’s power to designate sites and ordered a technology-neutral regulatory concept for the battery industry.
• Act XXXV of 2026: by amending Act LXXXIX of 2003 on environmental load charges, the air-load charge rates for sulphur dioxide, nitrogen oxides and non-toxic particulate matter double from 1 October 2026; the government package announced on 17 July also foreshadowed the phasing-out of tax allowances for multinationals and further rules for large water users.
• Nationwide battery-industry inspection programme (from 1 August 2026): on-site comparison of permit data with actual capacity, raw-material and solvent use, emissions, water use and waste management; inspections may be extended to suppliers and related facilities, with sampling and, in serious cases, immediate measures.
• Bill submitted to amend Act C of 2023 on Hungarian architecture: where the environmental or nature-conservation authority establishes an infringement, no further administrative permit may be issued for the priority investment until the unlawful situation is remedied, and for at least six months.
• National Environmental Supervisory Authority (according to the government’s announcement of 3–5 September 2026, from 1 January 2027): nationwide environmental permitting, inspection and sanctioning powers, with battery manufacturing as a priority area; under the announced sanctions regime, a HUF 5 billion cap for the most serious infringements, a “three strikes” principle – on the third infringement within five years, at least 0.5 percent of annual net turnover and no less than HUF 5 million – and abolition of the HUF 500 million ceiling for serious waste infringements. No bill had been submitted at the time of writing. The announced turnover-based rate is expected to apply to the annual net turnover of the Hungarian subsidiary rather than the group; whether the turnover of affiliated undertakings counts will be decided by the text of the bill – something the Chinese parent must also take into account in the capital and invoicing structure of its Hungarian subsidiary.

IV. POLITICAL CONFRONTATION OR LAWFUL SANCTION? – THE FIRM’S ASSESSMENT

Subject matter. We found no case in which an authority sanctioned a Chinese company without an established infringement. In the Semcorp case the factual basis is the authority’s measurements, in the CATL cases the company’s own admission, in the BYD case the sampling results and the fatal accidents. The target of the sanctions is the sector: the battery value chain and industries classed as major polluters, whose operators in Hungary are predominantly Korean- and Chinese-owned. The two maximum fines of the period hit a Korean plant and a Hungarian contractor; the Chinese companies’ own fines remained between HUF 1 million and HUF 10 million.

Severity. The fines fall within the frameworks in force – those created by the previous government. The real sanction is not the fine but the collateral consequence: withdrawal of consent, suspension of activity, work prohibition, refusal of the occupancy permit, political rejection of expansion, review of the subsidy agreement, criminal proceedings – and the market effect: CATL’s Hong Kong shares fell 4.65 percent on 2 September 2026 after the international press reported the Debrecen work prohibition. Hungarian authority findings can also be used at EU level: the European Commission is examining BYD’s Szeged investment under the Foreign Subsidies Regulation (FSR), and the review of Hungarian subsidy agreements is also linked to EU state-aid rules.

Communication. Political motivation can be detected in timing and communication: sanctions are announced by governing-party politicians on social media, CATL’s expansion was rejected by political statement, and the Szeged investment has drawn particular attention because of the former foreign-trade minister’s position at BYD. That motivation has nonetheless remained within the bounds of law enforcement: the decisions rest on statute and are open to legal remedy – Semcorp has filed an action, EcoPro contests proportionality – and the courts demonstrated their independence from the authorities in previous years as well.

The official Chinese position draws the same distinction. Ambassador Gong Tao, in an interview with Daily News Hungary published on 9 September 2026, said that the Chinese government has always expected Chinese companies – BYD included – to comply strictly with Hungarian and EU law; that it takes note of the investigations conducted by the Hungarian government in accordance with the law; and that it expects a fair, transparent, predictable and non-discriminatory business environment for all Chinese and foreign investors. An analysis published by the Peking University Institute for Cultural Exchange between China and Foreign Countries (北京大学中外人文交流研究基地; Zhu Zhaoyi 朱兆一, 29 April 2026) holds that the new government’s starting point is pragmatic cooperation, not confrontation – at the price of alignment with EU standards. Péter Magyar, on the day after the election, 13 April 2026 – as prime minister-designate – called China one of the most important, largest and strongest countries in the world, open to foreign capital under “clear conditions”: environmental protection, health, workplace safety.

The assessment in one sentence: continuity in law, a turn in visibility. Whoever operated without sanction until now was protected not by the absence of law but by the absence of publicity – and that period is over.

V. MAP OF THE AUTHORITIES: WHO, WHAT, IN WHICH PROCEDURE

For decision-makers at Chinese parent companies the greatest uncertainty stems from the fact that the Hungarian administrative system consists of several independent actors that examine the same site in separate proceedings. The specialised departments of the county government office – environment and nature conservation, water, occupational safety, industrial safety and disaster management, fire safety, construction – issue independent decisions with independent fine ranges. The police act under the Criminal Code (Act C of 2012) on the offences of environmental damage (Section 241), violation of the waste-management order (Section 248) and endangerment in the course of an occupation (Section 165), typically on a complaint by the authority or the municipality. Criminal proceedings are conducted against natural persons – typically the Hungarian managing director, the site manager, the HSE officer; measures under Act CIV of 2001 (fine, restriction of activity) may also be applied against the legal person, so the Chinese parent must prepare for the personal liability of its assigned managers as well (defence counsel, D&O insurance). The National Directorate-General for Aliens Policing examines the residence titles of third-country workers; the labour authority examines working time and pay. The Competition Authority and the National Tax and Customs Administration, as autonomous and central authorities respectively, supervise commercial practices and taxation. The fate of subsidy agreements and priority status is decided by the government and the Hungarian Investment Promotion Agency.

The procedural framework is Act CL of 2016 on General Public Administration Procedure (Ákr.) and Act I of 2017 on the Code of Administrative Court Procedure (Kp.). Four rules deserve emphasis. First: suspension and prohibition decisions are usually declared immediately enforceable by the authority (Ákr. Section 84); no administrative appeal lies against a government-office decision, an administrative action may be brought within 30 days of service (Kp. Section 39), and filing the action has no suspensive effect (Kp. Section 39(6)), so interim relief must be requested together with the action (Kp. Section 50). Second: a statement recorded in the minutes of an on-site inspection is later evidence – in the administrative and the criminal procedure alike. Third: where the circle of affected persons cannot be precisely determined, the authority publishes the decision in addition to serving it on the addressee (Ákr. Section 89), as happened in the EcoPro case – the company’s time limit for remedy runs from its own service, while the local public learns of it from the authority’s website. Fourth: the language of the procedure is Hungarian (Ákr. Section 20); the authority does not accept foreign-language documentation, operating logs or safety reports, statements are recorded in Hungarian, and arranging interpretation is the company’s responsibility.

VI. WHERE COMPANIES FAIL: EIGHT TYPICAL AREAS OF INFRINGEMENT

From the cases of the past five months – and the experience of earlier years in Göd, Komárom and Bátonyterenye – eight recurring types of error emerge.

• Hazardous-waste management: missing Hungarian-language labelling, unmarked on-site collection point, missing operating log, unattended collection point, open or damaged containers (CATL 2026; SK Battery 2025; Samsung SDI 2020–2021).
• Stormwater and wastewater management: operation deviating from the conditions of the pre-treatment consent, discharge of pressure-test or washing water into the sewer (CATL; HALMS 2024).
• Soil and groundwater monitoring: missing sampling and reporting deadlines attracts a fine in itself, irrespective of whether pollution occurred (Semcorp: HUF 1 million procedural fine for delay).
• Workplace exposure: omitted air measurements, unreported nickel and cobalt exposure, inadequate protective equipment, omitted occupational-health examinations (SK On, CATL, Samsung SDI, SK Battery).
• Construction phase: earthworks, removal of topsoil, waste transport, crane and loading safety, fatal accidents (BYD site 2026; Iváncsa 2023).
• Third-country workers: documentation of residence title, working time, pay and the subcontracting chain; contractors’ failures burden the investor’s reputation (AE Industry on the BYD site).
• Fire and industrial safety: operation deviating from the safety report, inoperable extinguishing system, dust emissions, unsealed pipe penetrations (Semcorp, EcoPro).
• Communication with the authority and the local community: foreign-language documentation, refusal to admit inspectors, mishandled public hearings, deteriorated relations with the municipality (EcoPro 2025–2026; Samsung SDI 2024; Semcorp–Debrecen).

VII. THREE LESSONS FROM THE SUMMER CASES

Self-reporting – with an action plan. CATL, in line with its statutory duty, itself reported the elevated nickel exposure of nine workers; the authority responded with a work prohibition in three plant sections because it found protective equipment missing on site. Self-reporting is correct and mandatory, but it should be made only with a ready action plan – a new protective-equipment matrix, medical follow-up, technological modification and its documentation. Otherwise the content of the action plan will be dictated by the authority’s prohibition.

The subcontracting chain. The pressure-test fluid CATL discharged into the sewer was the subcontractor’s responsibility, yet the subject of the administrative procedure was CATL; on the Szeged site the contractor’s HUF 100 million fine went through the press as a “BYD fine”; the inspection programme of 1 August expressly extends to suppliers. BYD introduced a subcontractor compliance declaration on pay, working time, visas and health insurance as early as May 2026 – that is the minimum. The contractual compliance chain must include entry controls, documentation and reporting duties, audit rights, a ground for extraordinary termination and an indemnity chain. Under Hungarian law the subject of the administrative procedure is the permit holder of the site, i.e. the investor: it bears the fine for the subcontractor’s failure and can pass it on only through civil law – without a contractual indemnity chain and security elements (bank guarantee, retention), a compliance declaration alone offers no protection.

Permitting precision. The occupancy permit for CATL’s second phase was refused not on environmental grounds but because of a site-plan error; Government Decree 140/2026 (IX. 1.) terminated priority statuses; under the submitted bill, no further administrative permit may be issued for a priority investment for at least six months after an environmental infringement. Permitting documentation today is not administration but a scheduling and financing risk.

VIII. HOW TO AVOID SANCTIONS: A TEN-POINT PROTOCOL

• Preventive enforcement audit against the criteria of the nationwide inspection programme: environment, water, waste, occupational safety, industrial safety, fire safety, immigration.
• Line-by-line re-reading of permit conditions and comparison with actual operation: capacity, raw materials and solvents, water use, emissions.
• Hungarian-language documentation regime: labelling, operating logs, safety report, internal rules.
• Monitoring and reporting calendar with authority deadlines and responsible persons; delay is an infringement in its own right.
• Subcontractor compliance package: declaration, entry permit, audit right, termination ground, indemnity chain.
• Workplace-exposure management: measurement plan, protective-equipment matrix, biological monitoring, occupational-health reporting.
• Inspection protocol: who receives the inspector, who makes statements, what is handed over, handling of statements in the minutes, presence of counsel.
• Self-reporting and incident-management procedure with a ready action plan.
• Remedy strategy: when to pay and close (the CATL model), when to contest (Semcorp; EcoPro proportionality); interim relief for every suspension.
• Legal review of subsidy agreements and priority status ahead of the review; continuous, documented relations with the municipality and the local community.

IX. THE ROLE OF LEGAL COUNSEL

Internal compliance is necessary but not sufficient. The administrative procedure is conducted in Hungarian and against deadlines; a statement in the minutes is later evidence; a suspension decision is immediately enforceable; under the announced 2027 regime the number of infringements – not only their amount – may count; and permitting and the subsidy review are a negotiating situation in which the investor’s position is decided by the quality of its documentation. DHH Budapest Office (Czudar DHH Law Firm – Hungary), as the Hungarian and EU strategic partner of DHH Beijing, offers Chinese investors the following standardised service packages:

• Enforcement audit: full legal due diligence of the site following the logic of the nationwide inspection programme, with a written gap analysis and action plan.
• Inspection readiness under a standing mandate: presence and representation at inspections, professional handling of the minutes and statements, Chinese-language liaison with the parent company.
• Representation in fine, suspension and prohibition cases: administrative remedies, administrative litigation with interim relief, an agreed restoration programme for supervised restart; coordination of criminal defence where needed.
• Permitting and subsidy representation: occupancy and environmental permits, priority status, review of subsidy agreements.
• Subcontractor and workforce compliance package: contractual compliance chain, immigration and labour-law due diligence, restructuring of the employment structure.

Our firm has represented Asian manufacturers operating in Hungary for more than ten years; our references include a successful remedy against a site-closure order, a legal opinion against a municipal environmental decree, the notification and permitting of industrial activities, and continuous immigration and corporate representation of Chinese and Korean companies. Fees are quoted individually.

X. CALENDAR: Q4 2026 – 2027

• 30 September 2026: deadline of the nationwide battery-industry inspection programme (Government Resolution 1181/2026 (VI. 5.)).
• 1 October 2026: doubling of air-load charge rates (Act XXXV of 2026); deadline for the proposal on strengthening the environmental liability regime (Government Resolution 1182/2026 (VI. 5.)).
• Autumn 2026: parliamentary debate of the architecture-act amendment and the announced bill on the national authority; results of the review of priority investments.
• 1 January 2027: planned start of the National Environmental Supervisory Authority and the announced sanctions regime.

Hungary is not closing the gate to Chinese capital – the government and the Chinese ambassador alike name lawful, non-discriminatory operation as the condition. But from now on the key to that gate is compliance: demonstrable, documented, in Hungarian, and with legal representation present from the first minute of the administrative procedure.

Sources

• Csongrád-Csanád County Government Office releases, 1 and 16 June 2026 (BYD)
• Hajdú-Bihar County Government Office releases, 24 June and 3 July 2026 (Semcorp), 25 August 2026 (CATL), 11 September 2026 (EcoPro, HB/21-TIO/00613-2/2026)
• kormany.hu: HUF 100 million fine on the Iváncsa battery plant, 21 August 2026; statement by László Gajdos, 21 June 2026; tax and environmental package, 17 July 2026; announcement of the national authority, 5 September 2026
• Magyar Közlöny (Official Gazette) 2026/64 (Government Decree 92/2026; Government Resolutions 1181–1184/2026); Government Decree 140/2026 (IX. 1.); Act XXXV of 2026 and its explanatory memorandum (njt.hu)
• GVH releases: Temu, 28 April and 20 July 2026; eMAG, 13 August 2026; Allegro, 30 June 2026
• Telex, 28 May, 5 June, 6 July, 24 August, 26 August 2026 (CATL, Semcorp; G7: seven investigations and four fines); G7, 19 August 2026 (HIPA statement to 24.hu); Portfolio, 25 August and 1 September 2026; Világgazdaság, 7 August 2026 (AE Industry correction), 2 September 2026 (CATL Hong Kong share price); 444, 7 August 2026; mfor.hu (architecture-act amendment); SCMP, 19 May 2026 (BYD subcontractor compliance declaration); Bloomberg, 18 July 2026 and Daily News Hungary, 19 July 2026 (statement by Dávid Vitézy)
• Átlátszó, 14 July 2026: Samsung SDI Göd, 61 decisions, HUF 405.3 million (2018–2025); Telex, 23 February 2026 (Csaba Latorcai: >HUF 400 million); Telex, 2 July 2025 (HUF 100 million occupational-safety fine, March 2025); Átlátszó, 23 August 2023 (SungEel suspension) and 30 August 2023 (Abasár, HUF 103 million); Index/Telex, 4 August 2023 (SK On Iváncsa, ~HUF 14 million); Átlátszó/HVG, 12 June 2026 (SK Battery Komárom); Debreciner (HALMS, Semcorp 2025); Telex, 21 March 2026 (Semcorp fire-safety fine); police.hu, 27 February 2026
• Daily News Hungary, 9 September 2026 (interview with Ambassador Gong Tao); Telex/Index, 13 September 2026; 北京大学中外人文交流研究基地 (朱兆一), 29 April 2026; Global Times (环球时报), 15 April 2026
• Czudar DHH – Cheng Tao: Chinese Investment in Hungary under the New Government – A Practical Legal Guide to Compliance (Part I; Hungarian and Chinese full text) and the English interview “Chinese Companies in Hungary Under the New Government: What Has Changed, and How to Respond”, July 2026