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Magyar Helsinki Bizottság

The Hungarian Helsinki Committee is a human rights organization protecting the rule of law through advocacy.

Lobbying Activity

Response to Guidance on the implementation of Regulation (EU) 2024/900 on the transparency and targeting of political advertising

25 Jun 2025

The Hungarian Helsinki Committee (HHC) is a human rights organisation based in Hungary, established in 1989. The HHC supports the European Commissions (EC) efforts to publish a guidance on the Regulation (EU) 2024/900 on the transparency and targeting of political advertising (Regulation). The Hungarian Helsinki Committee recommends the European Commission to draw up the upcoming guidance in a manner which ensures full respect for the rights of freedom of expression and freedom of association in practice, as well as the impartial application of the Regulation across the EU. Firstly, the broad definition of political advertising in Article 3(2)b) of the Regulation could result in its application to civil society organisations (and the media) even when these entities are exercising their right to freedom of expression on issues which are unrelated to the electoral competition. The definition encompasses messages which are designed to influence legislative or regulatory processes at EU, national, or local level. Section 1 of Article 8 of the Regulation provides a non-exhaustive list of features of a message that should be considered when determining whether a message constitutes political advertising. Section 2 authorises the EC to provide guidance on the proper application of the definition and the list. The EC guidance should ensure that the Regulation is not used to restrict freedom of expression or association. The definition of political advertising must not be so open-ended that it could be applied intentionally or inadvertently to hinder the work of civil society organisations, which are pillars of the rule of law and democracy throughout the EU. Civil society organisations routinely publish their perspectives on policy issues relevant to their mission. Their goals are to increase public awareness and advocate for improved policies. Because of how social media algorithms work, these organisations often must pay for promoted content or advertisements to ensure their messages reach their intended audience. A wide range of topics may fall under the definition in Article 3(2)b), from EU-level animal welfare, local environmental protection and national education, to healthcare, the rule of law and the right to non-discrimination. Secondly, given the variety of national authorities appointed to enforce the Regulation, the EC should provide detailed guidance on the definition of political advertising, how to avoid bias in applying the definition, and how to prevent the Regulation from being applied unfairly or abusively across the EU space. If a Member State does not appoint an independent authority, or if it appoints an authority that only appears to be independent but in effect is biased, the risk that the given authority will not examine violations of the Regulation conducted by its appointers and their affiliates in politically sensitive cases increases significantly. Conversely, there is also a risk that this authority could misuse its power to target critics of the appointers actions. For example, Hungarys National Media and Infocommunications Authority (Media Authority) has already been appointed both as the Digital Services Coordinator referred to in Article 49 of Regulation (EU) 2022/2065 and as the competent authority referred to in Article 30 of Directive 2010/13/EU. Both types of authority are referred to in Article 22 (Competent authorities and contact points) of the Regulation. The president of the Hungarian Media Authority is appointed, on the proposal of the Prime Minister, by the President of the Republic who is elected by the Parliament. The Media Authority is accountable only to the Parliament, in which the governing parties currently hold a supermajority. It is well documented that the Media Authority's practices in the media market are seriously biased towards pro-government actors, which corroborates the perceived loyalty suggested by the appointment of its president and its accountability.
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Meeting with Gosia Pearson (Cabinet of Commissioner Magnus Brunner)

26 May 2025 · Civil society in Hungary and implementation of funds in the area of Home Affairs.

Meeting with Fausto Matos (Cabinet of Executive Vice-President Henna Virkkunen)

23 May 2025 · Rule of law

Meeting with Simona Constantin (Cabinet of Commissioner Michael McGrath)

22 May 2025 · Rule of Law, European Democracy Shield

Meeting with Andrzej Celinski (Cabinet of Commissioner Piotr Serafin), Anne Funch Jensen (Cabinet of Commissioner Piotr Serafin)

21 May 2025 · Exchange of views on Rule of Law and conditionality mechanisms

Meeting with Daniel Freund (Member of the European Parliament) and Mérték Médiaelemző Műhely Közhasznú Nonprofit Kft and Háttér Society

20 May 2025 · Hungary Rule of Law Event

Meeting with Daniel Freund (Member of the European Parliament) and Energy Cities and Hertie School

7 Apr 2025 · BUDG/CONT hearing on RoL conditionality

Meeting with Daniel Freund (Member of the European Parliament)

25 Mar 2025 · Supporting Civil Society in Hungary

Meeting with Ivana McDowell (Cabinet of Commissioner Nicolas Schmit)

27 Jun 2024 · HU sovereignty law

Meeting with Alvaro De Elera (Cabinet of Vice-President Věra Jourová)

27 Jun 2024 · Rule of law

Meeting with Johannes Noack (Cabinet of Commissioner Johannes Hahn)

27 Jun 2024 · Discussion on the rule of law and the EU budget

Meeting with Daniel Freund (Member of the European Parliament) and Transparency International Liaison Office to the European Union and

1 Feb 2024 · The Rule of Law ahead of the EU elections

Meeting with Daniel Freund (Member of the European Parliament) and OXFAM INTERNATIONAL EU ADVOCACY OFFICE and

30 Jan 2024 · Rule of Law

Response to Proposal for a Directive on cross-border activities of associations

15 Dec 2023

Recharging Advocacy for Rights in Europe a solidarity alliance of over 50 human rights defenders from 19 EU countries welcomes the European Commissions proposal for a Directive on European Cross-Border Associations. CSOs that operate in multiple EU member states could create one legal organisation across their home and host countries. ECBAs would enjoy the free movement of goods, services and capital, and be able to change their home country without creating a new organisational structure or losing assets. However, the proposal does not address many of the administrative and legal complexities our organisations face. For member states to accept it, and for it to benefit CSOs as much as possible, EU legislators need to ensure the proposal supports EU values, clarifies structural issues and is fully implemented. Once adopted and transposed into national laws across the 27 EU member states, the inclusion of civil society voices in review processes will help ensure the directive is consistently applied in all member states. We also call on the EU to adopt additional measures to protect and expand civic space, such as a directive on Common Minimum Standards for Non-Profit Organisations, measures to harmonise taxation rules for cross-border donations to nonprofit organisations, and stronger protections for human rights defenders across the EU. Recommendations The directive should be as clear as possible for member states to accept and adopt it. It must reflect EU values, create clear structures for ECBAs, and be implemented with regular review by the European Commission and civil society. EU Values The directive should reflect the EUs founding values of respect for human dignity, freedom, democracy, equality, the rule of law and respect for human rights, and reference these Treaty on European Union Article 2 values in the text. ECBA Structures Executive Bodies Rather than requiring that all members of an ECBAs executive body be EU citizens or residents, we support the JURI reports suggestion that at least two members of an ECBA must have links to at least two member states (Article 7.2). External funding There should not be any restrictions on receiving funds from outside the EU (Article 15 may imply this). Tax obligations Clarify if ECBAs need to pay taxes in their home or host states. Implementation Funding from host and home countries Ensure that public authorities in home and host states allow ECBAs to apply for national, regional and local funding available to non-profits and address language barriers. ECBAs also need to be able to open bank accounts in host and home countries, even when no board members reside there. Sensitive information No additional disclosure requirements should be imposed on ECBAs (beyond existing national laws and European standards). Treat ECBAs the same as nationally registered associations during their registration and operations. In case these safeguards are not applied or are applied discriminately, the remedy in national law must be simple, speedy and affordable. Publicise the new legal form and help smaller CSOs set them up. Hold regular informational sessions for CSOs after the directive is adopted. Regular review with CSOs We call on the Commission to regularly review the directives implementation, including holding meaningful civil dialogue with representatives of associations (ECBAs and national CSOs) to discuss progress and challenges with the Commission, Parliament and member states, and suggest measures to improve it. We fully support the JURI reports extensive review recommendations.
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Meeting with Gwendoline Delbos-Corfield (Member of the European Parliament, Rapporteur)

7 Dec 2023 · Situation in Hungary

Meeting with Gwendoline Delbos-Corfield (Member of the European Parliament, Rapporteur) and Amnesty International Limited and

7 Sept 2023 · Situation in Hungary

Meeting with Gwendoline Delbos-Corfield (Member of the European Parliament, Rapporteur)

15 Jul 2023 · Situation in Hungary

Meeting with Gwendoline Delbos-Corfield (Member of the European Parliament, Rapporteur) and Amnesty International Limited and

14 Jul 2023 · Situation in Hungary

Meeting with Gwendoline Delbos-Corfield (Member of the European Parliament)

21 Feb 2023 · Alleged use of Pegasus spyware by Hungarian government

Meeting with Gwendoline Delbos-Corfield (Member of the European Parliament, Rapporteur) and Amnesty International Limited and

7 Sept 2022 · Situation in Hungary

Meeting with Gwendoline Delbos-Corfield (Member of the European Parliament, Rapporteur) and Human Rights Watch and Mérték Médiaelemző Műhely Közhasznú Nonprofit Kft

16 May 2022 · Situation in Hungary

Meeting with Gwendoline Delbos-Corfield (Member of the European Parliament, Rapporteur) and Mérték Médiaelemző Műhely Közhasznú Nonprofit Kft

1 Apr 2022 · Situation in Hungary

Meeting with Gwendoline Delbos-Corfield (Member of the European Parliament, Rapporteur) and Reporters sans frontières and

24 Mar 2022 · Situation in Hungary

Meeting with Joachim Herrmann (Cabinet of Commissioner Didier Reynders)

5 Feb 2020 · Challenges for the civil societies

Meeting with Ylva Johansson (Commissioner)

19 Dec 2019 · Discussions on the New Pact on Migration

Meeting with Thomas Zerdick (Cabinet of First Vice-President Frans Timmermans) and Civil Liberties Union for Europe and Társaság a Szabadságjogokért

10 Oct 2017 · Exchange of views on the current situation with NGOs in Hungary