Post-election report of the President of the NMHH as Digital Services Coordinator

Executive summary

The Digital Services Act (hereinafter: DSA) aims to provide a safe, predictable and reliable online environment for EU users of intermediary services, including online platforms, hosting services and search engines. The DSA also aims to combat illegal online content and the spread of disinformation. The Digital Services Coordinator (hereinafter: DSC or Digital Services Coordinator) is responsible for the implementation and supervision of compliance with the DSA by intermediary service providers established (or legally represented) in a specific Member State. Since 1 January 2023, the National Media and Infocommunications Authority (hereinafter: NMHH) has been the DSC in Hungary, no other competent authority has been appointed. The President of the NMHH independently exercises all the powers and functions of the DSC.

In addition to the general rules for intermediary service providers, under the DSA additional obligations apply to Very Large Online Platforms (hereinafter VLOPs) and Very Large Online Search Engines (hereinafter VLOSEs), collectively referred to as VLOPSEs. As a consequence of this obligation, the VLOPSEs are required to regularly assess the presence of systemic risks that can be identified in relation to their services, including adverse effects on the electoral process, and implement mitigation measures to reduce these risks.

Ensuring compliance with the obligations to mitigate systemic risks for electoral processes falls within the exclusive competence of the European Commission. Nevertheless, Digital Services Coordinators in the Member States play an important role in sharing relevant information, developing knowledge and supporting cooperation between stakeholders at national level. At its meeting on 19 February 2025, the European Board for Digital Services (hereinafter: DSA Board) adopted the document “DSA Elections Toolkit for Digital Services Coordinators - Instruments, Best Practices, and Lessons Learnt” (hereinafter: Elections Toolkit). Designed for the Digital Services Coordinators under the DSA, the Elections Toolkit aims to provide Digital Services Coordinators with guidance and a practical guide on how to contribute to a coherent protection of electoral processes across Europe by summarising approaches, methods and measures that can ensure a more effective response to systemic risks under the DSA. In preparation for the 2026 parliamentary elections, taking into account the best practices contained in the Elections Toolkit has helped the NMHH to perform its duties as a DSC in a prepared and efficient manner, within its statutory powers, during the campaign period and the parliamentary election. In addition, in the future it may be appropriate to clarify the competences relating to disinformation and to review the legal provisions allowing information sharing between the authorities involved in the electoral processes, in order to strengthen cooperation between them.

1. Introduction

Preserving the fairness and transparency of elections in the online environment is an increasingly complex task, requiring fast, clear and transparent communication mechanisms, while duly respecting legal competencies. Protecting electoral integrity is a common interest. This includes effectively managing illegal content, reducing risks from illegal campaigning practices and strengthening transparency and accountability, while fully respecting users’ freedom of expression. The interplay between national and EU regulatory frameworks and the co-existence of offline and online campaigning techniques creates a regulatory environment in which inter-institutional coordination is of particular importance. Election periods are also characterised by increased time pressure: authorities, service providers and legal remedy bodies have to react quickly to situations that raise issues of legality, fundamental rights, communication and technology.

The special characteristics of the Hungarian regulatory and institutional environment, together with the requirements of the EU digital regulatory framework, shaped the operational space in which the NMHH operated during the 2026 election period. This report interprets the NMHH’s activities related to the parliamentary elections within this framework.

Based on the Elections Toolkit, Digital Services Coordinators can issue post-election reports providing an overview of the actions taken and the lessons learned. This report summarises the activities of the President of the NMHH, as Digital Services Coordinator, in relation to the 2026 general election of Members of Parliament.

1.1. Hungarian electoral regulation and its institutional environment

Ensuring the integrity, transparency and lawfulness of the electoral process in Hungary is based on the cooperation of several interrelated areas of law and several institutions.

The time frame of the electoral process is regulated in detail in Act XXXVI of 2013 on Electoral Procedure. The date of the parliamentary elections is set by the President of the Republic, at least seventy days but not more than ninety days before the day of the vote, and the election procedure officially begins. The official campaign period starts on the 50th day before the vote. From that date, campaign activities are conducted within a legally distinct and regulated period, with particular emphasis on the rules on campaign communication, political advertising, media coverage and campaign financing. On election day, there is no general campaign silence and campaigning may, as a general rule, continue until polling stations close, but no campaigning may take place in the immediate vicinity of polling stations within 150 metres of the entrance. This relative territorial ban on campaigning is intended to allow voters to exercise their right to vote at the polling station without direct interference.

Hungarian legislation defines campaigning in a broad sense. Any activity aimed at influencing the will of voters is considered campaigning. This includes traditional instruments, in particular posters, leaflets, election rallies and press coverage, but also political content published online. This has become particularly important as digital services have become a key space for the democratic public in recent years. Political communication, campaign messages, voter mobilisation and public debate are increasingly taking place online. This change has created significant opportunities, but also new types of risks that are particularly acute during election periods.

Hungarian electoral legislation contains detailed provisions on the forms of communication used in the campaign and political advertising. Campaign publications must indicate the name and registered office of the publisher and the name of the person responsible for the publication. This serves transparency and accountability and also appears as a guiding requirement for paid political advertising in the online space. The law distinguishes between political advertising and political advertisements. The term political advertising is used primarily in relation to content published in audiovisual media services, whereas political advertisements refers to paid content in press products. Political advertising on television and radio during the campaign period must be free of charge and must be available to all entitled parties on equal terms. Political advertisements in print and online press products may also be published on a market basis, but this requires the prior publication of a price list and its submission to the State Audit Office of Hungary. However, this regulatory model is essentially based on the categories of media service providers and press products, and is not fully adapted to the functioning of social media platforms and other online intermediary services. According to the terminology of Hungarian electoral law, VLOPs are neither classical press products nor media service providers. Therefore, the domestic rules applicable to them are not always directly enforced, but often only through general campaign rules, transparency requirements or specific redress mechanisms.

The central actor of the Hungarian electoral organisation system is the National Election Commission (hereinafter: NEC). The NEC is an independent body at the top of the electoral commission system, whose task is to ensure the legality of the electoral process, safeguard the fairness of elections, enforce impartiality and equal opportunities, and restore the lawful order of elections when violations of the law occur. The NEC decides on the registration of the national lists, the approval of the ballot papers, the determination of the national results and the allocation of mandates. It is also an important forum for legal remedy, as a significant number of objections related to election campaigns, media coverage and other campaign tools are received through the Electoral Commission system. Its decisions may be subject to judicial review. The most important judicial review body is the Curia, the Supreme Court of Hungary, which proceeds expeditiously in applications for review of election cases. Due to the rapidity of the electoral process, the Curia’s proceedings are conducted within particularly short deadlines and its decisions are final and binding. In election disputes, the Curia thus ensures the unity of legal interpretation and judicial control of the decisions of electoral bodies. At the same time, the Constitutional Court is seen as an institution of constitutional control. On the one hand, it can review electoral legislation and, on the other hand, it can assess, on the basis of a constitutional complaint, whether the decisions of the judiciary in the electoral procedure are in line with the rights guaranteed by the Fundamental Law.

In the media field, the Media Council of the NMHH also has a special role to play during the election period. The Media Council, operating within the NMHH, supervises the enforcement of the legal requirements for media content and media services, including the media content requirements related to election campaigns. In the case of traditional media, it has a role in enforcing the rules on political advertising and in monitoring the requirements for impartial, fair and balanced presentation of candidates and candidate organisations. However, this competence is essentially related to the classical media services environment and does not extend in the same way to social media platforms and other online intermediary service providers.

1.2. The EU regulatory framework

Under Articles 34 and Article 35 of the DSA VLOPSE service providers must regularly assess the systemic risks associated with their services. One of these risks is any actual or foreseeable negative effects on civic discourse, as well as on the electoral processes and public security within the meaning of Article 34(1)(c). On the basis of the risk assessment, VLOPSE providers must implement reasonable, proportionate and effective mitigation measures. According to the DSA, providers not designated as VLOPSEs do not have such an obligation.

In recent years, attempts to influence elections via online platforms (e.g. through disinformation campaigns or foreign information manipulation and interference) have become a growing problem. Social media platforms play a significant role in the spread of disinformation, as their operating model and design features can inadvertently facilitate the rapid spread of false information. The DSA does not specifically identify “disinformation” as a harmful phenomenon, but addresses it in the context of systemic risk, focusing specifically on the responsibility of the largest platforms.

• According to Article 34(1)(c) of the DSA, Very Large Online Platforms (VLOPs) are required to identify systemic risks to civic discourse and the electoral process. The spread of disinformation could appear as such a risk.
• Under Article 35 of the DSA, it is not enough to identify these risks, they must also effectively mitigate them (e.g. by modifying their algorithms, or by modifying their content moderation procedures)

In addition to the DSA provisions, the European Commission has published a package of recommendations in the form of guidelines for providers of VLOPs and VLOSEs. According to the guidelines, the VLOPSEs should, among other things, take measures to prevent and curb disinformation, manipulated content and foreign interference attempts, and should establish cooperation with national authorities and DSCs in the Member States in the context of electoral procedures in order to take effective action. The systemic risk obligations of VLOP and VLOSE providers fall under the direct and exclusive supervision of the European Commission. The Digital Services Coordinators can assist the European Commission in this supervisory activity by monitoring the activities of VLOPSE providers with a view to preventing negative effects on the electoral process, taking into account national specificities. The role of Digital Services Coordinators is therefore not to enforce the obligations on VLOP and VLOSE providers, but to raise awareness among election stakeholders of the tools of the Digital Services Act that can contribute to protecting the integrity of elections. The Elections Toolkit for Digital Services Coordinators also provides guidance for DSCs in this area. The purpose of this Elections Toolkit is to provide Digital Services Coordinators with a practical guide on how they can contribute to a coherent protection of electoral processes across Europe, summarising approaches, methods and measures that can help to better address systemic risks under the DSA. The Elections Toolkit contains possible tools, activities and case studies recommended for DSCs, from which Digital Services Coordinators can select and apply the appropriate and necessary solutions, taking into account national specificities and competences.

1.3. Legal framework for the role of the NMHH as DSC

In the regulatory space outlined in 1.1 above, the Hungarian Digital Services Coordinator emerged as a new, distinct actor compared to the 2022 parliamentary elections. In this capacity, the NMHH’s role in electoral matters is not primarily that of a classical electoral authority, but consists of coordination, information provision and cooperation support functions. Within its mandate, the NMHH as DSC facilitates communication between relevant actors, supports users and service providers on issues related to the application of the DSA, cooperates with other national coordinators and the European Commission, and mediates or forwards complaints and requests as necessary.

During the election period, this role can be particularly relevant in areas such as supporting the identification and assessment of systemic risks related to the electoral process, facilitating the flow of information on illegal content on online platforms, and encouraging the development of communication and escalation channels to address the increased time pressure of election periods. This is particularly important as campaigns are no longer just on the streets, in the print media or on television, but increasingly in the online environment, especially on online platforms. The specificities of this environment, such as speed, immediacy, personalised content dissemination, the possibility of amplification, cross-border effects and the efforts to influence public discourse in an organised way, pose fundamentally new challenges. The only way to respond to these challenges is through concerted action by several actors. The President of the NMHH, as DSC, is one of the actors within this coordination framework, whose task is not to replace the powers of the electoral bodies or the courts, but to support communication, information sharing and cooperation using the legal instruments at its disposal.

2. Preparation and consultation with stakeholders

In preparation for the 2026 parliamentary elections, it carried out the tasks related to its duties as Digital Services Coordinator on the basis of an internal action plan, based on the DSA and the Elections Toolkit, and in a scheduled manner. In defining the tasks, it has taken account of national specificities and the NMHH’s statutory competencies. An important element in identifying the tasks was to clarify that:

• the President of the NMHH, as a Digital Services Coordinator, has no statutory competence to investigate the illegality of content and order the removal of content, nor does he have authority regarding artificial intelligence technologies and infringements of intellectual property rights,
• the NMHH has no authority to detect and identify disinformation,
• the services of online platform providers established in Hungary did not pose an identifiable risk to the electoral process, but it was identified that the social media services of some VLOPSE providers established in other Member States could have a significant impact on the Hungarian elections.

However, the integrity of the electoral process is a common interest and, although the role of the NMHH and the President of the NMHH in relation to elections is limited under the current national and EU legislation, the President of the NMHH, as a Digital Services Coordinator, aimed to promote cooperation and supporting fast, predictable and transparent communication between relevant actors within the available framework.

The President has identified the following tasks as priorities:

1. Coordination between the Member State authorities and bodies involved in the elections, the European Commission and the relevant VLOP and VLOSE providers to facilitate the establishment of appropriate contact points and communication channels. The aim of the NMHH was to enable an effective and coordinated response to potential incidents around elections, with implications for their integrity or public security, by establishing incident management protocols and networks, and by establishing and promoting access to appropriate escalation channels.
2. Sharing information with Member State authorities and bodies involved in elections on the mechanisms established by the DSA and their applicability during elections. The aim of the NMHH was to establish contacts and information exchange arrangements and processes to better understand the roles and responsibilities of the parties involved in the elections, the legal framework applicable to the elections, and the operation and measures of VLOPs and VLOSEs in the Hungarian parliamentary elections.
3. Promoting user awareness, education on the tools and mechanisms under the DSA to enforce users’ rights and on the various risks in the online space, in particular the systemic risks on the services of VLOP and VLOSE providers. In the case of the NMHH, it was also important to clarify and clearly communicate the role of the President of the NMHH as DSC in the context of the election procedure and the extent of his powers to supervise the activities of online platforms.

Preparations for election-related tasks started in the third quarter of 2025, to allow sufficient time for the NMHH to establish contact with stakeholders and consult with them individually before the expected date of the parliamentary elections, and to carry out communication activities aimed at promoting user awareness in a timely and timely manner. On 13 January 2026, the President of the Republic announced that the parliamentary elections would be held on 12 April 2026 and, subject to the provisions of the law, the official campaign period began on 21 February 2026.

2.1. National authorities, courts

In preparation for the parliamentary elections, the NMHH contacted the competent authorities, courts and bodies (the National Election Office, the National Election Commission, the National Security Service, the National Cyber Defence Institute, the Curia and the Constitutional Court) concerned with the elections and the risks identifiable in relation to elections on online platforms. The NMHH shared the Hungarian translation of the Elections Toolkit with the relevant bodies, providing information on its role. The NMHH also organised a professional consultation with relevant authorities, courts and bodies in February 2026, providing further comprehensive information on the role of the NMHH President as Digital Services Coordinator and the objectives and legal options for the DSA in relation to the elections.

2.2. Consultations with the VLOPSE providers concerned

Among the service providers established in Hungary, the European Commission has not designated any VLOP or VLOSE service provider, and the number of users of the online platforms operated by these service providers is significantly below the threshold for designation. The obligations set out in Articles 34 and 35 of the DSA therefore do not apply to identified online platforms established in Hungary. The President of the NMHH, as a Digital Services Coordinator, can monitor compliance with the provisions of the DSA relating to intermediary service providers and online platforms in respect of service providers established in Hungary and thus falling within his jurisdiction and competence, in particular the proper functioning and operation of the notification and action mechanisms under Article 16 of the DSA. Moreover, given the nature, characteristics, size and traffic of the online platform services of Hungarian-based service providers, the NMHH has not identified any Hungarian-based service provider whose operation is likely to raise the same kind of priority problems as the systemic risks identified in the DSA in relation to election procedures.

Internet usage research commissioned by NMHH for the year 2025*420* shows that a significant percentage of the Hungarian population rely on social media sites and other internet sources for obtaining information on elections and political issues. In addition to domestic providers, the NMHH has also examined the services of providers established in other Member States, mainly designated as VLOP or VLOSE providers.

The Eurobarometer Social Media Survey 2025 also confirms that social media platforms are the most important source of information for Hungarian users.

According to the NMHH’s 2025 internet usage survey, a significant number of Hungarian users use the services of several VLOP providers.

The NMHH has identified several VLOP and VLOSE providers that, due to the nature of their services, could potentially have a negative impact on electoral integrity:

In the light of this, the NMHH contacted the relevant VLOP and VLOSE providers and held meetings with their representatives between November 2025 and February 2026, either online or in person.

• Meta Platforms Ireland Limited (Facebook and Instagram Very Large Online Platforms)
• TikTok Technology Limited (TikTok Very Large Online Platform),
• Google Ireland Ltd. (Google Search Very Large Online Search Engine, YouTube Very Large Online Platform),
• Twitter International Unlimited Company (X Very Large Online Platform), and
• Microsoft Ireland Operations Limited (Bing is a Very Large Online Search Engine).

In the framework of the consultations, the NMHH provided information on its competences, its activities as a Digital Services Coordinator and the basic characteristics of the Hungarian electoral system. Providers described the characteristics of their services, their current usage policies and the measures and mechanisms they apply in relation to the elections, as well as their different escalation channels (including escalation channels used by the NMHH or other authorities).

2.3. Election Roundtable

On 5 March 2026, the NMHH organised a roundtable discussion in Budapest, where the following were represented online or in person: the European Commission, the most relevant VLOP and VLOSE providers for Hungarian elections, the relevant national authorities (such as the NEC, the National Election Office, the National Cyber Security Center of the Special Service for National Security), the Curia and the Constitutional Court. The main objective of the round table was to facilitate the exchange of information and best practices between stakeholders, authorities and service providers involved in the elections. During the meeting, the National Election Office presented the NEC and its own activities. The VLOP and VLOSE providers present gave a brief presentation of the main features of their services concerned, as well as the measures they have taken to ensure the integrity of the electoral process and their cooperation with local authorities. Two service providers have indicated that they will provide users*423* with basic information on the Hungarian elections in the pre-election period on their website.

The roundtable provided an opportunity for national competent bodies to engage in dialogue and ask questions to VLOP and VLOSE providers in order to better understand their preparedness for elections and potential election-related threats online, including foreign information manipulation and interference, disinformation campaigns and the proliferation of deepfake content generated by artificial intelligence. The meeting also raised the issue of the responsibility of VLOP and VLOSE providers, including the need to prevent the misuse of their services to spread disinformation or manipulate voters, in connection with which they provided information on the practices they apply. The service providers present declared that they meet the requirements for algorithmic transparency. In response to a question from the NMHH, it was also confirmed that escalation channels are available for testing purposes and that there is no obstacle to sending test cases after prior consultation.

2.4. Discussions in the framework of the DSA Board

In the context of the Digital Services Coordinator tasks, the NMHH also participates in the activities of the DSA Board and its working groups. In preparation for the elections, the NMHH consulted with the European Commission and regularly informed the DSA Board and its Election Integrity Working Group on progress. At the NMHH’s initiative, the Czech DSC, the Czech Telecommunications Authority (Český telekomunikační úřad), reported on its experience of the Czech parliamentary elections in autumn 2025 in an online consultation.

3. User awareness and NMHH’s communication activities

3.1 Media literacy activities and communication campaigns of the NMHH

The NMHH strategy aims to promote the informed use of online platforms and to develop media literacy. The NMHH’s education programmes aim to reach all age groups of Internet users in Hungary, but it places particular emphasis on supporting young people and their parents*424*.

In this context, the NMHH uses its own tools, such as the The Magic Valley media literacy education centre to encourage and support the conscious use of media, to contribute to the development of citizens’ digital competences*425* and to the enhanced protection of their interests and rights, in order to enable more and more people to use the opportunities offered by online platforms, while also equipping them with the tools to protect themselves against their dangers.

The Authority’s aim is to significantly increase the proportion of informed users who are able to take responsibility, be informed and make their own decisions, so that they become informed consumers of online content and have a healthy doubt about it. The NMHH is also making a major effort to ensure that users with different digital competences can successfully deal with the challenges of the online space, such as the importance of authentic information, through cooperation with various organisations, the involvement of influencers, awareness-raising campaigns in schools, publications, conferences, interactive presentations and training.

The NMHH also launched in May 2023 the onlineplatforms.hu where it will publish short educational articles and studies to help users navigate the online world. In order to assess the social impact of digital services and online platforms, the Authority conducts research with representatives of various disciplines (e.g. psychology, sociology, law, economics), the results of which are also made available on onlineplatforms.hu. This has included research on the media literacy of young people*426*, the detection of fake news*427*, the functioning of algorithms*428*, the activities of influencers*429*, the relationship between democratic public opinion and online platforms*430*.

In addition to the above, Annex 1 to the report contains further links to content published by the NMHH in the above areas.

3.2 Content published about disinformation, deepfakes, and the impact of artificial intelligence

The legislation imposes obligations on social media service providers to prevent the spread of disinformation and control AI-generated content. The NMHH does not have the authority to identify disinformation spread on social media platforms, however, the activities to improve media literacy detailed in the above point also serve to combat disinformation, and the NMHH may also act in this area in the absence of authority to deal with disinformation. The NMHH considers it of utmost importance to develop media literacy in order to increase the recognition of manipulation and disinformation by users, and thus to increase society’s resilience against disinformation. As an organic part of the NMHH’s ongoing media literacy activities, in the months leading up to the parliamentary elections, the NMHH published a number of studies, podcasts and articles specifically on disinformation, deepfakes and the effects of artificial intelligence on its various social media platforms and channels, as well as on its websites:

• In the NMHH AI podcast series, AI experts shared their views on the role of AI tools in content production, its implications, opportunities and threats*431*.
• The NMHH’s podcasts on freedom of expression and freedom of the press addressed the issues of disinformation, fake news, deepfake, credibility*432*.
• On onlineplatformok.hu, an article supporting users in filtering out fake news and disinformation was published*433*. In addition, in order to make it as widely known as possible, the NMHH published the unofficial Hungarian translation of the revised code of conduct on countering illegal hate speech online, as well as the code of conduct on disinformation built into the DSA’s regulatory framework*434*.

Examples of content published on social media platforms and video-sharing platforms are given in Annex 1 to the report. Although some of these are not specifically related to elections and civic discourse, they can provide a very useful reference point for users of online platforms when dealing with political topics and issues.

3.3 Information about the protection of user accounts and content

The vast majority of the complaints received by the NMHH under Article 53 of the DSA were related to the restriction or termination by the platform of user accounts and channels registered on social media and video-sharing platforms. The NMHH has therefore published a series of articles on what users can do to avoid these measures on the most popular platforms*435*. Also in this context, in order to help users of online platforms (including candidates and nominating organisations) to enforce their rights, the NMHH has published short, easy-to-understand step-by-step descriptions of the process, explaining what tools are available to the user to challenge a decision by the platform to delete or restrict either the user’s account or the content published by the user.*436*

3.4 Guides to reporting illegal content

When using online platforms such as social media platforms, users may also encounter illegal content. Content moderation is the responsibility of online platform providers, but they must comply with the rules they themselves set out in their terms and conditions and the DSA provisions that apply to their procedures. It should be stressed that the DSA does not regulate online content itself, but merely expects service providers operating an online platform to operate an effective internal complaints handling system that allows users to lodge complaints if they consider that information available on the online platform is unlawful in a Member State or does not comply with the terms and conditions of the service provider itself. Also in the context of elections, it is important that if a user believes that he/she has detected content on a platform that is illegal or in breach of the platform’s rules of use, he/she can report it to the platform. To help users exercise their rights under the DSA, the NMHH has therefore published step-by-step instructions for users on the notification process.*437*

3.5 Information on access to research data

Article 40 of the DSA provides access to VLOPSEs’ data, including data on actual or foreseeable negative impacts on civic discourse and electoral processes, for researchers dealing with systemic risks and assessing the adequacy, effectiveness and impact of risk mitigation measures adopted by VLOPSEs. In order to inform those interested in accessing research data, the NMHH has published a description on its website*438* and on the onlineplatforms.hu website*439*, and has also indicated the contact point through which researchers can contact the NMHH. In the pre-election period, the Authority’s staff also had separate consultations with the researchers who contacted the NMHH on the issues related to data access requests.

3.6 Communications concerning the powers of the NMHH

In accordance with the statutory provisions, the official election campaign period started 50 days before the election date (12 April 2026), i.e. on 21 February 2026. At the beginning of the campaign period, the NMHH published a notice on its website*440* regarding media content published during the parliamentary election campaign period and content on online platforms. In its statement, the NMHH stated that social media platforms do not qualify as press products or media service providers under Hungarian law; and that the European Commission has exclusive competence for certain obligations of Very Large Online Platforms and Very Large Online Search Engines, such as the management of systemic risks. The President of the NMHH may only investigate compliance with the obligations under the DSA and alleged breaches of the EU Regulation in respect of service providers established in Hungary, and does not have a content moderation role in relation to decisions made by intermediary service providers regarding illegal content. The Communication also stated that the President of the NMHH is responsible for coordinating the sharing of information between Member States on the response to systemic risks related to the electoral process.

Before the start of the official campaign period, but already in connection with the elections, Fidesz in Budapest published an AI-generated video on its Facebook page*441*, showing a Hungarian girl waiting for her father to come home, while a Hungarian soldier, i.e. the father according to the video, is executed on the front. The message of the video is “It’s a nightmare for now, but Brussels is preparing to make it a reality. Fidesz is the safe choice.” The video caused significant public outcry, and the NMHH received several emails requesting that it investigate the matter and take the necessary measures to prevent similar content in the future (however, no complaints under Article 53 of the DSA were submitted to the President of the NMHH as the Digital Services Coordinator). The chairman of a Hungarian political party has written several open letters to the President of the NMHH on the matter, asking the authority to take action. In this context, the NMHH has published a notice on its website clarifying the President’s powers as DSC in relation to content available on online platforms established in other Member States*442*. The President of the NMHH considered it important to emphasise that the NMHH works within the framework of the legislation in force, and therefore, in fulfilling its statutory obligation, the NMHH must first and foremost examine whether it has jurisdiction in any given case. Consequently, it may only deal with matters within the framework of official proceedings in respect of which its competence can be established, and it may not formulate a public opinion on individual matters not otherwise within its competence outside official proceedings. However, the current legislation does not cover the direct supervision of content posted by users, neither the DSA nor national legislation gives the Digital Services Coordinator the competence regarding the assessment of content on online platforms, and there is no legal provision allowing the President of the NMHH to order the removal of content from an online platform. Under the DSA, platform providers are the primary decision-makers as to whether content posted by a user is illegal or in breach of the terms of use (guidelines) and whether or not it should be removed. Online platforms have an obligation to provide an appropriate reporting platform for users to report illegal or harmful content to the platform and to provide information on the decisions taken on the basis of such reports, in accordance with the statutory requirements. Furthermore, the Notice stated that the President of the NMHH, as the coordinator of digital services in Hungary, can only investigate compliance with obligations under the DSA, including Articles 16 and 17 of the DSA, and alleged violations of the DSA with respect to service providers established in Hungary, and has no content moderation role with respect to decisions by intermediary service providers regarding illegal content. Based on the inquiries received by the NMHH and publicly available information, a significant number of people have reported the video to Facebook, but the video is still available. The content in question was published on Facebook, the service concerned is operated by Meta, a service provider established in Ireland, against which the President of the NMHH cannot act under the DSA rules to monitor its activities.

4. Monitoring of activities and election-related risks during the campaign period

Based on the Elections Toolkit, Digital Services Coordinators will work to support collective preparedness to respond to incidents on online platforms, enabling an effective and coordinated response to potential incidents around elections with implications for their integrity or public security, by establishing incident management protocols and networks, involving stakeholders in key escalation channels.

4.1. The NMHH’s ability to receive and escalate incident reports

The NMHH is prepared to receive reports of potential incidents and to escalate substantiated reports of incidents:

• The NMHH can be contacted through a number of channels – electronically, by post or via the personal helpdesk – to make a complaint or request. The NMHH is prepared in advance to receive and handle any incident reports through all these channels.
• The NMHH has established escalation channels to the VLOPSE providers concerned (see 2.2 above) so that, in the event of a notification received by the NMHH concerning a VLOPSE provider’s platform, the NMHH can report the incident to the platform. The functioning of the available escalation channels (response time, possible unexpected technical obstacles) has been tested by the Authority in consultation with the relevant service providers and no disruptions were observed during the tests.
• In order to report any incidents to the NMHH that may have been detected by the Co-authorities concerned by the elections, the NMHH has provided the Co-authorities with a dedicated electronic contact address and additional contact details for urgent contact. In addition, the NMHH, through its information sharing and coordination tasks, has promoted the direct use of the escalation channels set up by the VLOPSEs for this purpose by the authorities involved in the electoral process, so that they can report any problematic content or incidents they have detected directly to the platforms. Based on feedback, several authorities have established direct escalation channels to VLOPSE service providers.
• The pre-defined protocol is an important element in ensuring that the NMHH is able to react as quickly as possible in the event of an incident being brought to its attention. In order to standardise the handling of notifications and possible escalation processes, detailed instructions have been prepared for the NMHH staff involved in investigating notifications and escalating incidents to platform providers.
• In order to ensure that any incident reports received through any channel were dealt with in a timely manner, the NMHH’s designated staff (customer service and Digital Services Coordinator) monitored the receipt of reports outside office hours. This standby period started two weeks before the election and lasted until the end of the week following the election day.

The President of the NMHH, as DSC, has not received any indication of an incident or systemic risk to the integrity of the elections. Furthermore, although candidates and candidate organisations have made significant use of social media platforms as part of their election campaign, and the 2026 parliamentary elections were accompanied by a particularly lively social interest and heightened public awareness, which led to an extraordinary level of activity on all election-related issues, including phenomena in the online space, among the various media, news portals and analytical organisations, and in the course of government communication,*443* the President of the NMHH, as Digital Services Coordinator, has not received any indication, either from users or from the co-authorities, that he should have initiated any action or investigation in his capacity as President, in his capacity as the legal authority.

4.2. NEC decisions on content published on social media platforms

The NEC, as a central body of the Hungarian electoral system, plays a key role in the electoral redress system. The Hungarian electoral institutional system allows for the submission of objections to the electoral committees and the NEC in case of a violation of the law. Objections may be lodged on the grounds of violation of the legislation governing the election or of the principles of the election and the electoral procedure. The NEC has not only second-instance but also first-instance powers to rule on infringements of the law: acting within its remit and powers, it decides in first instance on objections to certain types of cases concerning infringements of the law and rules on appeals against decisions taken in first instance by parliamentary single-member constituency and regional election committees.*444* The decisions of the NEC are publicly available.*445*

On the basis of the NEC President’s general report on the NEC’s activities in the general election of Members of Parliament held on 12 April 2026*446*, the NEC has taken a decision on a number of objections and appeals received concerning content published on social media platforms. The following decisions are highlighted:

• Cases where an incumbent mayor – but not a candidate in the parliamentary elections – has published a post or video on his or her social networking site in which he or she has openly or implicitly expressed a position for or against a candidate organisation.
• Cases related to the veracity of negative statements made by candidates, nominating organisations or others about nominating organisations (no final decisions on false allegations were taken in cases decided by the NEC in this electoral procedure).
• Posting misleading information on social networking sites about the time or method of voting.
• Examination of the requirement of balance in relation to social networking sites linked to the linear media service of a public service media provider (the Curia and the Constitutional Court have adopted different interpretations of the law in this area on several occasions*447*).

4.3. Content moderation by platforms

On the basis of the Code of Conduct to combat disinformation*448*, the operators signing the Code have established a “rapid response system” (hereinafter: RRS), which is the basic framework for their cooperation during elections ad crises, complementing the platforms’ incident management mechanisms. The RRS aims to identify and evaluate election-related content and incidents observed during election periods that may violate the rules of online content providers. It acts as a systematic communication and coordination channel for a given period, where participants (e.g. online platforms, fact-checkers, NGOs) send each other alerts about potentially harmful content, so that they can quickly report problematic content or coordinated manipulation campaigns to each other. The RRS cooperation does not perform content moderation per se, the actual actions are taken by each platform according to its own rules. The cooperation does not involve the European Commission or the individual national Digital Services Coordinators. For the Hungarian elections, the RRS was activated on 16 March 2026. The RRS participants do not share information about their work with the national Digital Services Coordinator, but they do produce a public report on their activities afterwards (reports covering the period including the Hungarian parliamentary elections are not yet available at the time of writing).*449*

Among the VLOPSEs, the monthly reports on covert influence operations available on the TikTok website*450* provide precise figures on how many accounts were affected and how many followers (the total number of accounts that followed an account within a given network when it was removed) were identified by the provider as targeting political discourse in Hungary on the platform.

According to the latest publicly available TikTok reports

• the TikTok discovered and removed between 1 and 31 March 2026
  • a network operating from Hungary and targeting a Hungarian audience, the individuals behind the network created fake accounts (with fictitious personalities, stock photos as profile pictures, or other non-original images) in order to artificially amplify narratives critical of the Tisza Party – the network consisted of 91 accounts and had 246 followers.
  • a network based in Hungary and targeting a Hungarian audience, the individuals behind the network created fake accounts (with artificial intelligence-generated profile pictures) to artificially amplify narratives critical of Fides – the network consisted of 62 accounts and had 1,452 followers.
• the TikTok discovered and removed between 1 and 28 February 2026
  • a network operating from Hungary and targeting a Hungarian audience, the individuals behind the network posted artificial intelligence-generated content to support their messages in order to artificially amplify narratives critical of the Tisza Party – the network consisted of 107 accounts and had 37,070 followers.
  • a network operating from Ukraine and targeting a European audience, the individuals behind which created fake accounts in order to discredit certain European political figures, such as Viktor Orbán, then Prime Minister of Hungary (the network created accounts that were disguised as news portals) – the network consisted of 45 accounts and had 47,114 followers.
• in the period between 1 and 31 December 2025, TikTok discovered and removed a network operating from Hungary and targeting a Hungarian audience, where the individuals behind the network created fake accounts in order to artificially amplify narratives favourable to the Fidesz political party (the network liked and shared its own content in order to artificially increase its reach) – the network consisted of 28 accounts and had 18,247 followers.
• in the period between 1 and 30 November 2025, TikTok discovered and removed a network operating from Hungary and targeting a Hungarian audience, where the individuals behind the network created fake accounts in order to spread narratives favourable to Fidesz (the network was coordinated across multiple online platforms) – the network consisted of 95 accounts and had 131,342 followers.

The websites of the other VLOPSEs involved in the 2026 Hungarian elections do not yet have a report for the election campaign period available at the time of writing.

5. Conclusions

5.1. Effective exercise of powers to review content published on online platforms

The NEC may, within the limits of its powers as referred to in this report, examine the conformity of content published on online platforms with the law in the event of complaints or requests for redress. In the NMHH’s view, the precise, clear and consistent indication of the competences of the authorities involved in the election may have also played a role in the fact that objections to the content displayed on social media platforms during the campaign period were submitted to the election committees and not to the NMHH, as an authority without supervisory competence with regard to user content published on online platforms. In the context of the National Election Commission’s decision on the merits in the proceedings on the basis of objections or requests for redress in relation to content displayed on online platforms, it may be justified to examine whether the NEC may, by its decision, order the online platform providing the platform for the display of the content found to be infringing to remove the content. The escalation channels established with the VLOPSE service providers can ensure that the service providers can be informed of these decisions within a short time and can take the necessary measures, with formal notification in accordance with the Hungarian legislation governing the NEC procedure.

5.2. Clarifying responsibilities for disinformation and ensuring the conditions for cooperation between the authorities concerned

More and more public discourse, political debates, campaign messages and voter mobilisation are taking place online. This change has created many opportunities but also new risks, and these risks are particularly acute during election periods. One of the main risks is the spread of disinformation and attempts at foreign interference in electoral processes using various techniques.

The focus has increasingly shifted to the online space, including platforms. Here, the speed of dissemination, the immediacy and, above all, the personalised content delivery are characteristics that were difficult to manage with the previous tools. Targeted outreach, rapid amplification, cross-border campaign effects and coordinated influence operations are all phenomena to which public institutions and service providers must be prepared to respond. Legislation imposes obligations on service providers, such as social media platform providers, to prevent the spread of disinformation and to deal with AI-generated content and deepfake videos. Other Member State authorities and the European Commission may also act to supervise the related obligations of the VLOPSEs under the DSA, in accordance with the rules of jurisdiction and competence of the DSA, even if the AI-generated content appears on various platforms in connection with the Hungarian electoral processes. It is also important to note that the NMHH does not have the authority to detect and identify ex officio disinformation or foreign interference in the online space (whether on the interfaces of service providers established in Hungary or in other Member States).

Taking action against disinformation or foreign interference to preserve the fairness and transparency of elections is a complex task. The coexistence of the national and EU regulatory frameworks and of offline and online campaigning techniques creates a situation where coordination between actors is of paramount importance and cannot be done effectively without clearly defined competences established by law. One of the guarantees for effective and lawful action by public authorities against any type of illegal content is that all authorities act with due regard for their legal powers and with full knowledge of them. It would be necessary to clarify and specify, possibly through legislation, which authority or authorities perform these tasks, and under what conditions and framework information can be shared between the authorities concerned in order to perform common tasks in the context of electoral procedures to combat disinformation and foreign influence. The need to do so is also supported by the preliminary findings and conclusions of the report of the International Election Observation Mission of the Office for Democratic Institutions and Human Rights of the Organization for Security and Cooperation in Europe.*451*

1. Examples of messages and content published on the NMHH’s social media platforms to raise awareness among users

1. a) Artificial intelligence and deepfake

   Should we be afraid of artificial intelligence?

   Pamkutya also points out that these days, it’s impossible to know for sure whether the people in videos are real or not.

2. b) Notices of illegal content to platforms

   You can make the online world safer.

   Reporting illegal or harmful content on online platforms

3. c) Video about user rights in the event of account restrictions

   Has your account been deleted or restricted on a social media platform?

4. Dezinformáció

   Fake news – Legal regulation of disinformation

   Disinformation, opinion, fake news: where is the line? – NMHH Podcast: Dr. János Tamás Papp, Dr. Bernát Török

   Platforms, algorithms, business interests – NMHH Podcast: Zsolt Ződi, János Tamás Papp

   Fake profiles, fake news, and comment trolls are vying for voters' attention on social media platforms

2. Contact details of the content published by the NMHH in connection with its cooperation with various organisations, influencers, school outreach campaigns, publications, conferences, interactive presentations:

categoryprotection of children and minors

Digital balance in childhood – new expert video series to launch

Bethesda Children’s Hospital and the National Media and Infocommunications Authority (NMHH) are launching an educational video series titled “Tips for a More Screen-Free Childhood” aimed at families.

20 March 2026

categoryNet-Coach

Contains a photo gallery, number of images

5

NET-COACH Association held its opening conference titled “Safety in the Digital World”

At the professional event, the speakers demonstrated how collaboration helps children, their parents, and educators develop digital media literacy.

16 March 2026

categorythoughtful use of media

Contains video

Digital balance starts in the family

This year’s Safer Internet Day encourages users in more than 160 countries to be aware and responsible online.

10 February 2026

categoryMobil a családom? – NMHH program

Contains video

Introducing the renewed “Do I have a mobile family?” lecture series

Until now, the program has primarily targeted parents and their children, but the NMHH and the Momentán Theater Company will soon be visiting public schools with a revamped series of events designed specifically to meet the needs of schools and students.

4 May 2026