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ATAILA Newsroom · Budapest ·

2026-W39

Hungary's AI Act authority is now on the ministry's org chart.

On 21 September the Hivatalos Értesítő, the official gazette's supplement, published the organisational and operating rules of the Ministry of Science and Technology, signed by minister Tanács Zoltán and approved by the prime minister. Bitport's reading three days later was structural: four state secretariats, eight deputy state secretariats, and a coordination problem. We read the same hundred pages the way a company that deploys AI in Hungary would, looking for the answer to one question: who supervises me, and where do I write?

The article we are responding to

“A koordináció lesz a legnagyobb kihívás a TTM új struktúrájában”

bitport.hu, 24 September 2026

The department, the contact point and the sandbox

The document is instruction 2/2026. (IX. 21.) TTM on the organisational and operating rules of the Tudományos és Technológiai Minisztérium, published in Hivatalos Értesítő 2026/46 on Monday 21 September and in force from the following day. Bitport's summary of the shape is accurate: four state secretariats, eight deputy state secretariats, and a digitalisation state secretary whose secretariat is, in Bitport's words, the widest-ranging unit in the building, with the government's IT companies (IdomSoft, NISZ, Pro-M) under its direction through the Digital Hungary Agency.

Under that state secretary sits a deputy state secretary for artificial intelligence. Section 54 lists the five departments they direct: national data strategy, AI strategy, the AI market surveillance authority, AI regulation, and government records management. The one that matters to a company deploying AI is the third. Section 1.3.3.4 gives the MI Piacfelügyeleti Hatósági Főosztály five duties, three of which matter here. In plain language: it performs the market-surveillance tasks that fall to the ministry under Article 70 of the AI Act and the Hungarian AI law; it runs the Article 70 single point of contact; and it carries out the tasks set in law for operating the AI regulatory sandbox, with a duty to channel what the sandbox teaches into market surveillance and regulation.

The authority itself was not created by this rulebook. According to mihivatal.gov.hu it operates under Act LXXV of 2025 and Government Decree 344/2025 (X. 31.), as an organisational unit of the ministry rather than an independent authority. The rulebook places it on the org chart and fixes its duties.

The public face already exists. The Mesterséges Intelligencia Hivatal at mihivatal.gov.hu explains the transparency obligations that have applied since 2 August 2026, in Hungarian, for individuals and for companies, and carries a complaint page for anyone who believes a rule has been broken. The department's contact details, per the site: 1146 Budapest, Ajtósi Dürer sor 19–21., email mi_bejelentes@ttm.gov.hu. That page is the part of this story a deployer should read twice. It is the route by which a customer, an employee or a competitor can put your AI system in front of the authority.

5

departments directed by the deputy state secretary for AI (section 54): data strategy, AI strategy, AI market surveillance, AI regulation, government records

Art. 70

of the AI Act: the market-surveillance authority and the single point of contact, both assigned to the AI Market Surveillance Authority department (section 1.3.3.4)

2 August 2026

the date from which the transparency duties explained on mihivatal.gov.hu apply; the site's complaint route is live

point 56

of the digitalisation state secretary's duties (section 23): "the domestic data centres needed to train and operate artificial intelligence, and the development of sovereign computing infrastructure"

30 September

the deadline for the justice minister's report on SZTFH's future under government resolution 1277/2026, nine days after the rulebook appeared; nothing published as of 26 September

4 + 8

state secretariats and deputy state secretariats in the new ministry, per Bitport

The sentence about sovereign compute

Section 23 lists the digitalisation state secretary's duties in numbered points. Point 56 reads, in our translation: the state secretary provides for the strategic planning and development of the computing infrastructure needed to develop and apply artificial intelligence, "including high-performance computing capacity (HPC), the domestic data centres needed to train and operate artificial intelligence, and the development of sovereign computing infrastructure."

We sell in that category, and this is the first time we have seen the phrase written into a Hungarian state document as somebody's job. It is worth saying what the sentence is and what it is not. It is a remit. It is not a budget, a tender, a residency rule or a procurement preference, and the rulebook attaches none of those. It could as easily describe state-built capacity that competes with private operators, or a contract with a US vendor inside a state hall. The state's own identity platform, the Digital Citizenship Programme, runs on a US vendor's cloud stack inside the Government Data Centre, according to a NISZ announcement of 7 October 2025, republished by the eGov Hírlevél. That is a working definition of sovereign that we do not share, and the rulebook does not choose between the two.

Two cyber departments, and a date

Three departments report straight to the digitalisation state secretary rather than to any deputy (section 24): the Digitalizációs Nemzetközi Kapcsolatok Főosztály, which handles international relations, and two cyber departments. The Kiberbiztonsági Szabályozási és Audit Főosztály lists its functions by letter: regulation, requirements and methodology, scope and registry of the organisations concerned, supervision, audit supervision including the qualification and registry of auditors, certification, and, at letter g, enforcement: "compelling compliance and sanctioning." The Kibervédelmi Főosztály lists the operation of the national incident-handling (CSIRT) capability, threat analysis and early warning, vulnerability handling and crisis coordination.

Today those are the toolkits of two other bodies. SZTFH supervises and audits under the cybersecurity act that implements NIS2, and NBSZ NKI runs the national CSIRT. Government resolution 1277/2026 (VIII. 31.) ordered an examination of SZTFH with a report due on 30 September, which we wrote about on 1 September. The rulebook appeared nine days before that deadline with a department that describes SZTFH's job. Reading the one as the successor of the other is our inference, not anything the document says. The law still names SZTFH, and a law is what it would take to move the supervision. Bitport's own conclusion is the cautious one: the wider the remit, the harder the coordination.

What a deployer should do with this

Nothing is required of you that was not required before the rulebook appeared. Three things are worth filing.

You know where to write. Questions about your obligations under the AI Act go to a named department inside the ministry, the same one that runs the Article 70 contact point for the Commission and the other member states, and complaints about your system arrive at that department too. Know it before somebody else uses it.

The sandbox exists on paper. If you are building anything the AI Act would call high-risk, ask the ministry about the regulatory sandbox before you build it, not after. The rulebook obliges the department to carry out the sandbox tasks and to learn from them; it does not say the sandbox is open yet.

The auditor may change. The question will not. Whoever audits you in 2027, under NIS2 or under the AI Act, will ask where the AI workloads, the data and the logs physically run and who can reach them. That is the same question SZTFH asks today and the same question we build for.

Where we are weak: an organisational rulebook is an org chart. It grants no powers, sets no rules and moves no budget. The same ministry now promotes AI, is charged with building sovereign compute and supervises AI systems, and a vendor applauding that arrangement would look self-serving, so we note it and do not applaud it. And we do not know what "sovereign computing infrastructure" will mean when it reaches a tender. Nobody does yet.

Sources, and what is our inference

The story we are answering: A koordináció lesz a legnagyobb kihívás a TTM új struktúrájában, bitport.hu, 24 September 2026. Opened and read in full. Bitport describes the structure and the coordination risk; the department-level detail below is from the primary document, not from Bitport.

The primary document: 2/2026. (IX. 21.) TTM utasítás, in Hivatalos Értesítő 2026. évi 46. szám, 21 September 2026, downloaded as PDF and read as text on 26 September. Section 3 (1): in force the day after publication, except section 2, in force from 1 October 2026. Section 54 for the five departments; section 1.3.3.4 for the market-surveillance department's duties; section 23, point 56, for the sentence on sovereign computing infrastructure; section 24 for the three departments under the state secretary's direct control; sections 1.3.0.2 and 1.3.0.3 for the two cyber departments. Signed by Tanács Zoltán, approved by Magyar Péter. Our English renderings of Hungarian passages are translations, and the Hungarian article carries the originals.

The authority's public site: mihivatal.gov.hu, opened 26 September, for the 2 August 2026 transparency duties and the complaint route; its About page for the legal basis, the organisational status and the contact details, opened 27 September. Also read: ICT Global, 22 September, which summarised the rulebook two days before Bitport.

Government resolution 1277/2026 (VIII. 31.) and the 30 September deadline: as reported in our 1 September article; no report had been published on sztfh.hu, kormany.hu or in the gazette as of 26 September. The Digital Citizenship Programme's infrastructure: eGov Hírlevél, 19 October 2025, republishing a NISZ announcement of 7 October 2025 that names Oracle Dedicated Region Cloud@Customer inside the Government Data Centre; opened 26 September.

Our inference, and only ours: that the new cyber audit department is positioned to take over SZTFH's NIS2 supervision. The document does not say so, and no law has been amended.

Correction, 27 September 2026: after a post-publication fact check we made clear that the market-surveillance authority operated before the rulebook, which places it on the org chart; added the department's contact details; and corrected that three departments, not two, report directly to the digitalisation state secretary, and that the department channels sandbox lessons into market surveillance and regulation.

The original article

“A koordináció lesz a legnagyobb kihívás a TTM új struktúrájában”

bitport.hu, 24 September 2026