State Public Procurement Advisor (ÁKSZ) and FAKSZ: status and outlook in 2027

Kbt. s. 27

Who must involve an ÁKSZ?

From 1 January 2027, ministries, designated central purchasing bodies, the state and budgetary bodies must involve an ÁKSZ if a procurement of supplies or services reaches the EU threshold, a works project reaches HUF 700 million, or the procedure is funded from EU sources. One condition is enough. The obligation does not apply to local governments, local-government institutions or state-owned companies.

The obligation arises only when two conditions are met together: the contracting authority is on the list, and the procedure falls under one of the four cases.

Which contracting authorities must involve an ÁKSZ?

In which procedures is an ÁKSZ mandatory?

When is no ÁKSZ needed?

• No ÁKSZ is needed for a direct order under a framework agreement.
• Nor is one needed for an EU-funded procurement under a framework agreement that does not reach the value under (a) or (b).
• If the procurement does not even reach the national threshold, no procurement procedure is needed, and so no ÁKSZ either.
• If a central purchasing body runs the procedure on behalf of the obliged contracting authority, it also supplies the ÁKSZ.

What became of the FAKSZ?

The FAKSZ, or Responsible Accredited Public Procurement Advisor, was a professional listed in the Public Procurement Authority's register whose involvement was mandatory in many procedures. Since 8 November 2023 no new FAKSZ can be registered, and the transitional rules expire on 31 December 2026. The ÁKSZ has taken over the mandatory role, but only an employee of a ministry, a central purchasing body or a budgetary body can be an ÁKSZ.

How can a contracting authority get an ÁKSZ?

There are three routes: as the authority's own employee, by engaging another contracting authority's ÁKSZ under a mandate, or by having a central purchasing body run the procedure and supply the ÁKSZ. It takes years of practice for a new staff member to become an ÁKSZ, so for bodies that rarely procure, a mandate or a central purchasing body is the more realistic route.

1. Own employee as the ÁKSZ

In the past three years the staff member must have conducted at least ten procedures from start to finish and taken part in five more (see the conditions below). This is realistic for bodies that procure often, or if the organisation hires someone already registered as an ÁKSZ. According to a survey presented in September 2025, more than 62 per cent of contracting authorities have no in-house procurement specialist.

Gov. Decree 478/2023

2. Another contracting authority's ÁKSZ, under a mandate

With their employer's permission, an ÁKSZ may conclude a mandate contract with another contracting authority. The conditions:

• The ÁKSZ concludes the contract in their own name, as a private individual or a sole trader. A company cannot be the mandated party.
• Professional liability insurance is required, covering at least HUF 50 million a year and HUF 25 million per claim. It must also cover a fine imposed by the KDB or a court, and any EU funding lost, where the advisor's infringement caused it. The insurance must be evidenced by the time the contract takes effect.
• The mandate is itself a procurement of services. According to the Public Procurement Authority, the value of such mandates must be aggregated, and splitting them into parts is unlawful.
• The Authority considers it problematic for an ÁKSZ working under a mandate to sit on the evaluation committee, because they would be advising an internal body as an outsider.

3. The central purchasing body's ÁKSZ

If the central purchasing body runs the procedure on behalf of the obliged contracting authority as an ancillary procurement service, it also supplies the ÁKSZ.

Gov. Decree 478/2023 s. 18

What is the ÁKSZ responsible for, and what stays with the team?

The ÁKSZ is responsible only for procurement-law expertise, not for the technical, market or financial content, nor for legal content outside procurement. In the EKR, the ÁKSZ approves the notice and the procurement documents, the tender opening minutes, the evaluation committee's minutes and the summary of tender evaluation. Their name and registration number also appear in the notice.

Among the procurement documents, the ÁKSZ does not approve the technical specifications, the design documentation or the unpriced bill of quantities. The documents must also state their name, postal address, email address and registration number. An employed ÁKSZ is liable under employment law, a mandated ÁKSZ under the Civil Code (Ptk.).

What stays with the contracting authority's team

• assessing the procurement need and researching the market
• setting the estimated value and aggregating values
• the technical specifications and the unpriced bill of quantities
• convening the evaluation committee and organising its work
• administering the procedure in the EKR and keeping to the deadlines
• monitoring contract performance and handling contract modifications

Together, the people involved in the procedure must have the professional, procurement, legal and financial expertise that the subject of the procurement calls for. The ÁKSZ covers only the procurement part.

What does this mean for your organisation?

It brings new tasks for ministries, central purchasing bodies and central budgetary bodies: where a FAKSZ used to be enough, from 2027 only an ÁKSZ can act. Local governments, state-owned companies and foundation universities do not need an ÁKSZ. For tenderers, the range of possible representatives in review proceedings narrows.

Ministries, hospitals, school districts, government offices

It is worth planning for the ÁKSZ at the preparation stage. Based on the Authority's position of June 2026, the absence of an ÁKSZ is not a ground for declaring a procedure unsuccessful, and if the contracting authority has not provided for one, this may breach its duty to prepare the procedure.

For supply and service procurements still running on 1 January 2027, it follows from the same position that an ÁKSZ must be involved in place of the FAKSZ, even mid-procedure. If the ÁKSZ's name was not in the notice, their involvement must be recorded in the evaluation documents and their name stated in the contract award notice. The Authority wrote this for the 30 June 2026 deadline. As of 11 November 2026 we have found no new position for the 2027 changeover, so this is our own conclusion.

Local governments and local-government institutions

There is no ÁKSZ obligation, not even for EU-funded projects. The procurement expertise can be provided by a former FAKSZ, an attorney with procurement experience or another professional with adequate knowledge. We cover the rules for local-government procurement in a separate article. We run the entire procedure for local governments, as described on our page on public procurement consulting for contracting authorities.

State-owned companies, foundation universities, subsidised organisations

There is no ÁKSZ obligation. The FAKSZ working there lose the title on 31 December 2026, but they can carry on with their work, because the title is not a requirement in these procedures. We write about grant-funded procurement on our page on procurement for grant-funded projects.

Tenderers: narrower representation before the KDB

Nothing changes in the procedure itself. For a request for review, the range of possible representatives narrows, as we explain in the next section.

Kbt. s. 145(7)

Who can represent parties before the Public Procurement Arbitration Board?

Representation before the KDB is mandatory, and from 1 January 2027 only an attorney, a chamber-registered legal counsel or an ÁKSZ can provide it. A FAKSZ can act as a representative only temporarily, until 31 December 2026. An ÁKSZ is an employee of a ministry, a central purchasing body or a budgetary body, so in our reading a tenderer filing a request for review will in practice need an attorney or a chamber-registered legal counsel.

According to the Integrity Authority's 2025 report, mandatory representation and the narrow range of representatives hinder tenderers' access to remedies, and phasing out the FAKSZ may narrow that range further. In September 2026 the government did not support opening up representation, and it listed the FAKSZ among the existing representatives, even though the FAKSZ's right of representation ends on 31 December 2026. Whether a legislative amendment will follow is not yet known.

We help with the professional preparation of the request for review, and the authorised representative files it. Details are on our page on procurement legal remedies and dispute resolution.

Gov. Decree 478/2023

How does someone become an ÁKSZ?

To become an ÁKSZ, a person must work for a ministry, a designated central purchasing body or a budgetary body, hold a higher education degree, have taken part in enough procurement procedures in the past three years, have collected 15 training points and have paid the HUF 60,000 fee. A register entry is valid for two years and must then be renewed.

Conditions for entry in the ÁKSZ register

• an employment contract or another form of employment with a ministry, a designated central purchasing body or a budgetary body, certified by the employer
• a higher education degree and a clean criminal record
• no grounds for exclusion, and the applicant is not barred from practising as an attorney or chamber-registered legal counsel
• registration in the EKR (our EKR guide helps with this)

Persons with limited legal capacity, the public procurement commissioner and the President of the Public Procurement Authority cannot be an ÁKSZ.

Required experience from the past three years

• at least ten procedures conducted from start to finish and five more in which the applicant performed procurement or audit tasks, or at least 50 procedures with such a reference
• procurements under a framework agreement or a dynamic purchasing system do not count as procedures conducted
• a procedure that is not visible in the EKR does not count, nor does one in which the KDB or a court found an infringement, unless the applicant declares that they did not cause it
• certain management, law-making, procurement commissioner and audit posts can replace the references

Training points and their cost

Registration requires 15 points, which can be used for two years. A postgraduate specialist programme in public procurement completed within the past six years counts once for 15 points. Point-earning training may be provided only by the minister responsible for public procurement, the Public Procurement Authority, the operator of the EKR and higher education institutions. The minister recognises each course and sets its point value. In September 2025 there were 21 recognised courses.

In November 2026 the list price of one commercial online course was HUF 36,900 for 3 points. On that basis, 15 points cost roughly HUF 185,000 every two years. The Authority's conferences are free, but only in-person attendance earns points.

Registration fee, procedure and renewal

• Registration costs HUF 60,000 and renewal HUF 40,000. The fee is not refunded if the application is rejected.
• The Authority decides within 20 days. Applications can only be filed electronically, not in person at a government one-stop office (kormányablak).
• Renewal requires ten procedures conducted or 20 references from the past three years. The application can be filed no earlier than 90 days before the entry expires.
• If the employment relationship ends, the ÁKSZ must report it within 21 days and prove a new eligible employer within 120 days, or the Authority removes them from the register.
• A former FAKSZ can use the training points of the past two years and the experience of the past three years.

Promises, extensions, closed entry

A successor to the FAKSZ has been promised several times, but as of 11 November 2026 none has materialised. In June 2026 the transition was extended once more, to 31 December 2026, and no new FAKSZ has been registered since November 2023. The explanatory memorandum to Act XX of 2026 justified the extension on the grounds that no new professional or institutional model was yet available that could properly maintain procurement expertise once the FAKSZ ends.

This is not the first time the FAKSZ deadline has been pushed back. In 2020 FAKSZ registrations were extended by eight months because of the pandemic, in 2023 the Ábtv. granted a transition period until 30 June 2026, and in 2026 a further six months followed.

Why can't the circle of procurement advisors grow?

• Since 8 November 2023 no new FAKSZ can be registered.
• Only an employee of a ministry, a central purchasing body or a budgetary body can be an ÁKSZ.
• Point-earning training can be provided only by state bodies and higher education institutions.

The Integrity Authority recommends that experience gained on the tenderer side and in auditing should also count. It considers it problematic that the circle of FAKSZ has been closed since 2023, and that during the transition existing FAKSZ did not have to renew their registration or attend training. According to its report, there are also cases where someone joins the ÁKSZ register through a job of a few hours a week and then takes on work on the market with the title. The report gives no figures on this.

What to expect

No proposal has been tabled for either a successor model or a further extension. The coming months may decide whether a new expert model arrives, whether the ÁKSZ is phased out as well, what the new concept for the Ábtv. will contain, and whether the Authority issues guidance for procedures running on 1 January 2027.

Last checked: 11 November 2026

• Successor model. According to the explanatory memorandum to the extending act, the extension gives time to prepare a new regulatory model. No bill has been tabled so far.
• Phasing out the FAKSZ and the ÁKSZ together. The Integrity Authority proposed it, and in September 2026 the government partly agreed. If it happens, the ÁKSZ title may also cease to exist.
• Rewriting the Ábtv. The Ministry of Transport and Investment has started professional consultations on a new concept for the Ábtv. The ÁKSZ was created by this act.
• Section 24 of Government Decree 478/2023 still gives 30 June 2026, the Kbt. 31 December 2026. The EKR applies the date in the Kbt.
• Authority guidance for procedures running on 1 January 2027. The Public Procurement Authority's conference on 19 November 2026 and the next issues of Közbeszerzési Értesítő Plusz may provide answers.
• Professionalisation strategy. A government resolution of March 2025 set a deadline of 30 November 2025. We have found no published strategy.

If any of these happens, we will update the page and the change log.