Read the draft tender documentation that MEKH — Hungary’s Energy and Public Utility Regulatory Authority, sometimes referred to under its English initialism, HEPURA — put out for consultation in late July, and then read the decree the government actually signed into law five weeks later, and you’ll notice the two don’t quite match. Not in the way that draft rules usually firm up around the edges before publication, either. Between July and August, Hungary’s flagship wind tender changed what it measures, how much room it gives bidders, and arguably what kind of project it’s designed to reward. That evolution — visible only by lining up the draft and final texts against the legal commentary published at each stage of the process — tells a more interesting story than either the announcement or the final rules do on their own.
A second attempt, not a first one
Start with something that got lost in nearly every account of this tender, including our own: this isn’t Hungary’s first swing at reviving wind. Legal commentary on the process confirms that, back in early 2024, the government already relaxed the regulatory barriers that had frozen the sector and allocated roughly 700 MW of grid connection capacity to new wind projects. That round went ahead — but, as one legal analysis of it put it, it “benefited only a geographically narrow set of developers,” and those projects are, as of this year, still stuck in permitting. Hungary’s installed wind fleet has sat at roughly 330 MW for more than fifteen years, and the 2024 attempt to change that hasn’t yet put a single new megawatt on the grid. Whatever else is true about the 2026 relaunch, it’s the second attempt at this, not the first, and the first one is still working its way through the permitting system somewhere in the background.
The real reset came in June 2026, when the government adopted wind energy as a formal strategic priority and laid out a framework of annual grid-connection tenders running through 2030, targeting a cumulative 4 GW of new wind capacity. The first round of that framework is the tender everyone’s now writing about — but even its headline number moved during the drafting process.
The megawatt figure that shrank
Legal commentary published in late July described the first call as “covering a minimum of 1,000 MW,” initially slated for publication by the end of August. Days later, a separate legal note framed it differently — a 700 MW baseline that the government was actively considering expanding towards 1,000 MW, citing investor interest running ahead of expectations. Either way, something north of 700 MW was clearly on the table over the summer. By the time MEKH actually published the tender at the end of August, the number on offer was 702 MVA of total capacity across nine grid nodes — essentially the original 700 MW figure, not the larger one being floated in July. Nothing in the public record explains why the more ambitious number didn’t survive into the final version. It could be grid limitations, a more cautious regulator, or simply a government deciding to test the model at a smaller scale before committing more capacity in next year’s round. But it’s a detail that disappeared from the coverage once the final tender landed, and it’s worth remembering the ambition was larger before it wasn’t.
Smaller projects got let in — but got a lot less time to apply, until they didn’t
Two of the more concrete changes between draft and final rules cut in opposite directions for developers. The minimum project size came down: the draft, per legal commentary published at the time, set the threshold at 15 MW installed capacity and 15 MVA feed-in capacity, while the final decree — per later legal commentary and the published tender terms — lowered that to 14 MW and 14 MVA. It’s a small change in absolute terms, but it does open the door to somewhat smaller projects than the government initially planned to allow.
The application window, meanwhile, ballooned. The draft rules gave bidders eighteen days — midnight on 1 September to 23:59 on 18 September — to file a complete application, with automatic disqualification for anything late. The published tender extended that to nearly two months, 4 September through 30 October, and pushed the results deadline from MEKH’s original 2 December target out to 13 December. An eighteen-day window for a tender this complex — one requiring site control, technical documentation, security deposits, and now an intricate scoring submission — always looked tight, and it’s a fair bet that industry pushback during the consultation period is exactly why it got tripled.
The security deposits, at least, held steady
One thing that didn’t move: the mechanics of the tender and performance security. Legal commentary on the draft specified a tender security of 0.5% of the project’s “benchmark investment value” — calculated as HUF 406 million per MW for wind capacity and HUF 200 million per MWh for co-located storage — payable as cash or a bank guarantee. Winners then have 30 days from their award decision to post a performance security of at least 2.5% of that same benchmark figure. Later legal commentary on the final decree confirms a bid bond and performance guarantee structured the same way, without restating the exact percentages, which suggests these figures carried through largely unchanged. If so, they’re worth having on hand: for a 50 MW wind farm, a 0.5% tender security works out to roughly HUF 1 billion (a little over €2.5 million) just to submit a bid, before a single turbine is ordered.
How much of the pie one company can take also got a rewrite
The draft rules limited concentration with a blunt instrument: one application per network node per corporate group. The final decree replaced that with something more granular — a cap of 100 MVA per grid node and 200 MVA nationwide, per corporate group, across the roughly 700 MVA on offer. That’s a real loosening in one sense (a large group can now spread bids across more of the tender than “one application per node” would allow) and a real tightening in another (it puts a hard nationwide ceiling on total exposure that the draft’s node-by-node rule didn’t). Either way, it’s a different anti-concentration philosophy than the one industry was consulted on in July.
The scoring criteria didn’t just change. They flipped.
This is the part of the story that isn’t stated outright anywhere, but that falls out plainly once you put the draft and final versions side by side — and it’s the most consequential change in the whole process.
The July draft scored applications on seven factors, and they were almost entirely about technical seriousness: how much capacity a bidder committed behind its connection point, whether it would accept a partial award, how far above the minimum its performance security ran, whether it beat the minimum grid-balancing requirements, land quality at the site, and — the largest single category — “project readiness,” an explicit list covering a feasibility study, a business plan, site control, a turbine layout plan, wind measurement campaigns, bat and bird monitoring, an environmental impact assessment, permits already in hand, and a grid connection plan. A seventh factor gave credit for long-term energy offtake arrangements with municipalities, but it was one item among seven, not the centrepiece.
None of that survived intact. Legal analysis of the final decree found an evaluation framework where local financial contributions — the one-off municipal payments and ongoing per-MWh payments — carry 35% of the total score, by far the single heaviest factor, with a further 15% for equipment manufactured in the EU. And explicitly, credits for feasibility studies, wind measurement campaigns, and wildlife monitoring — the backbone of the draft’s “project readiness” category — were removed. In five weeks, Hungary’s wind tender went from primarily rewarding developers who’d done their technical homework to primarily rewarding developers who pay their host communities the most and buy European-made turbines. The municipal-benefit idea that appeared as a minor factor in July became, by August, not just the dominant scoring criterion but a mandatory cost of entry — layered with a separate, non-negotiable requirement that winners grant government-designated “renewable energy communities” a call option on up to 25% of the project company.
Whether that pivot reflects a political calculation about local acceptance, industrial policy priorities, or simply what came out of the consultation process isn’t something the public record explains. But it’s a genuinely different tender than the one industry was asked to comment on over the summer, and it’s not obvious the market has fully absorbed that yet.
What developers are actually saying about the version that shipped
The bidders and analysts we spoke to directly are reacting to the final rules, not the draft, and they’re not happy. One prospective bidder called the combined weight of municipal fees, taxes, security deposits, and the community purchase option “irrationally high,” telling us bluntly that “the math doesn’t work.” Analyst József Balogh zeroed in on the upfront municipal payment specifically, arguing it “lacks necessity” within the tender structure because it front-loads a large cash outlay onto developers before a project earns a euro of revenue — a criticism that lands harder once you know that fee wasn’t even a headline scoring factor two months earlier. A separate bidder criticised the site list itself, arguing the nine connection points were chosen for available grid capacity rather than wind resource quality, and flagged the Ócsa node — a 255 MVA slot in a densely populated area near a protected nature zone — as close to unworkable.
Not every legal read is this dark. Torsten Braner, Managing Partner at Taylor Wessing Hungary, has publicly advised that, with applications scheduled through September and October 2026, “market participants considering investments in Hungary may wish to start preparing their projects now.” Dr. Tamás Szkiba, Partner at Fehérváry Horányi Kovács Baker & McKenzie, went further, calling the relaunch “a decisive policy reversal” after years of neglect. Vajk Várai-Jeges, Associate at NZP Nagy Legal, struck a middle note, describing the relaunch as “more than an energy-policy adjustment; it is a strategic rebalancing of the renewable mix” that could become “one of the most important investment stories in the Hungarian energy market over the coming years” — provided developers bring “not only technical and financial preparation, but also a clear legal strategy.” Given how much moved between draft and final rules on this one, that last qualifier is doing a lot of work.
MEKH itself has been characteristically measured in public. Its president, Edit Juhász, has stated that the tender “was preceded by an extensive market survey, a detailed grid analysis, and industry consultation” — the kind of line a regulator gives when it wants you to know the homework got done, even as bidders on the ground remain unconvinced.
What still isn’t settled
Even the final decree leaves real questions open. Separate legal commentary on the final decree flags unresolved friction points: how the accelerated 30-day environmental and 20-day building permit tracks interact with existing easement zones, whether the newly permitted 199-metre turbine height clears military radar restrictions in practice, and how individual municipalities will interpret nature and landscape protections that vary site to site. Layer onto that the deadline maths nobody’s fully reconciled: winning projects need final, binding building permits by 1 January 2030, years before their grid connection windows even open between September 2030 and September 2032 — and, if the draft’s post-award rules carried through unchanged, a separate 24-month clock to commission the project and begin using the connection once it’s live, with milestone failures triggering forfeiture of the performance security.
Hungary has now written, rewritten, and published a genuinely ambitious wind policy — 4 GW by 2030, on a grid that has added no new wind capacity in over a decade, with a first round that already looks different from the one it announced eight weeks earlier. Whether that flexibility is a sign the government is genuinely listening to the market, or a sign the rules aren’t done moving yet, is the question this tender leaves for its own results, due 13 December, to start answering.
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