Each year, the Hungarian National Tax and Customs Administration (NAV) publishes its audit plan, providing clear guidance on the areas on which the tax authority will place particular emphasis during the given year. The NAV Audit Plan 2026 is no exception: based on the document, taxpayers can again expect supportive procedures this year, while a number of targeted tax audits are also likely.
As in the previous year, data-driven risk analysis will continue to play a key role in NAV’s operations. At the same time, NAV is applying artificial intelligence-based analytical models with increasing efficiency, significantly accelerating the preparation of audits.
Supportive Procedures: Focus on Compliant but Error-Prone Taxpayers
NAV’s objective remains unchanged: in the first instance, it seeks to apply supportive procedures to taxpayers who are generally compliant but make mistakes in the course of taxation. The 2026 audit plan has been extended with several new areas, including:
- supportive procedures or audits concerning motor vehicle dealers unlawfully claiming transfer tax exemption;
- supportive procedures concerning manufacturers and importers of products subject to the public health product tax;
- supportive procedures concerning taxpayers claiming unpaid motor vehicle tax in their company car tax returns;
- supportive procedures concerning taxpayers required to file tourism development contribution returns but failing to do so despite control data indicating an obligation;
- supportive procedures concerning taxpayers failing to comply with their retail tax return filing obligations;
- supportive procedures concerning taxpayers unlawfully opting for the taxation method under the Simplified Public Contribution to Revenues Act (EKHO).
Accordingly, in these areas the tax authority is expected, in the first round, not to launch an immediate tax audit but rather to contact taxpayers regarding the proper fulfilment of their obligations.
Key NAV Tax Audit Focus Areas in 2026
NAV classifies taxpayer-specific audits into a separate category. This year, the following groups of taxpayers have been moved into the audit category and can therefore be expected to face increased scrutiny:
- delivery (courier) companies,
- online content providers,
- taxpayers engaged in film production, event organisation, advertising, marketing, media services
The following will also be of particular importance:
- the examination of the retail tax obligations of domestic and foreign e-commerce platforms;
- increased scrutiny, based on identified risks, of income obtained by online content providers through social media platforms, as well as intensified reviews of the online sphere and the entities operating within it.
High-Risk Business Sectors – An Expanding List
The range of activities classified by NAV as high risk has expanded further in 2026. Enhanced audits are expected, among others, in the following sectors:
- Enhanced audits are expected, among others, in the following sectors:
- (used) motor vehicle and motor vehicle parts trading, and vehicle repair activities,
- personal and property protection services,
- facility management and cleaning companies,
- temporary agency work / labour leasing,
- trade in IT products,
- textile wholesale and retail traders,
- sellers operating via platforms,
- fruit and vegetable wholesalers,
- purchasers and distributors of food industry and agricultural goods,
- construction industry and building materials trading activities,
- tourism, hospitality and accommodation services,
- taxi services,
- traders selling Far Eastern products,
- online content providers,
- taxpayers deriving income from controlled capital market transactions and cryptocurrencies,
- taxpayers operating in the beauty industry or providing fitness-related services, including personal training and massage services,
- taxpayers carrying out excise-duty-related activities.
Transfer Pricing Rules and Related-Party Transactions: An Unchanged NAV Focus
As in the previous year, within the audits of large taxpayers and those with the highest tax performance, the review of related-party companies and intra-group transactions will continue to receive particular emphasis. We note that our own practical experience also confirms that the tax authority has recently shown a marked preference for reviewing companies’ transfer pricing documentation and records.
It is important to note that significant amendments entered into force in the field of transfer pricing at year-end, which we discussed in a separate blog post.
Eliminating Fundamental Discrepancies
As we have already reported, thanks to its highly advanced IT systems, NAV is increasingly able to process the vast amount of taxpayer data available to it with ease. We will therefore provide a detailed overview in a separate blog post of the focus areas of audits based on online invoice data.
During NAV’s risk analysis procedures, the following may attract attention: companies operating for several years on shareholder loans, taxpayers continuously carrying forward deductible VAT generated in previous years, the submission of VAT returns with zero data content, newly established businesses that report a large number of invoices or invoices of significant value from the outset, as well as taxpayers showing discrepancies between their VAT returns, recapitulative statements and online invoice data. Taxpayers failing to file VAT returns or seeking to minimise their tax liabilities may also come under review.
Targeted Risk Analysis
The tax authority continues to closely monitor discrepancies between online cash register data and VAT returns. In addition, priority remains on tracking goods through the EKAER system, as well as on reviewing the master data, turnover data and statistical information submitted through the National Tourism Data Supply Centre (NTAK) by accommodation providers, catering establishments and tourism units.
We will discuss the focus areas of the NAV Audit Plan 2026 relating to online invoice data in a separate blog post.
Tax Incentives Claimed in Relation to Dual Vocational Training
As expected, a new element in NAV’s 2026 audit plan is the requirement for the tax authority to pay particular attention to the lawful application of the social contribution tax allowance related to dual vocational training. We have previously reported in detail on our audit experience in this area in an earlier blog post.
Customs and Excise Areas
Within its customs administration powers, NAV conducts inspections both before and after the release of goods. The primary purpose of these inspections is to preserve the integrity of international trade and to guarantee the security of the global supply chain.
Particular attention is paid to the enforcement of sanctions imposed in connection with the Russia–Ukraine war. In addition, NAV takes strict action against the illegal trade in narcotic drugs, weapons and dual-use goods.
NAV audits also focus on products infringing intellectual property rights and dangerous products, such as counterfeit car parts and toys, as well as on the implementation of new EU environmental regulations, including the Carbon Border Adjustment Mechanism (CBAM).
By examining the authenticity of customs values, NAV seeks to filter out undervalued goods in order to protect budget revenues, while also keeping the dynamically growing e-commerce flow and airport distribution centres under close supervision.
In addition to customs audits, the authority strictly reviews the registration tax and VAT payable on foreign vehicles, as well as eligibility for subsidies financed from the European Agricultural Guarantee Fund (EAGF), in order to prevent abuses.
Audits by NAV’s Law Enforcement Division
This year again, NAV continues to treat the prevention of metal theft and the elimination of illicit trade as priorities, implemented in close cooperation with the waste management authority. Previous experience has confirmed the deterrent effect of unexpected and regular joint actions carried out with partner authorities, and similar inspections can therefore be expected in the future as well.
Particular attention is being paid to uncovering the illegal trade in medicinal products, thereby protecting the lawful market and consumer health.
NAV is committed to protecting law-abiding transport operators and is therefore stepping up inspections to filter out businesses seeking to gain a competitive advantage through unlawful practices.
Home distillation also remains within the authority’s focus; experts strictly examine the lawful application of the reduced excise duty rate. As part of this, distilleries may expect unannounced excise inspections at any time during the year.
It is also important to note that, in order to curb the black-market fuel trade, NAV will carry out strict on-site inspections at petrol stations with the aim of preventing fuel from illegal sources from being placed on the market through filling stations.
