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Abstract

In relation to public authorities exercising governmental power, it is a fundamental interest and “right” of clients that their human dignity is respected and that they are treated equally, along with the enforcement of related procedural principles, in summary the practical enforcement of the right to good administration. In addition, clients expect the enforcement and assurance of many other rights from the authorities conducting the procedures, which lead to decisions and actions by the authorities that they find acceptable. Such rights and principles include the fulfillment of the obligation to provide information, the brevity of the procedural time and the assurance of professional conduct during the procedure.

1. Introduction

1.1. Beginning of the electronic taxation

“It is important to emphasize, however, that a key task is to ensure the conditions necessary for the voluntary fulfillment of tax obligations. […] A notable e-Government measure in 2005 was the establishment and commissioning of the Client’s Gateway (Here in after: »Client’s Gate«), an online one-stop-shop for administration. From the perspective of tax administration, this period also saw the introduction of the General Form Filling Application (Here in after: »ÁNYK«) around 2006 (»ABEV 2006«),[1] which laid the foundations for electronic tax administration. However, this framework program is being phased out at the end of 2026 after more than two decades of operation. By 2006, the foundational phase of e-administration was completed in Hungary, including the development of the basic infrastructure necessary for its establishment and operation.”[2]

The procedural basis for electronic administration was established by the Act CXL of 2004 on the General Rules of Administrative Proceedings and Services (Here in after: Ket.).[3] A notable legislative attitude from the latter half of the 2000s was that data available in official registers do not need to be verified by the client, as the authorities conducting certain administrative procedures can obtain them from the primary registers.[4] From the mid-2010s, with the spreading of increasingly diverse electronic services and administration options, the state tax and customs authority also accelerated its own electronic development.

From the mid-2010s, the state tax and customs authority has taken on an increasingly significant role within public administration by developing electronic administrative processes[5] and making them accessible to taxpayers. To mention a few examples:

  • In 2015, the state tax and customs authority introduced the eKÁER system, which has significantly contributed to tracking fraudulent B2B transactions that cause VAT shortfalls and to sanctioning the taxpayers involved in VAT fraud. The approximately 30% VAT gap was reduced to less than a quarter within about two years thanks to the eKÁER system.[6]
  • From 2017 onwards, taxpayers have had the opportunity to file their personal income tax returns via the electronic Personal Income Tax (Here in after: ePIT) portal, based on the tax authority’s pre-filled draft return. This year (24SZJA), the Hungarian National Tax and Customs Administration (Here in after: NTCA) prepared more than 5.6 million people returns-draft on the ePIT portal, and over 2 million taxpayers submitted their returns through the ePIT portal[7] (which includes three categories: those who accepted the draft return, those who modified/complemented it, and those who submitted empty returns).[8]
  • Among these developments, the introduction of Online Form-Completion Application (Here in after: ONYA) on January 9, 2019 – which I will discuss in more detail later – and the launch of the eÁFA web and eÁFA M2M systems on January 1 of 2024 are particularly noteworthy. The eÁFA system provides a 24/7 web-based service for fulfilling VAT return obligations without installation, while eÁFA M2M offers the same service for taxpayers through machine-to-machine communication, in accordance with Section 184 of the VAT Act.[9]

In the context of the examined topic, I formulated the following research questions:

  • How are procedural rights enforced from the taxpayers’ perspective during electronic tax administration procedures?
  • What are the motivations behind the development of electronic tax administration services and processes, and what impact do they have on taxpayers, i.e., what benefits can the NTCA achieve through full digitalization?

1.2. Basic Principles and Perspectives of Examination Regarding the Right to Good Administration

In Hungarian administrative procedures – since the entry into force of the previously Ket. – the general hierarchical relationship between the client and the authority has increasingly been complemented by a more equal (coordinated) relationship[10] in certain procedures, case types, and procedural methods, as well as by a service-oriented approach and support from the acting authority. This gradual transformation was further reinforced by in the legislation in 2015-year, in the Act CCXXII of 2015 on the General Rules for Trust Services and Electronic Transactions (Here in after: Eüsztv.). Furthermore, the renewed “spirit” regarding the position of clients/taxpayers in the Ket. was continued by a form of decentralized legislative process in procedural law through the Act CL of 2016 on General Public Administration Procedures, as well as the “spirit” of the Act CL of 2017 on the Rules of Taxation (Here in after: Art.) and the Act CLI of 2017 on Tax Administration and the Regulation of Tax Administration (Here in after: Air.) in the case of tax administration procedures.

Regarding the topic, I intend to examine how procedural rights are enforced from the taxpayers’ perspective in electronic tax administration procedures. Primarily, I aim to discuss the enforcement of taxpayers’ procedural rights/obligations ensured during tax administration procedures and their fulfillment in the case of electronic services.

2. The Status of Taxpayers’ Rights During Electronic Tax Administration Procedures (Fulfillment of Tax Obligations)

In recent times, the NTCA has been offering an increasing number of services to taxpayers that assist in fulfilling various tax obligations and, where applicable, in ensuring the enforcement of taxpayers’ rights.

A particularly important example in this regard is the state tax and customs authority’s information portal,[11] the NTCA Client Portal, which generally provides tax-related information to taxpayers. If taxpayers wish to receive online information or verify data concerning their specific taxable activities, for instance,

  • what information the NTCA currently holds about them in its registers, or
  • which monthly tax and contribution returns they have submitted regarding their insurance relationships, etc.

They can access these data and the electronic services provided by NTCA by using the Central Identification Agent (Here in after: KAÜ) identification service – provided they have a pre-registered KAÜ identifier. After successful identification, taxpayers can access the data NTCA holds about them and the electronic services available.

The protection of personal data and the lawfulness of access to taxpayer data in the registry are of paramount importance during KAÜ identification.[12] In the Eüsztv., it meant four methods between term of 2015-2025, this were username-password identification, electronic Personal ID Card, video identification and RKTA. Upon successful identification, NTCA grants access to the taxpayer’s data stored in the registry based on the “legal presumption” that the person performing the identification is either the taxpayer themselves or a legally authorized representative reported to the tax authority. This issue also raises the right to freely choose a representative, meaning the taxpayer can select a competent person as their representative who handles sensitive tax data with proper expertise during electronic tax administration procedures/services.

It is important to emphasize that any security measure taken by the tax authority – regardless of its strictness or level – is considered “unnecessary” if the taxpayer does not adequately safeguard their own authentication tools or methods (such as usernames and passwords) that grant access to their data. I will elaborate on this problem in more detail in the chapter on practical enforcement of rights. At a certain stage in the continuous development of electronic administration, public administration may reach a level where the protection and use of authentication methods/devices for taxpayers will be of utmost importance for the enforcement of the right to good administration and in electronic official procedures. This is because the comprehensive electronic access provided through KAÜ will allow a complete overview of the taxpayer’s entire “lifecycle”, including the ability to fully manage tax accounts and any taxpayer surpluses. This electronic identification development path may seemed somewhat “intimidating” to everyday taxpayers and led to rise a new type of fraud enabled by IT systems.

However, alongside the taxpayers’ responsibility, lawmakers – primarily not only at the Hungarian but also at the EU level – bear significant responsibility to upgrade currently simple authentication procedures/methods and develop electronic identification systems that provide adequate protection of taxpayers’ tax secrets and personal data even in the case of cross-border fraud. This need has already emerged in the financial sector during online banking and online purchase authentication. Banks and related IT companies strive to protect customers using methods such as one-time passwords, two-factor authentication applications/SMS, etc., ensuring protection at the highest possible level. In my view, this demand from the private sector will gradually become a serious and unavoidable requirement in the public sector as well, especially in tax administration procedures, taking into account the objectives set out in Article XXVI of the Fundamental Law.

This explains the phase-out of the „simple” Client’s Gate identification service on January 16, 2025, and the mandatory introduction of Client’s Gate+ and Digital Citizenship identification (Here in after: DÁP). It is important to highlight that even for electronic identification services, the users’ right to choose must be ensured. Identification methods that require mandatory two-step or device-based authentication, as imposed by lawmakers, meet the requirements of protecting personal data under our legal system and EU law.

However, this protection must not come with the technical requirement that mandates using only a state-preferred software (in this case, the DÁP mobile application). Here, it is necessary to briefly address the legal enforcement and realization issues arising from the choice and use of electronic identification methods. The Client’s Gate+ service is particularly significant as it effectively implements the requirement for two-step authentication but can operate with any authentication software developed by third parties. This service ensures the customer’s freedom of choice since it allows registration and association of any third party-developed authentication application that meets the basic service requirements and has been pre-approved by the provider. In contrast, the technical requirements and design of the DÁP identification method may raise concerns about limiting the principle of interoperability. In this identification mode, the state essentially creates a monopoly position with its preferred authentication software and excludes the possibility of using authentication software developed by third parties. This legal framework, which creates a technical monopoly and reflects legislative intent, may lead to decreased user experience, excessive technical control, and a violation of the technology neutrality principle applied by eIDAS, especially if this remains the sole identification method over time. It is important to highlight that lawmakers do not create free interoperability between identification services; they unilaterally allow the transformation of Client’s Gate+ into DÁP identification but do not permit the reverse.

Beyond successful client identification – and the potential risks involved – the NTCA provides separate electronic services (portals) for fulfilling various obligations, such as reporting and change notification, tax return filing, or tax payment. These services aim to replace procedures requiring personal presence or paper-based administration and extend the possibilities of administration while ensuring taxpayers’ rights are not violated during service use.

In certain procedures, such as through ONYA or the ePIT portal, NTCA provides additional services to promote the enforcement of taxpayers’ rights during the fulfillment of tax obligations (Air. 6 §) or for taxpayer information purposes. Furthermore, the spread and gradual expansion of electronic tax administration services – for example, enabling employers to electronically report insured relationships or household employment – contribute to the enforcement of the principles of professional and efficient administration (Air. 2 §) as well as fair procedure.

It is important to emphasize that regardless of whether NTCA offers online options for fulfilling tax obligations or enforcing taxpayer rights, technical and IT solutions must also ensure the right to good administration. In fact, it can even be considered a goal that electronic procedures uphold this principle at a higher level than if taxpayers were to act in person at NTCA customer service offices.

3. Presentation of the achievements of electronic tax administration from the perspective of taxpayer legal enforcement

As previously highlighted in the theoretical legal foundations, the legal protection model aligns with the characteristics and peculiarities of electronic tax administration procedures. The steps of the basic procedure and related processes differ depending on whether the taxpayer initiates the procedure or it starts with a specific official action. In the practical examples presented, I primarily focus on taxpayer tools applicable in the basic procedure and related technical innovations.

The ONYA – as mentioned earlier – has been part of the NTCA’s electronic service portfolio since January 9, 2019. The essence of ONYA is that taxpayers can fulfill their tax obligations – such as notification, change notification, declaration, and tax payment obligations – in a simple and comprehensible manner. Using the service does not require specialized knowledge; only four simple conditions must be met to use it:

  1. The user must have an internet connection,
  2. The user must have a smart device with at least a 5-inch screen,
  3. The user must have KAÜ registration, and
  4. The user must have a Hungarian tax identification number, which the NTCA can identify electronically during KAÜ login based on its records.

It is important to highlight that starting from 2024, the last two conditions will no longer be required for using ONYA, since the NTCA has published an identification-free, so-called ONYA public interface similar to the offline ÁNYK form filler. The purpose of this interface is not to exclude those private individuals and organizations (other taxpayers, foreign organizations with Hungarian tax numbers, other taxpayers, etc.) who are not obliged to maintain electronic contact [according to Air. 36. § (4)–(6)] from the digital transformation of the NTCA.

ONYA appeared as an alternative to the ÁNYK framework program, aiming to fix the ÁNYK framework program’s shortcomings, such as:

  • Difficult installation,
  • JAVA helper program and Windows incompatibility issues,
  • Lack of direct connection to the official specialist systems,
  • No automatic template version or patch installation, etc.

The goal of ONYA is to establish a web-based framework program, essentially a portal system, to facilitate fulfilling tax obligations, which reduces the administrative burdens on taxpayers caused by the difficulties of installing and updating the ÁNYK framework program.

Using ONYA does not require installing any separate programs or administrative assistance and is accessible worldwide, anytime, 24/7. In the following, I intend to present the possibilities of taxpayer legal enforcement and legal exercise during the use and operational steps of ONYA, which guarantee the enforcement of taxpayer rights and facilitate fulfilling obligations in electronic administration.

4. Electronic identification as a guarantee for procedures initiated upon request

It is important to emphasize the significant role of electronic identification within the NTCA’s electronic portals and services. As highlighted earlier and mentioned among the initial hypotheses of my research, it is crucial that the tax authority can identify the user (taxpayer) wishing to use its electronic services during electronic tax administration procedures.

It should be noted that until January 16, 2025, the so-called “simple” Client’s Gate login maintained temporarily under the Eüsztv. and later Dáptv. represented a data protection risk for all taxpayers and the tax authority alike. Due to the flexible regulatory framework, some taxpayers abused the “username and password”-based identification method, especially when acting as permanent representatives of the taxpayer. By using the credentials provided by their clients, they logged into, for example, the NTCA ONYA, NTCA ePIT, or NTCA Online Invoice portals “on behalf” of the taxpayer and „instead” of the taxpayer. In this case, the tax authority only perceived that the taxpayer had successfully completed the KAÜ identification process using one of the provided methods, followed by identity verification in its records, and then electronically initiated the transaction. From the tax authority’s perspective, this identification method was highly risky regarding data protection and unlawful handling/disclosure of tax secrets, as it appeared that the taxpayer was acting personally during electronic administration, and any error or omission was attributed to the taxpayer’s electronic “activity” If the taxpayer made a mistake, the tax authority would not accept the argument that the error was made by the permanent representative since the system data clearly showed that the taxpayer acted on their own behalf.

This situation changed, reducing the possibility of abuse of electronic identification, with the introduction of Client’s Gate+ and DÁP identification as electronic identification services.

Based on the above, it can be stated that electronic identification is a legal and technical prerequisite for taxpayer protection, the use of electronic tax administration procedures, the enforcement of taxpayer rights, and the fulfillment of obligations.

In procedures initiated upon request, the taxpayer is obliged to apply one of the identification methods provided by the legislator. Currently, the legislator ensures the choice between identification methods. Both methods contribute to the protection of the user’s personal data. In the case of officially initiated electronic procedures, the tax authority preliminarily identifies and classifies taxpayers with and without electronic identification. It also separately groups taxpayers who have „prohibited” electronic accessibility according to the Registry of Dispositions. Certain taxpayer groups, such as sole proprietors, cannot make such provisions because it would contradict the statutory requirement that these groups maintain electronic contact with the tax authority (Art. 36. §).

The tax authority uses the identification interface and electronic identification services developed and supervised by IdomSoft Zrt., through which the identification services presented above are available when the user clicks the “Login” button:

1. illustration – Online Form-Completion Application, where the user can start the electronic authentication process (Picture made by myself with Microsoft Picture Cut program)

2. illustration – Online authentication website where the user can choose the electronic authentication’s method (Picture made by myself with Microsoft Picture Cut program)

 

If the users authentication is succesful then they can reach the autheticated homepage provided by NTCA.

3. illustration – Online Form-Completion Application homepage after successful user authentication (Picture made bymyselfwith Microsoft Picture Cut program)

4.1. Freedom to Choose a Representative and the Possibility of Free Representation

Sections 14–20 of the Act on Tax Administration (Air.) provide taxpayers with the opportunity to authorize a representative during their electronic tax administration procedures, either generally or for handling a specific case. Currently, the NTCA only allows permanent representatives to use the ONYA portal for procedures; however, it fully guarantees taxpayers’ right to freely choose their representatives in this regard. In connection with this, it is worth highlighting that the tax authority does not distinguish between permanent and occasional representatives when submitting electronic (ePAPÍR) requests, other ÁNYK declarations, data submissions via web channels, or paper-based requests and petitions.

Below, I will present the ONYA Representatives menu:

4. illustration – This site shows the “Representatives” menu, where the user can choose from the taxpayers (Picture made by myself with Microsoft Picture Cut program)

In the Representatives menu – unlike the NTCA Customer Portal – the tax authority currently distinguishes four types of taxpayers:[14]

  • companies,
  • private individuals (natural person taxpayers),
  • private individuals with tax numbers, and
  • individual entrepreneurs.

If the taxpayer is also registered as a sole proprietor in the Individual Entrepreneurs Register (EVNY), they can switch between acting as a “private individual” and as a „sole proprietor” in this menu. A similar approach is used by the E-Municipal Portal, where the switching between different taxpayer “identities/roles” is essentially realized through the “Role Change” function.

If the permanent representative does not act on their own behalf or in relation to their own sole proprietorship, the tax authority provides an option in this menu of ONYA for the representative to select the principal/client on whose behalf they intend to act before starting the administration.

If the user successfully selects the represented person, the result of their choice can be tracked in the top right corner of the screen with the label “logged-in user – represented taxpayer”. In this section, during the completion of reports, returns, and declarations, the taxpayer always ensures the user has the opportunity to verify and control their actions to prevent incorrect submissions of reports and returns.

5. illustration – ONYA right-up corner header where user can check the session time, the username and the represented taxpayer’s name, what he/she chooses (Picture made by myself with Microsoft Picture Cut program)

Currently, a shortcoming of the interface is that the taxpayer cannot track the representative’s actions. However, the NTCA Client Portal offers numerous other options for monitoring the representative’s activities, such as through the “Query Declarations”, “Query Missing Declarations” and “Query Documents” functions, among others.

In the future, ensuring the traceability of activities between the representative and the represented taxpayer on the tax authority’s electronic administration platforms may become a key issue. This traceability serves as a guarantee and a „safeguard” from the perspective of taxpayer rights enforcement in relations between taxpayers. It is important to emphasize that from the authority’s perspective, whether the taxpayer acts independently or through a representative, both are considered the taxpayer’s actions, “performance,” or, in the case of inaction, a failure. In my opinion, the tax authority should not interfere in the civil law relationship between the taxpayer and the representative, although these existing and potentially future functions support taxpayer rights enforcement against errors or negligence by the representative.

A related example is the comparison between the eBEV portal and the NTCA Client Portal’s detailed tax account statement. The eBEV portal, launched in the 2000s, fully performed its functions until mid-2022, after which it was replaced by the NTCA Client Portal in July 2022. Compared to the previous tax account query function, the NTCA Client Portal clearly and purposefully displays the taxpayer’s current tax account balance, as well as any potential late payment and penalty fees. In cases of possible negligence by their representatives, taxpayers can more easily verify why the tax authority may have imposed a penalty on them. Due to the tax authority’s detailed accounting on the „obligor side,” taxpayers can also determine which tax obligation the penalty relates to, whether it results from omission, deficiency, or error.

If the taxpayer wants to review the content of a penalty decision, they can easily retrieve it through the NTCA Client Portal’s Document Query service. They can also enforce claims for reimbursement of the penalty due to the representative’s actions against their permanent representative or employee. Based on the above, it is clear that although the ONYA portal does not provide this, the tax authority has other services accessible to taxpayers that enable tracking and monitoring of representatives’ activities following their registration. These services contribute to the practical enforcement of the right to good administration.

4.2. Support for Data Reporting, Change Notification, and Tax Return Obligations

In the event that the taxpayer has successfully logged in without selecting a representative or a represented taxpayer, the taxpayer has the opportunity to view their current data registered by the tax authority. The purpose of this function is to inform the taxpayer about what information the tax authority currently holds about them in the taxpayer registry system. This registry is considered the primary record in terms of tax-related characteristics and information; however, other data are maintained in secondary registries, such as company data, individual entrepreneur registration details, court-registered organization data, etc. Additionally, on the ONYA platform, the tax authority provides a „restricted” data overview under the “My Data” menu, whereas taxpayers can access a broader, more transparent, and dynamically updated service with the same name on the NTCA Client Portal (NTCA ÜPO).

In designing ONYA, the tax authority aimed to create a clear and transparent electronic service. A key achievement of this approach is the introduction of the so-called Form Map (Nyomtatvány-térkép). In the Form Map, the tax authority has “grouped” the notifications, returns, declarations, and other applications accessible on the ONYA interface.

6. illustration – ONYA form’s map, where the user can choose from the available online tax processes/forms (Picture made by myself with Microsoft Picture Cut program)

The Form Map also features a “smart” search function, the essence of which is that the NTCA provides a list of matching services based on the typed word or word fragment. It is important to highlight that during the initiation of a case, the “tax status” of the selected taxpayer – i.e., whether it concerns a private individual, sole proprietor, private individual with a tax number, or an organization – affects the range of services displayed and accessible. By this, the tax authority fulfills its obligation to provide information as set out in the Air. (Act on Taxation), as well as its duty to conduct procedures professionally, cost-effectively, and within a reasonable timeframe. Furthermore, it meets its cooperative obligation to support taxpayer rights enforcement and compliance with obligations.

Beyond what has been described above, during the use of services, several additional functions assist the user in fulfilling their tax obligations, such as:

  • The tax authority always pre-fills the identification data of the taxpayer (acting “virtually”) in all cases.

In some services, the taxpayer’s “current” data or previously reported data are pre-filled.

  • Certain services allow, according to the taxpayer’s choice, the loading of data from the tax authority’s records into the service to facilitate reporting obligations (so-called data pre-filling).
  • During data entry, after leaving data fields/cells, the system can automatically run validations and notify the user of presumably incorrect data.
  • The service provides the smart search function described above, offers informational bubbles (help) to assist with completion, and performs comprehensive error checks before submission – that is, it compares entered data with the data held by the NTCA, and also conducts logical and targeted external consistency checks.
  • For reporting errors, deficiencies, and system inconsistencies, a technical reporting email is available 24/7, and on weekdays, taxpayers can also report ONYA issues via the national customer service number 1819, among other options.

Based on the above, the tax authority aims to develop an online service within ONYA that focuses entirely on supporting taxpayers and enforcing their procedural rights, with the ultimate goal of guaranteeing the practical enforcement of the right to good administration.

5. Conclusions and Summary

In summary of my article, I would like to answer the research questions posed at the beginning of the study, taking into account the above:

1. “How are procedural rights enforced for taxpayers during electronic tax administration procedures?”

In electronic tax administration procedures, the rights of taxpayers are fully enforced, perhaps even at a somewhat higher level than in most traditional paper-based procedures, because:

– the NTCA (Hungarian Tax Authority) creates the necessary procedural “conditions”, and

– it ensures taxpayers’ rights through electronic services as if the client personally visited any NTCA customer service office and the caseworker “guided their hand”.

The tax authority responsible for electronic administration bears full professional and technical responsibility to ensure that taxpayers’ rights are not compromised during the use of services, and that regardless of place, time, or any other circumstance. After successful taxpayer identification, comprehensive and professional administration is provided for the taxpayers, in which the constitutional right to good administration is upheld.[15] In the case of ONYA, the NTCA has created a service that strives to eliminate the errors of its predecessor, and the tax authority develops and applies functions during the selection of services, provision of information about data, and use of the service to support users (taxpayers) in exercising their rights and fulfilling their obligations. Ultimately, these contribute to the practical enforcement of the right to good administration in electronic tax administration procedures.

It can be concluded that the use of electronic tax administration procedures and services cannot hinder the enforcement of taxpayers’ rights, nor can the inadequate level of development of the service. This professional requirement (conclusion) supported by OECD for example in „Tax Administration 3.0” or „Digital Transformation Maturity Model” reports.[16]

At the context of ONYA, to validate this conclusion, I used these examination aspects, like:

  • Is the ONYA needs any special technical requirement? No, you only need for example smart phone, internet connection and internet browser.
  • Is the ONYA needs any expertise to use? No, the ONYA developed to everyday people and only few steps need to fulfill your tax obligation.
  • Is the ONYA reachable anytime? Yes, everyday, anytime (24/7) and everywhere, etc.

In connection with this conclusion must be declare that the ONYA or most of the tax administration’s services are only an optional electronic method for the tax obligations’ fulfillment. For example, if the ONYA each service has a technical issue, the taxpayer can choose another method to fulfill his/her obligation like NTCA M2M (machine to machine) or ÁNYK. We know the expiration’s date of ÁNYK when the ONYA will be the only method taxpayer legals enforcement or tax obligation fulfillment, but now the taxpayer can choose the tax obligation fulfillment method. [17]

2. “What are the motivations behind the development of electronic tax administration services and processes, and their impact on taxpayer – that is, what are the benefits that NTCA can achieve through full digitalization?”

The complete digital transformation embodies the vision of “invisible taxation”. The essence of this vision is that taxation occurs without active participation from the taxpayer, who is informed afterward. System processes take place automatically without human intervention. For example, the system automatically offers taxpayers the possibility of a refund if it detects that the taxpayer is entitled to a benefit. In this vision, taxpayers use NTCA’s electronic services, and monitoring taxation does not require professional assistance (this can be considered the authority’s motivation for development). This is achievable if NTCA simplifies the tax procedures, rights exercise, and obligation fulfillment for taxpayers and makes them understandable. The design of individual services is not determined by system requirements invisible to taxpayers but by clear and comprehensible laws, clear objectives, and in practice, regularly assessed taxpayer needs simplify the use of services, thereby ensuring the full enforcement of the right to good administration.

 

* Szalóki, István, doctoral candidate, University of Debrecen, Marton Géza Doctoral School of Legal Studies, Supervisor: Árva, Zsuzsanna, professor, University of Debrecen, Faculty of Law

[1] See more: Cseh Gergely – Czékmann Zsolt: Elektronikus közszolgáltatások a SZEÜSZ-ök tükrében [Electronic public services in the light of the SZEUSZs], Publicatione Universitatis Miskolciensis Series Juridica et Politica Tomus, 2014/32. p. 135–145. and Csáki Gyula Balázs, Kérdésfelvetések az e-közigazgatás fogalmának meghatározása körében. Infokommunikáció és Jog, 29, 2008.

[2] Molnár Szilárd: Úton az e-közigazgatás megvalósítása felé. [On the way to implementing e-government] in: Álló Géza et al.: Tanulmányok a magyar e-közigazgatásról. A „Hiteles helyektől” az elektronikus közigazgatásig. [Studies from hungarian e-government. From „Authoritative Places” to electronic public administration.] Primaware Kiadó [Primaware Publishing], 2014. p. 194-202.

[3] See more about the contradictionary nature of the regulation: Csáki Gyula Balázs, Környezetváltozás a közigazgatásban – szemléletváltozás nélkül. Infokommunikáció és Jog, 2006, 3.

[4] See more about the development of e-government and regulation in Hungary:
Kovács Tamás – Molnár Szilárd: A közigazgatási ICT stratégia és az új jogi-szervezeti keretrendszer. [The public administration ICT strategy and the new legal-organizational framework.] in: Tózsa István (szerk.): Az infokommunikációs technológia hatása a közigazgatás tudományra. [The impact of information and communication technology on public administration science] NKE KTK, Budapest, 2013.
Sántha György: „Utazás a digitális állam körül.” E-közigazgatási úti beszámoló az elmúlt 10 évről [„Travel around the digital government.” E-public administration road report about the last 10 year], Új Magyar Közigazgatás [New Hungarian Public Administration], 2015/3. p. 69–78.
Czékmann Zsolt – Kiss Lilla Nóra: The concept of e-Administration int the Hungarian regulation, Curentul Juridic, 2015/1. p. 73–88.

[5] See more: Vozár Anikó – Bán Erika: Digitalizáció, digitális transzformáció – a Nemzeti Adó- és Vámhivatal gyakorlatában [Digitalisation, digital transformation – in the practice of National Tax and Customs Administartion], Pénzügyi Szemle [Financial Review] 2024/1. p. 85–109.

[6] See more eKÁER system’s beginning experience, goals and regulation:
Mihics Henrik: EKAER-rel kapcsolatos legfontosabb tudnivalók [Most important information about EKAER], Adóvilág [Tax-world] ARCHÍV, 2015. https://adovilag.hu/2015/02/07/az-ekaer-rel-kapcsolatos-legfontosabb-tudnivalok/, [2024.03.10.]Varga Zoltán: Az EKÁER gyakorlati nézőpontból [The EKÁER from the practical point of view], Infokommunikáció és Jog [Infocommunication and Law], 2020/2. https://infojog.hu/dr-varga-zoltan-az-ekaer-gyakorlati-nezopontbol-2020-2-75-e-kulonszam/ [2024.03.10.]

[7] Vágujhelyi Ferenc: Rekordot döntött az eSZJA https://mti.hu/hirek/2025/06/01/vagujhelyi-ferenc-rekordot-dontott-az-eszja, [2025.06.30.]

[8] See more ePIT portal: eSZJA a fejlesztő szemével [ePIT from the view of the developer „eye”], SZAK-ma, 2017. https://szak-ma.hu/ado/eszja-a-fejleszto-szemevel-101353 [2024.03.10.]

[9] See more eVAT portal:
Varró György: Praktikus információk az eÁFA-rendszer használatához – I. rész [Practical information for eVAT-system use – Part I.], Adóvilág [Tax-world], 2024/1. https://adovilag.hu/2024/02/09/praktikus-informaciok-az-eafa-rendszer-hasznalatahoz-i-resz/ [2024.03.10.]Varró György: Praktikus információk az eÁFA-rendszer használatához – II. rész [Practical infromation for eVAT-system use – Part II.], Adóvilág [Tax-world], 2024/4. https://adovilag.hu/2024/02/09/praktikus-informaciok-az-eafa-rendszer-hasznalatahoz-i-resz/ [2024.05.20.]Sipos Tímea: eÁFA – újdonságok [eVAT – novelties], Adóvilág [Tax-world], 2024/10. https://adovilag.hu/2024/11/18/eafa-ujdonsagok/ [2024.11.18.]Czöndör Szabolcs: Az eÁFA jövőbeli fejlesztési irányai [The eVAT future development’s directions], Adóvilág [Tax-world], 2025/1. https://adovilag.hu/2025/02/03/az-eafa-jovobeli-fejlesztesi-iranyai/ [2025.02.12.]

[10] See more:
Árva Zsuzsanna: A közigazgatási hatósági eljárás alapelvei nemzetközi kontextusban. [Principles of administrative procedure in an international context.] in: Csáki-Hatalovics Gyula (szerk.): Eljárásjogi kodifikáció – nemzetközi hatások: tanulmányok. [Codification of procedural law – international impacts: studies.] Budapest Patricinium, 2018, p. 115–128.
Csűrös Gabriella: Okos adóztatás, okos adóreform – adópolitikai alapvetések [Smart taxation, smart tax reforms – tax policy fundamentals], Istum Aequum Salutare, 2019/3. p. 27–44.

[11] https:\\www.nav.gov.hu

[12] Szalóki István: Új normák a közigazgatásban? Elektronikus kapcsolattartástól az elektronikus közigazgatásig [New norms in public administration? From electronic communication to electronic public administration], Régiókutatás Szemle [Regional Research Review] 2020/1. p. 41–58.

[13] The ONYA doesn’t have an official translation, yet, that is why I used the official hungarian webpage’s pic-
tures in the article.

[14] See more about taxpayers’ digital role: Szalóki István: Az adózók szerepe a digitális adóigazgatásban [The role of taxpayers in the digital tax administration], Jegyző és Közigazgatás [Notary and Public Administration] 2021/2. p. 24–29.

[15] See more about smart taxation:
Bordás Péter: Smart taxation in the hungarian tax system, Curentul Juridic 2021/87. p. 62–70.

[16] See more about OECD elektronic tax administration development or requirements in:
OECD Tax Administration 3.0: The Digital Transformation of Tax Administration. 2020. Hivatkozás: https://www.oecd.org/tax/forum-on-tax-administration/publications-and-products/tax-administration-3-0-the-digital-transformation-of-tax-administration.pdf, Letöltés ideje: 2025.10.20.
OECD: Digital Transformation Maturity Model 2021 Hivatkozás: https://www.oecd.org/tax/forum-on-tax-administration/publications-and-products/digital-transformation-maturity-model.pdf, Letöltés ideje: 2025.10.20.

[17] Nowdays the ONYA doesn’t have detailed regulations or we cannot find judge practice about ONYA electronic taxation services. We have to wait until 1st of January, 2027 when ONYA becomes exclusive electronic way for many taxpayers. That is the reason why I could not analyse this areas in the article.