NAV in 2026: supportive attitude and data‑driven audits

The National Tax and Customs Administration (NAV) has published its inspection plan for 2026. According to the document, continuing the traditions of previous years and making use of its data assets, the authority will again select taxpayers for targeted audits this year. Deloitte experts note that NAV continues to follow the principle of gradual escalation: it first reconciles data and provides support, but intervenes immediately in the case of repeat offenders.

NAV’s 2026 inspection plan shows that, as in earlier years, the authority first attempts reconciliation. If it detects inconsistencies between tax returns and its own data, it requests corrections through a new procedure known as data reconciliation. If this process fails, the tax authority launches a formal audit as the next step.

There are several easily identifiable anomalies that NAV consistently focuses on because they may indicate tax evasion. Taxpayers falling into these categories can expect increased scrutiny. These discrepancies are typically identified using control data and often become apparent immediately.

Examples include:

• Companies consistently filing “zero” VAT returns or failing to submit VAT returns, despite online invoice data indicating turnover
• Newly established or ownership‑change companies reporting unusually high turnover
• Companies registered at a virtual office without employees
• Companies operating without employees but generating high or suddenly increasing revenue
• Companies carrying forward deductible VAT for several years

The Üvegkapu system shows in real time who is present at construction sites and which companies participate in a project. This supports the monitoring of lawful employment and the uncovering of subcontractor chains. The aim is to increase compliance in the sector. NAV continues to monitor this data and use it in its audits.

Construction has been the sector most affected by legal disputes in recent years, reflecting NAV’s strict enforcement. Businesses in this area should proceed with caution and pay close attention to compliance and partner vetting, as both NAV and the courts expect this.

Hungary’s VAT gap—the difference between potential and actual VAT revenue—has slightly worsened in recent years, which is also reflected in NAV’s inspection plan. The authority places special emphasis on uncovering fictitious invoicing chains. By using artificial intelligence, NAV can analyze its data assets to detect risky invoices in real time and take immediate action.

Thorough partner vetting remains essential. Companies caught up in suspicious chains can quickly become subject to audits, which may even result in the loss of their VAT deduction rights.

Areas where inspections may intensify include:

• E‑commerce platforms and online marketplaces, with a special focus on retail tax compliance
• Companies claiming social contribution tax relief (SZOCHO) for vocational or dual education programs
• Businesses employing “on‑paper” registered relatives to claim family policy benefits
• Companies subject to food‑chain supervision fees, as NAV took over these audits in 2025

NAV audits large taxpayers based on risk analysis, so when the authority shows interest, there is usually a specific reason. Industries likely to be in focus include automotive, construction, chemicals, IT, and software development. Transfer pricing—the pricing of intra‑group transactions—will remain a key topic in 2026. Companies performing routine manufacturing, distribution, or agency activities with persistent losses or low profitability can particularly expect audits. Intra‑group loans and unusual financial transactions may also attract NAV’s attention. Additionally, incomplete data reporting can trigger audits across all taxpayer groups.

Beyond transfer pricing, NAV will closely monitor the correct application of tax incentives, especially those related to development, energy efficiency, and renovation.

Taxpayers can also expect audits related to the global minimum tax, particularly concerning corporate income tax, the innovation contribution, and the Robin Hood tax. The main focus will be on the correctness of accounting treatment and loss carryforwards.

In customs matters, NAV continues to focus on the review of customs values that are deemed too low.

Several municipalities have recently increased land and building taxes, which may result in a tangible increase in the tax burden. Given these rising costs, businesses should review potential savings opportunities—such as local tax relief—and verify the accuracy of their recorded floor areas.

Deloitte Legal experts advise taxpayers to take all inquiries seriously and respond accurately and on time, as proactive cooperation is often the best form of defense.