Summary
- Viktor Orban has seized control of nearly all the levers of power in Hungary since he became prime minister in 2010, effectively turning the country into an electoral autocracy.
- Republicans in the US have noticed Orban’s success. Orban’s Fidesz party and the Republicans have lately strengthened their links significantly; Republicans appear to have learned from the former’s march through Hungarian institutions.
- In the four years since President Donald Trump left office, veterans of his administration have thought hard about how to make a new administration more effective than the last. Many believe that a similar seizure of control of the instruments of US governance is necessary.
- If Trump wins the presidency, Republicans will likely adapt many of Orban’s techniques to the US context to end what they view as liberal control of the “administrative state” and civil society.
- This new form of US governance could have profound implications not only for European foreign policy, including the robustness of NATO’s collective defence, but also EU and domestic European democracy as a Trump White House seeks to lead and champion like-minded allies across the world.
The meaning of Orban
“There is a great man, a great leader in Europe — Viktor Orban. … He is the prime minister of Hungary. He is a very great leader, a very strong man.” – Donald Trump, January 2024.
Hungary’s Viktor Orban is arguably the most successful populist leader in the world today. Since he became prime minister for the second time in 2010, he has transformed Hungary into what many describe as an “illiberal democracy”. Over those 14 years, he has seized control of nearly all the institutions of the state and most of the media, and has put increasing pressure on civil society in Hungary. Competitive elections persist, but Orban’s control over the media and the skewed electoral system help ensure his Hungarian Civic Alliance (Fidesz) party continues to win overwhelming majorities. At a time of fierce anti-incumbency sentiment, Orban is currently the longest-serving leader in the European Union and the longest-serving prime minister in Hungary’s post-communist history.
As former president Donald Trump implies, Republicans in the United States have noticed Orban’s success. Many are looking to the Hungarian example to understand how a second Trump administration might succeed at transforming America in a way that the first one never managed.
Orban, after all, also lost power after his first term as prime minister (1998-2002). He accepted that defeat, but Fidesz too planted a seed of doubt about electoral fraud committed by the then-opposition parties. Orban then spent eight years in opposition nursing grievances against the socialists and liberals. In his view, they stood not for the nation but for capitalist and foreign interests and threatened the creation of the “civic Hungary” he sought to build.
Upon returning to power in 2010, Orban and his advisers concluded that the source of Hungary’s problems in the preceding eight years had been the weakness of the executive and the state, which was vulnerable to capture by private business interests. With the constitutional majority now in their hands, they set out to build the so-called System of National Cooperation, in which the governing parties would strengthen the state and, more importantly, the governing parties’ grip on it. A newly empowered executive would allow for the implementation of their agenda that, according to their slogan, put the interests of “the nation” in the forefront.
The concentration of power that Orban achieved after 2010 largely did away with institutional constraints and silenced dissent. For the many who served in the Trump administration who blame liberal bias and obstructionism for their implementation problems, the Hungarian experience is an inspiration. In their view, the first Trump administration fell short on implementing presidential promises such as building a wall on the border, withdrawing from NATO and Afghanistan, or ending the trade deficit with China not because of incompetence but due to a liberal bias and obstructionism in the state administration.
Accordingly, removing checks and balances of all kinds is the only way to counter what they see as entrenched liberal control of key governmental and civil society institutions, including the civil service, NGOs, higher education, finance, the media, and the technology industry. As the preface to The Heritage Foundation’s Mandate for Leadership evocatively puts it, “[t]he long march of cultural Marxism through our institutions has come to pass. The federal government is a behemoth, weaponized against American citizens and conservative values.” In this view, even Trump’s own “establishment” political appointees, unconsciously infused with liberal values, often betrayed him and frustrated his agenda.
The now infamous Heritage Foundation-led Project 2025, directed by Paul Dans, the former head of Trump’s White House Personnel Office, contains at its heart the idea that liberal control of the “administrative state” and civil society have long stymied conservative governance and must be overcome for Trump to govern effectively. It avows that the primary effort of a second Trump administration will be to “dismantle the administrative state and return self-governance to the American people.”
As part of that effort, they are seeking to learn from Orban’s success in Hungary. But how did he manage to exercise control over Hungary and can the lessons from Hungary be exported to the very different context of the US? This policy brief seeks to answer those questions. It looks at how Orban seized control of Hungary, what US Republicans have learned from that experience, and whether and how they might translate in American context. We call it the Orbanisation of America.
The Hungarian experience
“Modern Hungary is not just a model for conservative statecraft, but the model. Americans, Brits, Spaniards, Australians—everyone—can and should learn from it.” Kevin Roberts, president of the Heritage Foundation, The Hungarian Conservative, December 2022.
Liberal democracies are increasingly less likely to collapse due to coups d’états or blatant electoral fraud. More frequently, they are undermined by state-led erosion of their institutions and electoral manipulation. Hungary under Orban serves as the paradigmatic example of this type of modern democratic erosion. Since 2010, Hungary has experienced a gradual but severe democratic decline driven by these initially democratically elected officials, who expanded their grip on power while upholding the façade of democracy.
After a period of domestic political and economic crisis in Hungary in the late 2000s, Fidesz won Hungary’s 2010 parliamentary election with 52.7 per cent of the popular vote. That slim majority nonetheless translated into two-thirds of the seats in the national assembly for the governing coalition. The Christian Democrats have served continuously as Orban’s junior coalition partner for the last 14 years. They are, however, entirely politically dependent on Fidesz and have no clear separate political programme or agenda. The effective super-majority commanded by Fidesz allowed Orban to put the legislative branch in the uncontested service of the executive, pass and amend any legislation, and even rewrite the constitutional rules of the democratic game. In April 2011, after only a year in power, the governing majority adopted the so-called Fundamental Law, Hungary’s new constitution, without any consultation with opposition parties or the public. As Orban himself put it, “we need to win only once, but we need to win big.”
Orban paired his authoritarian approach to governance with an ideology that has been steadily shifting toward the far right over the past decade. The government adopted a populist and nativist rhetoric that targets various external and internal groups – including critics of the government as well as various minorities and vulnerable groups – as potential threats to the country, its population, and its culture. In doing so, the government engineered a permanent sense of crisis in its public communication. This type of threat inflation has fuelled polarisation, solidified Orban’s base and served as a reason to adopt various “emergency” measures. This process of executive aggrandisement – the concentration of power and takeover of state institutions – eliminated the checks and balances from the system that could have held the executive accountable and guaranteed the rights and protection of political, ethnic, religious, and other minorities. By the early 2020s this had transformed the country into an electoral autocracy.
The judiciary
After coming to power, Orban’s government started to weaken horizontal accountability by undermining judicial independence. In 2010, a key legislative amendment allowed justices of the Constitutional Court to be elected by a two-thirds parliamentary majority, replacing the previous model that sought to find consensus about nominations among all parliamentary forces. The number of justices was increased from 11 to 15, their mandates were extended from 9 to 12 years, the retirement age limit was abolished, and the right to elect the Constitutional Court president was transferred from the court to the parliament. These changes enabled the nomination of justices loyal to Fidesz and, by 2013, pro-government justices held the majority. Additionally, the court’s authority to review budget-related laws was annulled, allowing the government to implement economic policies without judicial oversight during Hungary’s economic and financial crisis.
In 2011, the Fidesz government passed further reforms that reconfigured the court system. Most importantly, it abolished the National Judiciary Council, which oversaw the judicial branch, and replaced it with two new bodies: the National Judicial Council, a self-governing body composed of judges that exercises supervisory functions over the judiciary, and the National Office of the Judiciary, responsible for the central administration of the country’s courts, whose head was subsequently elected by the parliament. This reform ensured that Tunde Hando, wife of Fidesz MEP Jozsef Szajer – who wrote the Fundamental Law – could take the post. The government also lowered judges’ retirement age to 62, forcing the removal of 274 judges and allowing the NOJ president to fill these positions. The European Court of Justice deemed the removal of the judges illegal, but the situation was not reversed. In 2020, further centralisation took place with reforms strengthening the Curia, Hungary’s highest court. These reforms required lower courts to follow Curia decisions, while the Curia in turn was mandated to run legal unity reviews should a lower court wish to deviate from its case law. The following year, Fidesz appointed Zsolt Andras Varga, a loyalist and former Constitutional Court justice with no prior judicial experience, as Curia president, increasing political control over the judiciary.
Personnel politics
The nomination of loyalists to the helm of state institutions played a central role in the consolidation of power by Fidesz. Besides taking over the constitutional court and filling the highest positions in the judiciary with loyalists, the prosecutor general (Peter Polt, 2010-) and the president of the State Audit Office (Laszlo Domonkos, 2011-22), among others, were also former members of Fidesz. In certain cases, Fidesz also expanded the term of its political appointees well beyond a governmental cycle, cementing the party’s political influence in the system should it lose parliamentary elections (more on which below).
Securing the loyalty of the president of the republic was another crucial aspect of Fidesz’s strategy. Although the role of president is largely symbolic, the office signs laws into effect and has the right to challenge the constitutionality of legislation passed by parliament. After the mandate of President Laszlo Solyom, an independent legal scholar and former Constitutional Court justice, ended in 2010, Fidesz nominated and with its two-thirds majority elected Pal Schmitt, at that time a Fidesz MEP. Schmitt showed great loyalty to his party and refrained from using his control functions as president. In fact, he openly expressed his commitment to the government’s legislative agenda.
The nomination of party politicians as president and their subsequent compliant attitude continued beyond Schmitt. Fidesz politician Janos Ader, author of the 2011 judiciary reform and president from 2012 to 2022, at times used his veto powers, but did not position himself as an independent counterweight or check on the government’s authority. His successor, Katalin Novak, who held office until February 2024, was a former vice-president of Fidesz and member of Orban’s government before her presidency; she was also fully aligned with the government both politically and ideologically.
The electoral law
The path to electoral autocracy is a dangerous one, even for the leader who paves it. By definition, it creates an executive authority that is too powerful to give up. As one Polish politician put it in the lead-up to the 2023 general election following eight years of gradual shift towards electoral autocracy, “this election is about whether we go to jail or they go to jail.”[1] As autocratisation unfolds and the electoral stakes increase, leaders will naturally use their executive authority to tilt elections in their favour in any way they can.
To maintain its grip on power, the Hungarian government periodically amended the electoral law, a document which establishes the rules of elections. The government started with an overhaul in 2011 that reduced the parliament’s size to 199 members and redrew the electoral map, raising concerns about gerrymandering. Adopted unilaterally without consultations with the opposition parties, the reform strengthened majoritarian elements over proportional ones, increasing the importance of single-mandate constituencies and ultimately favouring the strongest political force.
Of the 199 seats, 106 are now from single-mandate districts and 93 are allocated proportionally. The new law also permitted Hungarian citizens without registered addresses in the country to vote via mail, benefiting those who gained citizenship through Fidesz’s 2010 simplified naturalisation process. Further amendments before the 2018 and 2022 general elections also favoured the governing parties. Last-minute changes in 2022, for example, disrupted the strategy of opposition parties, which were forced to submit a joint national list to be able to stand a chance against Fidesz. Due to these legislative adjustments, coupled with uneven campaign finances, misuse of state funds, and restricted media access for the opposition, the Organisation for Security and Cooperation in Europe has deemed Hungarian elections since 2014 free but not fair.
The media
Fidesz has also tightened its control of the media. In 2010 it pushed through a constitutional amendment that removed the obligation to prevent media monopolies and established the National Media and Infocommunication Authority (known as the Media Authority) as the media regulator. Its president, former Fidesz member Annamaria Szalai, was elected for a nine-year term by a two-thirds parliamentary majority. The Media Authority and its Media Council, which is responsible for regulating content, gained the authority to monitor media, issue penalties, and suspend operations of outlets that it deems present “unbalanced” or “amoral” content. The centralisation of state media operations and content production under the Media Service Support and Asset Management Fund (MTVA), controlled by the Media Council, effectively ended the ability of public media to operate independently as it enabled censorship and governmental interference in editorial practices.
Fidesz has also expanded its influence over non-state media. Business circles linked to the party established new outlets and acquired existing ones, which were then financially supported through state advertising. Later on, the Central European Press and Media Foundation, established in 2018 and led by individuals close to Fidesz, acquired these outlets and ultimately merged 28 companies comprising around 500 outlets. Notably, this conglomerate was exempted from competition law by the government, which declared the acquisitions of “national strategic importance”. The exemption was challenged in court, but the Constitutional Court dismissed the case.
As a result, Hungary’s media landscape today is dominated by pro-government outlets that support Fidesz’s political agenda. These outlets often run smear campaigns to discredit journalists and experts, making widespread use of elaborate conspiracy theories. In some of these cases, video material used of the targets of the smear campaigns was later revealed to be the result of covert intelligence operations carried out by Israeli private firm Black Cube.
What is left of independent media faces sanctions, hostility, and surveillance. A notable example is Klubradio, a radio station critical of the government that had its broadcasting licence revoked by the Media Council for alleged breaches of the media law. Despite legal challenges, the revocation was upheld, prompting the EU to launch an infringement procedure. Klubradio now operates online.
In 2021, investigative journalists revealed that about 300 Hungarian citizens, including many journalists, were targeted with Pegasus, a spyware developed by the Israeli cyber-arms company NSO Group. Although the software had been purchased by the Hungarian state, a later investigation by the government-controlled Hungarian National Authority for Data Protection and Freedom of Information concluded that no laws were breached when it was used, resulting in no practical consequences.
Non-governmental organisations
Over the years, Fidesz has enacted a series of restrictive laws targeting NGOs that are critical of the government. The 2017 Lex NGO law required NGOs receiving funds from non-Hungarian sources above a certain amount to register as “organisations funded from abroad”. In 2020, the European Court of Justice (ECJ) found that law in breach of EU legislation, but the government repealed it only the following year. In 2018, the “Stop Soros” law package adopted by the governing parties criminalised aiding asylum seekers. The ECJ also ruled against that, but the package remains in effect. In 2021, a law mandated the State Audit Office (SAO) to audit NGOs with annual budgets exceeding 20m forints every two years, classifying them as “civic organisations engaging in activities likely to influence public life”. The SAO, which previously only dealt with public funding, thus gained the ability to oversee how NGOs spend private funds.
In 2023, the Fidesz government adopted the Sovereignty Protection Act, reminiscent of similar Russian foreign agent legislation. It established the Sovereignty Protection Authority (SPA), tasked with protecting the country against foreign interference. Led by Tamas Lanczi, the former director of Fidesz’s think-tank Szazadveg and a former president of MTVA online, the SPA has broad and unchecked powers to investigate the activities of civil society organisations and media outlets to determine if they receive funding from abroad. The SPA has the authority to obtain data from any state or local government body, as well as other organisations. It may refer cases it investigates to the relevant authority to initiate infringement or criminal procedures should it identify what it considers irregularities. It also prepares public reports about its findings, and there is no forum to appeal against these reports or the broader activities of the SPA. Since key concepts were not defined in the law, the SPA retains significant discretion to interpret its mandate, giving its inquiries virtually unlimited scope.
In May 2024, the SPA published its first report, which was an investigation into alleged illicit foreign financing of opposition parties’ campaign for the 2022 parliamentary election. It concluded that a network of US-based actors continues to seek to influence politics in central Europe, including in Hungary, and threaten the integrity of elections. The investigation relied on covertly recorded videos of individuals connected to Action for Democracy, a US-based NGO led by a former adviser of Budapest’s opposition mayor. In June 2024, the authority launched its first comprehensive investigation against anti-corruption watchdog Transparency International Hungary and the investigative journalism portal Atlatszo, adding to concerns that the SPA will be used to put pressure on critical voices. The authority claims that these organisations use foreign funding to seek to influence “the will of the voters”.
Ideology
Fidesz’s permanent parliamentary control has been critical in consolidating its power. Equally crucial has been its populist and nativist rhetoric, through which it provides an ideological justification for its state capture. Already after his 2002 electoral defeat when Orban proclaimed that “the country cannot be in opposition”, and especially following then-prime minister Ferenc Gyurcsany’s infamous leaked speech admitting to having lied in the campaign of the 2006 parliamentary election, Fidesz fostered an ‘us’ v ‘them’ narrative, attacking the ruling socialist-liberal coalition and positioning itself and its leader, Orban, as the true representatives of the Hungarian people.
As EU criticism of the Hungarian government’s anti-democratic measures grew in the early 2010s, Fidesz began portraying the EU, “Brussels”, the “liberal elite”, and critical politicians as enemies of the Hungarian people. The government and pro-government media often depicted domestic NGOs and civil society organisations that were critical of the government as paid agents – often by George Soros – serving foreign interests. Additionally, in 2015, the government’s rhetoric took a clear turn to the right as it started focusing on “illegal migrants” as threats to Hungary and Christian culture. This especially put NGOs advocating for the human rights of refugees and asylum seekers, such as the Hungarian Helsinki Committee, in the government’s crosshairs. In one manifestation of growing pressure on critical and dissenting voices, in 2018, a pro-government magazine published a “blacklist” of individuals it claimed were working to implement the will of George Soros in Hungary.
Fidesz has also increasingly delved into the realm of identity politics and culture wars. As the immediate pressure of the refugee and migration crisis faded, the government identified a new ‘threat’ to Hungarian families and children: sexual minorities. In 2021, it adopted a so-called anti-paedophile law that gained a strong homophobic character when, by the introduction of amendments regarding sexual minorities, the law conflated homosexuality and paedophilia. These amendments banned the portrayal and “promotion” of homosexuality and the display of content “promoting” homosexuality and sex reassignment to minors. Since 2023, the law has been used to impose fines on bookshops that did not display children’s books featuring LGBT+ characters in closed wrapping.
The government continues to identify new threats to the nation, perpetually fuelling a sense of crisis. This strategy serves to distract the public from the failures and shortcomings of Fidesz’s governance and to provide a justification for the government’s onslaught against NGOs, media outlets, and journalists that attempt to hold the government accountable.
Cultivating a friendly civil society and intellectual elite
While watchdogs and critical NGOs face mounting pressure, civil society actors aligned with Fidesz have flourished since Orban’s return to power. A prominent example is the Civil Cooperation Forum (COF), which plays a key role in mobilising support for the government. The COF often runs pro-government billboard campaigns and is the organiser of the so-called peace marches, which at sensitive times have brought thousands to the streets to show support for Fidesz’s policies.
Various think-tanks and research centres with ties to Fidesz, such as the Szazadveg, the Nezopont Institute, the XXI Century Institute, the Danube Institute, and the Center for Fundamental Rights have provided intellectual justification for the government’s agenda. In parallel, government-friendly figures have gained increased support and prominence in the cultural sector, which has emerged as a key battleground for the government’s identity politics. Aligning with Fidesz’s personnel strategy, party politicians and individuals close to Fidesz were appointed to head various museums, such as the Hungarian National Museum and the Petofi Literary Museum.
Fidesz also strengthened its grip on the educational sphere, leading to increased centralisation of public education and diminished teacher autonomy. In higher education, the government established the well funded National University of Public Service, tasked to train the next generation of civil servants, including police and military officers. Meanwhile, most Hungarian public universities had their governance structure overhauled in ways that undermined their autonomy. They were placed under the supervision of so-called public asset management foundations, the boards of which had members with close ties to the government, including prominent Fidesz politicians and even ministers. In response, the European Commission suspended 21 universities in 2023 from the Erasmus+ scholarship programme because of concerns over corruption and conflict of interest.
In parallel, the operations of the Matthias Corvinus College (MCC), a private college close to Fidesz, were expanded after the governing majority handed over the state’s ownership of a large share of stocks in Hungary’s two leading companies to the asset management foundation behind MCC in 2010. It now runs programmes from primary school to university and recruits students from Hungary and Hungarian minorities in neighbouring countries, with the aim of creating an ideologically aligned intellectual elite. The chair of the college’s board of trustees is the prime minister’s political director.
States of emergency
One of the tools most recently used by the government to consolidate its power is the abuse of the exceptional legal regime of the state of emergency (veszélyhelyzet). For many years after the 2015-16 peak of the refugee arrivals, the government maintained that the country was in a constant state of crisis. Then, in 2020, the covid-19 pandemic provided the justification to institute a state of emergency that allowed it to govern by decree, as well as to suspend or bypass existing legislation with few constraints. The parliament also enacted a provision that allowed decrees to remain in force beyond the then-constitutionally prescribed 15-day limit.
The government did not limit the scope of these decrees to tackling the pandemic. In the absence of judiciary oversight, it frequently overreached. Later, parliament passed amendments to the Fundamental Law that created new justifications for renewing the state of emergency and to prolong the validity of the decrees. As a result, until the present day Hungary has been governed under a state of emergency for over four years under various pretexts – currently the reason is the war in neighbouring Ukraine – sidelining both the standard rules of the governance process and other actors in it.
Hungarian links to the United States
“We have entered the programme-writing system of President Donald Trump’s team, and we have deep involvement there.” Hungarian prime minister Viktor Orban, July 2024.
NGOs and think-tanks close to Fidesz play an increasingly important role in establishing and strengthening ties with international partners.
These organisations have focused primarily on deepening cooperation with like-minded groups, scholars, public intellectuals, journalists, and media personalities abroad while promoting the Hungarian government’s culturally conservative and sovereigntist vision and policies. This track of international alliance-building became particularly prominent towards the US after the first meeting of Orban and Trump in 2019. Previously, the Hungarian government relied on the efforts of Hungarian organisations based in the US, such as the Hungary Foundation and diaspora organisations, as well as paid and registered American lobbyists, such as Connie Mack and David Reaboi, and various lobby organisations.
Once Fidesz found its counterparts on the right wing of the Republican party in the early 2020s, a new influence-building strategy emerged, including a new set of actors. This new circle of organisations most prominently include the Danube Institute and the Center for Fundamental Rights. The Danube Institute, established by the Lajos Batthyany Foundation in 2013 as a conservative, economically liberal, and Atlanticist organisation, provided fellowships for American right-wing and alt-right personalities such as Rod Dreher, Christopher F. Rufo, Michael O’Shea, and many others. As visiting researchers, they studied and, in their writings, promoted the Hungarian government’s views and practice in the US, for example in areas such as family policy.
The Danube Institute also established cooperation with The Heritage Foundation. In 2023, it committed to the joint organisation of an annual geopolitical conference and to hosting visiting researchers from The Heritage Foundation to study Hungarian policies in various fields. Through cooperation with right-wing intellectuals abroad, the Danube Institute has proved instrumental in promoting the culturally conservative vision of Orban’s Hungary.
The Center for Fundamental Rights, also established in 2013 as an institute focusing on political and legal analysis, pursues an agenda in support of the Hungarian government’s views. Its self-proclaimed goal is to counter political correctness and what it refers to as human rights fundamentalism. The institute also has established connections with The Heritage Foundation and organised the first European spin-off of the Conservative Political Action Conference (CPAC) in Hungary in 2022. Since then, CPAC Hungary has provided an annual platform for the networking of Hungarian, American, and European figures of the far-right, as well as an opportunity for the international diffusion and amplification of their policy and political platforms. The Center for Fundamental Rights played a key role in establishing connections also in political circles through frequent visits by its staff to the US.
From the Hungarian perspective, this strategy has indeed delivered a strong American connection in recent years. It is not only the Hungarian prime minister who promotes the country as “a conservative island”. Kevin Roberts, the president of The Heritage Foundation and the man behind Project 2025, had already in 2022 spoken of the country not only as a model of conservative statecraft, but as the model. In May 2024, Heritage even welcomed Orban for a closed-door lecture in Washington, DC.
Towards an Orbanised America
“I think Orban made smart decisions that we could learn from in the US.” – Republican vice-presidential candidate J.D. Vance, CBS Face the Nation, June 2024.
Orban has shown how to use institutional reform, the regulation of civil society, and the power of the state to gradually erode the essence of liberal democracy and build an electoral autocracy. The US context, however, is vastly different from that in Hungary. So how might the Hungarian experience translate in the US context?
One important distinction between the US and Hungary is that the American president faces an independent legislature and a strong judiciary. Even if the president’s party controls Congress, he does not exercise anything approaching parliamentary control of the legislature, nor is he is likely to have a “constitutional majority”, which in the US requires not only two-thirds control of Congress, but also control of three-quarters of the state legislatures.
The US route to electoral autocracy therefore means, in the first instance, creating a powerful executive that can overwhelm the other branches. Since at least the Reagan administration, various Republican thinkers have been promoting unitary executive theory. According to proponents of this idea, the power of the presidency has been unconstitutionally hobbled by limits placed by the courts, Congress, and the civil service rules on the president’s ability to control the executive branch. As a result, the president no longer controls his own branch of government and cannot implement the mandate the voters have given him. The unitary executive project therefore is to restore control of the executive branch to the president.
The issue of whether unitary executive theory conforms with the US constitution is a very controversial one, but the likely effects of its implementation on governance in the US are fairly clear. Over recent decades, power in Washington has flowed increasingly to the executive branch. A divided and understaffed Congress struggles to exercise its oversight function effectively over the vast executive branch. The courts are similarly too slow and lacking in administrative capacity to constrain the president on most issues. The 2024 Supreme Court decision in Trump v the United States, which asserted that the president enjoys near-total immunity in his official acts, has given the president yet more power relative to Congress and the courts.
Arguably, the principal source of checks and balances in Washington now resides within the executive branch. Independent agencies such as the Federal Communications Commission and the Federal Trade Commission, technical agencies such as the Food and Drug Administration and the Environmental Protection Agency, and specially chartered institutions such as the Federal Reserve and the Justice Department’s special prosecutors, all to varying degrees escape direct presidential authority.
The unitary executive project would recover the president’s power to control the executive branch, thus cementing his control over governance generally. This resonates with the Hungarian experience, which demonstrates that strong control of the government’s executive functions is the key to being able to eventually establish control over the broader institutions of governance and civil society.
But increasing executive branch power does not come naturally to the Republican Party, which has long preached an ethic of small government and individual freedom. Here, the Hungarian example has been instructive. As one pro-regime Hungarian interlocutor put it to us, “we have showed the Republicans how you can use the power of the state” to accomplish policy goals and break the power of liberal ideology on civil society.[2]
The message appears to have been received. In a video on his campaign website that echoes the claims of unitary executive theorists, Trump vowed to bring the independent agencies “under presidential authority, as the Constitution demands.” As Russell Vought, Trump’s former budget director and the policy director of the Republican platform committee explained, “what we’re trying to do is identify the pockets of independence and seize them.” Even the Federal Reserve Board, which sets US monetary policy and is arguably the crown jewel of Washington’s independent agencies, is not exempt.
But, of course, Trump’s most important effort to achieve stronger executive control will probably involve the Justice Department. The president appoints the 93 US attorneys, the regional Justice Department officials who act as the chief federal prosecutor within their geographic jurisdiction. Traditionally, US presidents have not interfered in prosecution decisions by the US attorneys. But Trump has explicitly said that he might fire US attorneys who refuse to prosecute on his orders. This implies that, should he return to office, the presidential authority could extend to determining whether to prosecute.
Additionally, Trump has often threatened to use this power against his political opponents, including President Joe Biden and his family. Trump’s message in this regard so blatant that he often capitalises it. “WHEN I WIN [the 2024 presidential election],” he warned on Truth Social in September 2024, “those people that CHEATED will be prosecuted to the fullest extent of the Law, which will include long term prison sentences. … Those involved in unscrupulous behavior will be sought out, caught, and prosecuted at levels, unfortunately, never seen before in our Country.”
It is not an idle threat. The Supreme Court’s decision in Trump v the United States confirms that the president has the power to make these decisions and that no court can question his motives for doing so.
The importance of personnel
The most important step for taking control of the executive branch is personnel. The federal government is a large and unwieldy ship that any administration struggles to turn, and turn to its purposes. The Trump administration that took office in 2017 appeared to struggle even more than most to bend the US government bureaucracy to its will. Their struggles resulted, in part, because they had not expected to win and had not undertaken the extensive transition preparation that most incoming administrations do. (Trump fired the entire leadership of his transition team, including its head, New Jersey governor Chris Christie, two days after the 2016 election.) Trump administration veterans believe, however, that their challenges stemmed less from a lack of preparation than from a lack of suitable personnel.
In the US, there are two parts to this problem. The first part involves disloyal political appointees. Because Trump had not expected to govern in 2017, his transition team had not identified and vetted many potential candidates to take up the more than 4,000 political appointments that a president needs to make to the executive branch. In a host of areas, including for some very senior positions such as secretary of defence, the Trump team was forced to select from among the traditional Republican elite. These people often did not carry out his orders, such as to withdraw from NATO or to use the military to disperse Black Lives Matter demonstrators. Some resigned in protest at key moments, others actively undermined his agenda from the inside.
The second part is the civil service, which former Trump officials believe is infused with liberal bias. As one member of the Project 2025 team noted to us, federal civil servants nearly all live in Washington, DC and its surrounding suburbs, an area that votes over 90 per cent for Democratic candidates. It follows from simple math that the overwhelming majority of federal workers vote for the Democrats.[3] To prove this point, Trump’s former secretary of the interior, David Bernhardt, wrote a book, “You Report to Me”, to document in exhaustive detail “how unaccountable power has been concentrated deep within the administrative state.”
The Trump administration had identified and begun to deal with these problems even before the end of its term in 2021. Two weeks before the 2020 election, Trump’s team promulgated what seemed at the time an arcane reform of the civil service in an executive order laboriously titled “Creating Schedule F in the Excepted Service”. The Schedule F reform would have given the president the power to fire approximately 50,000 civil servants across the federal government who occupied positions deemed linked to policymaking.
That period also provides clues to Trump’s plan for dealing with disloyal political appointees. In the days following the 2020 election, as part of his efforts to claim he had won, Trump ordered his administration to begin implementing his second-term plan. This revealed his intention to install loyalists in key positions in various department and agencies, particularly the Defence Department, the intelligence community, and the Justice Department, to better control his own government.
After Trump left office in January 2021 and Biden immediately rescinded Schedule F, nothing much came of these efforts. But the broader Republican ecosystem has used the period since then to refine and widen these plans. Trump himself has promised that his next term “will demolish the deep state” and “throw off the sick political class that hates our country.”
At the same time, a new Trump administration would not necessarily need to fire tens of thousands of civil servants. It would simply need to demonstrate that it could and would – and then most of the existing civil servants would fall in line. “The mere mention of Schedule F,” says Vought, “ensures that the bureaucracy moves in your direction.”
To ensure more loyal political appointees, Heritage’s Project 2025 has created a database of some 20,000 pre-vetted potential officials. The Trump campaign has strongly repudiated Project 2025, but it will likely value that database nonetheless if Trump wins the election. There is simply no place else to go for so many loyal officials.
Dealing with Congress
Another lesson from the Hungarian experience is the importance of reining in other governmental power centres beyond the executive. As noted, in the US, unlike Hungary, the first and most important element in this effort is to bring the legislature to heel. Broadly speaking, the US Congress has two sources of leverage vis-à-vis the executive: the power to set the budget and the power to confirm appointees. Even as the Republican Party works to assure a compliant Republican majority in Congress, a future Trump administration would likely challenge each of these sources of leverage.
On the budget, the Trump administration would likely revive a practice known as impounding funds in which the president refuses to spend money that Congress appropriates. “I will use the President’s long-recognized impoundment power,” Trump declared in a campaign video, “to squeeze the federal bureaucracy for massive savings.”
His administration would also likely expand the president’s power to redirect funds appropriated by Congress to the president’s priorities. In 2020, after Congress blocked funding to build a wall along the southern border, the Trump administration simply redirected hundreds of millions of dollars from Pentagon spending in Europe. Various members of Congress expressed frustration, but Congress as an institution lacked sufficient unity to reverse the decision. There is little reason to believe the situation would be any different in a second term in which Republicans held a majority in at least one house of Congress. If the executive can not only refrain from spending money that Congress has appropriated but also redirect funding to priorities Congress chose not to finance, it raises questions about Congress’s actual budgetary authority.
The Trump administration also pioneered some novel ways around the requirement that the US Senate must confirm all senior political appointees to the executive branch. During his term, Trump often left key positions vacant across the federal government. In the Justice Department, for example, according to a report from the Brookings Institution and the Partnership for Public Service, Trump left 31 per cent of Senate-confirmed positions continuously vacant, with 55 per cent still unfilled by late 2020.
Beyond the sheer number of vacancies, the Trump administration also made much greater use than any previous administration of “acting” officials, officials supposedly in post temporarily while awaiting confirmation or replacement. “I sort of like ‘acting’”, Trump explained in 2019. “It gives me more flexibility; … I like ‘acting.’” Trump further demonstrated a willingness to put into place officials that the Senate had already rejected, including Ken Cucinelli, who became acting deputy secretary of homeland security, and Anthony Tata, who became “the official performing the duties of under-secretary of defence for Policy,” avoiding even the fairly loose rules that regulate acting appointments.
This expansive use of vacancies, actings, and “officials performing the duties” would seem to seriously erode the Senate’s capacity to exercise leverage on the executive branch. But, again, political polarisation meant that the Senate lacked the unity to raise any formal objection to these practices during Trump’s term. There is every reason to believe that they would continue and expand if he was re-elected, particularly if the Republicans control the Senate.
The judiciary
In both Hungary and the US, the judiciary is an important potential check that could prevent democracy sinking into electoral autocracy. As noted above, in Hungary, establishing effective control of the judiciary was a key early arena in Orban’s efforts to consolidate control over the country. In the US, which has a very powerful judiciary, that struggle has been under way for quite some time. Since at least the 1990s, both parties have made appointing “friendly” judges a priority when they hold the White House; by and large, judges have proven true to their ideological affiliations. The Republicans, however, have been more successful, particularly at the Supreme Court and Appeals Court levels where they hold majorities, despite only having held for the presidency for 12 of the last 32 years.
Beyond continuing the strategy of republicanisation of the judiciary, a future Trump administration’s plans for consolidating control of the judicial branch remain vague. Trump has frequently engaged in personal attacks against judges for rulings he disagrees with, which might serve to delegitimise court decisions and intimidate some judges. Although Trump has expressed his willingness to comply with court orders, ignoring the courts remains a possibility. His running mate, J.D. Vance, is less circumspect. “When the courts stop you,” he told a podcast in 2021, “stand before the country like Andrew Jackson did and say, ‘the chief justice has made his ruling. Now let him enforce it.’” In fact, unlike in Hungary where the EU can exercise leverage over the government, in the US there is little power by any actor to prevent open defiance of judicial authorities by the executive.
The electoral law
The Hungarian example demonstrates that, as executive power increases, elections become much more consequential. In the US, the growing power of the presidency has inspired increasing efforts by both parties to tilt or even rig the electoral rules through mechanisms such as redistricting, voter registration drives, restricting voter access, media fairness doctrines, campaign finance laws, and multiple other mechanisms. Of course, these efforts have long existed and many of them are perfectly legal and legitimate.
But the looming threat of electoral autocracy has increased the stakes. Trump’s efforts to overturn the 2020 election and – to date – the failure to hold him to account for those actions has broadened controversies over issues of voter fraud, procedures for counting ballots, election certification, and the power of state legislatures to use fraud accusations to overturn election results. Republicans under Trump have, in the manner of Fidesz, stoked the false narrative that US elections are rife with fraud, which justifies efforts to change rules and take extraordinary measures after election day to “ensure free and fair elections”.
In the US, much of this manipulation happens at the state level because the states administer the election for the federal office. (The US presidential election is effectively over 50 separate elections.) The results of the 2022 midterm elections put the government of most of the swing states in Democratic or mixed hands (that is, one party controls the legislature, the other the governorship), which limits the ability of the Republicans to impose new electoral laws. The only exception is Georgia, where Republicans are currently engaged in an effort to give themselves the power to delay or even overturn election results based on their views of possible fraud.
The Georgia effort prefigures what Republicans and Trump himself have signalled to be a comprehensive push to reform the electoral law if they were to win the presidency. In 2022 and 2023, for example, Congressional Republicans introduced the American Confidence in Elections Act, which included a broad package of election reforms based on the idea of widespread voter fraud, including concerns over voting by immigrants. It includes mechanisms for purging the voter rolls of individuals deemed suspicious, limiting voter registration and access, and undercutting the impartiality of election administration. It would also further loosen campaign finance rules to allow larger and less transparent donations.
Media and non-governmental organisations
One new area of contestation for a Trump administration could be an effort to regulate the media and non-government organisations. Trump, along with many other Republicans, have consistently alleged that the media is hopelessly biased and even corruptly prejudiced against him. To cite just one example of thousands, Trump claimed without citing any evidence that ABC, the television network hosting his first presidential debate with Vice-President Kamala Harris, leaked the debate questions to her in advance. Over time, this anti-media discourse has had an effect. Trust in the media is at an all-time low among Americans and especially Republicans. Other institutions of civil society such as schools and the criminal justice system have similar image problems.
These attacks have laid the groundwork to undermine the media and civil society. Taking a page from Orban’s playbook, a Trump administration would likely not resort to heavy-handed tactics, such as shuttering newspapers and sending journalists to prison. Rather, it would use federal regulatory mechanisms, including the Federal Communications Commission and the Justice Department, and the Internal Revenue Service, to break up the “liberal hegemony” over civil society, unironically adopting the supposed liberal playbook of using the administrative state to enforce ideological conformity. This might involve new uses of fairness doctrines to shape media content and new criteria for determining the non-profit status of NGOs, which is relevant for tax exemption purposes. Any think-tank, for example, that lost its non-profit status would almost certainly go out of business. Similarly, the government could make use of the existing Foreign Agents Registration Act, which gives prosecutors broad discretion to criminalise any sort of foreign support of or even foreign contact with NGOs and think-tanks. Meanwhile, new, more ideologically compliant think-tanks would find the regulatory landscape far easier to navigate.
A new Trump administration might further emulate Hungary by starting up its own compliant branches of the media and civil society. Through the strategic use of government contracts and advertising budgets, and by enlisting friendly businessmen to buy up struggling media outlets, the US government could easily tilt the media playing field. Elon Musk’s purchase of Twitter (now X) is a model in this regard. Trump certainly has plenty of other billionaire friends who might be willing to play similar roles if he retook the presidency.
States of emergency
A new Trump administration may use a trying moment to declare a state of emergency in a similar manner as Orban did in response to the covid-19 crisis. Georgetown law professor David Cole has documented, in the context of the war on terror in the early 2000s, how states of emergency have often been used throughout American history to permanently increase the power of the government.
Trump is already aware of the possibilities. During the Black Lives Matter protest in 2020, many in his administration advocated invoking the Insurrection Act, which would have allowed the president to deploy the US military to disperse protesters and restore order. Other administration officials, particularly in the military itself, opposed that suggestion because they disliked the idea of the military getting involved in domestic political disputes. In the end, they managed to get Trump to pull back from using the Insurrection Act, although the military’s top office, General Milley, did make an appearance in Lafayette Square as the police cleared the protesters. But the incident demonstrated that there are few institutional restraints on the president claiming such authority in a crisis situation, including a crisis of his own making.
A similar scenario could play out in a second Trump term if mass protests erupted in US cities, perhaps in response to some of the other measures described above to consolidate presidential authority. In an administration with more compliant and loyal personnel, it is hard to imagine voices raising in opposition to using the Insurrection Act to rid the administration of troublesome protesters. However, once the state of emergency is declared and the military is on the streets, the executive will fear that ending the emergency and return the military to barracks will simply occasion more protests and greater unrest. The result is that the emergency extends indefinitely, as it has for the last several years in Hungary.
What Orbanisation means for US foreign policy
“I have an Article II, where I have the right to do whatever I want as president.” – Donald Trump, speech to Turning Point USA, 23 July 2019.
Trump has had an expansive view of the presidency at least since 2019. That view grafts easily onto the idea of the unitary executive that has been kicking around the Republican Party for decades. During his term in office, however, Trump and his inner circle often felt stymied by what they saw as disloyal political appointees and an intransigent civil service imbued with partisan bias.
In the intervening four years, Trump and various former Trump administration officials have proposed a “war on the administrative state” as well as various efforts, documented above, to combat this problem and to clear the obstacles to an all-powerful executive. In this effort, the Hungarian experience, despite the very different context, has been instructive. Republican circles have formed strong ties to the Hungarian government and to pro-regime Hungarian intellectuals. They have imparted many important lessons from their experience in creating an electoral autocracy, particularly through demonstrating ways to capture the administrative state and use its power to strengthen the government.
None of these developments augurs well for the health of democracy in America if Trump is re-elected. But from a European perspective, the more immediate question is what effect the Orbanisation of America would have on US foreign policy, particularly towards Europe.
The first implication is that a Trump administration that had successfully installed loyal political appointees, tamed the administrative state, and rendered Congress nearly powerless would face very few internal constraints on its foreign policy actions. In other words, the adults will have left the room and the guardrails will be gone. Moreover, the US, unlike Hungary, also faces few external constraints. The US government will not fear that Brussels will withhold cohesion funds or initiate infringement or rule of law conditionality procedures against it, as the Hungarian government must.
But this situation does beg the question of what a re-elected President Trump would do with that new freedom in foreign policy. Beyond his implementation difficulties, Trump lacked consistency in foreign policy as president. He often got distracted by shiny objects and enchanted by whatever the last adviser or Fox New commentator told him. For example, one day he would fail to retaliate for an Iranian attack on the most important energy infrastructure in Saudi Arabia, and the next he would approve the assassination of the head of the Iranian Revolutionary Guard Corps.
Nonetheless, there are some issues on which Trump has had a consistent approach dating back many years, principally when it comes to the holy trinity of trade, immigration, and alliances. Trump has demonstrated a consistent antipathy to every member of the trinity for decades. We should imagine that a Trump-led electoral autocracy will succeed in implementing massive across-the-board tariffs, severely restrict immigration, and reduce the US commitment to allies and alliances.
On trade, Europeans should thus take seriously the Trump campaign’s announced intention to implement a 20 per cent tariff nearly across the board. More speculatively, Trump’s antipathy towards climate policy and his apparent fondness for the traditional energy industry raises the possibility of a fossil fuel-based version of the Biden administration’s Inflation Reduction Act, offering subsidies for US energy production to encourage industrial advantage. Such a policy could create substantial de-industrialisation in Europe.
Trump’s dislike of standing alliances may not necessarily result in the US pulling out of NATO, but it will certainly undermine the confidence among both rivals and friends on the US commitment to defending its NATO allies in times of crisis. But that is the only purpose of the NATO alliance so, at that point, the United States’ formal membership of NATO might become a technicality
One reason that Trump does not like permanent alliances is that he seems to feel that they restrict US freedom to manoeuvre and negotiate more advantageous deals with a wider variety of partners. This aversion to constraints has parallels with Orban’s foreign policy. His government has sought to extend Hungary’s ties beyond, and often at the detriment of, its EU and NATO membership. This began with the idea of an “eastern opening” toward China and Russia, and has expanded more recently to the broader concept of “connectivity” that critiques the emergence of blocs in the world.
During his first term, Trump reflected this promiscuous approach to alliances in his outreach to North Korea and his frequent willingness to talk nice to dictators around the world. If re-elected, a less constrained Trump is likely to exercise his predilection to make transactional deals with strongmen rather than engage in the long, bureaucratic process of alliance decision-making. This implies that he will, for example, seek a deal with Vladimir Putin over Ukraine and perhaps even a deal with Xi Jinping over Taiwan.
Trump’s penchant for forging discrete deals with individual partners may have an even more profound effect in Europe. The strong ties that the Trumpian ecosystem has built up with Hungary and, to a lesser extent, other European populist forces in Austria, Italy, Poland, Slovakia and elsewhere could easily shape internal EU politics. A new Trump administration might be willing to back them in their intra-EU struggles or help out in their individual challenges. In exchange, these forces could use their influence in the Council to, say, reduce retaliation from the EU against his trade policies or for increasing fossil fuel and weapons purchases from the US.
European populist leaders with a champion in the White House will feel vindicated and have vastly more leverage in their dealings with Brussels and the more traditional leaders of the EU. The central US role in European security, coupled with Trump’s demonstrated willingness to instrumentalise it, means that the EU could face enormous costs for defying the US president.
And, of course, European populist leaders have a long list of problems with the EU on which they would like the help of the president of the US. They might like to slow down the EU’s fossil fuel phase-out, block the implementation of the European Asylum and Migration Pact adopted in April 2024, or avoid the financial penalties for violating the pact. They also want stricter EU enforcement of border controls and to drastically reduce the cap for new asylum seekers.
Much of this is speculative, of course – not least because Trump may well fail in his re-election bid. But a few points shine through this haze of what-ifs. Hungary has provided a roadmap to electoral autocracy. Republicans in the US have indeed learned from it and adapted it to the US context. Despite America’s much longer democratic history and more established institutions, a second Trump administration has the necessary ideas and levers to substantially “Orbanise” America over another four-year term. They know how to create a nearly all-powerful presidency that could overwhelm Congress, dominate the media and civil society, and substantially intimidate the judiciary. These developments would obviously have negative effects domestically. But, given the central place of the US in European security and economic affairs, they might be equally damaging to European governance and the future of the EU as a democratic project.
About the authors
Jeremy Shapiro is director of research at the European Council on Foreign Relations and a non-resident senior fellow at the Brookings Institution. He served at the US State Department between 2009-2013.
Zsuzsanna Vegh is an associate researcher at the European Council on Foreign Relations.
Acknowledgments
This paper results from the kind of cultural interchange that makes ECFR such a special place. In this case, that means that a Hungarian and an American sat around Berlin cafés, drinking espresso, and kvetching about their respective domestic politics for so long that they started to realise they had similar problems. They also discovered that, for the first time in many years, ideas about political change seem to be flowing from central Europe to the US, rather than the other way around. This seemed to us to be an important development, even if not a salutary one.
The authors would like to thank the many European, American, and Hungarian officials and thinkers who helped them refine their ideas, but who mostly wish to remain anonymous. We owe a huge debt of gratitude to Célia Belin, Majda Ruge, Mark Leonard, and Chris Herrmann for helping us refine our ideas and for supporting us in the process. And we also want to thank Taisa Sganzerla and Adam Harrison for their brilliant editing and limitless patience with Hungarian spellings. Any errors in the text, however, remain the fault of a lack of coffee.
[1] Anonymous Polish politician, conversation with ECFR, Warsaw, September 2023.
[2] Anonymous Hungarian think-tanker, conversation with author (Shapiro), Washington, DC, July 2024.
[3] Anonymous Project 2025 official, interview with author (Shapiro), Washington, DC, November 2023.
The European Council on Foreign Relations does not take collective positions. ECFR publications only represent the views of their individual authors.
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