In preparation for the 53rd Session of the Universal Periodic Review (UPR) Working Group, scheduled for October–November 2026, CAP Liberté de Conscience (CAP LC) has submitted a report addressing the state of Freedom of Religion or Belief (FoRB) in Hungary. The submission, titled “The Weaponization of Data Protection Laws to Violate Freedom of Religion or Belief,” examines the administrative and legal measures employed by the Hungarian state that disproportionately affect minority religious communities, with a specific focus on the Church of Scientology.
The document highlights a concerning trend where general data protection regulations are allegedly utilized to obstruct religious practice. Central to this submission is the decision by the Hungarian Data Protection Authority (NAIH) to order the total destruction of religious records held by the Church of Scientology. This measure, which was recently upheld by the Metropolitan Court of Budapest in January 2026, mandates the destruction of hundreds of parishioner files. According to CAP LC, these files contain notes from “auditing,” a spiritual counseling practice central to Scientology, and their destruction would effectively erase the religious history and spiritual progress of the community.
The submission argues that this order is manifestly disproportionate. The NAIH contended that identifying potential “third-party” data within the files was too burdensome, leading to the conclusion that total destruction was the only viable solution. However, this administrative difficulty stands in contrast to the findings of the National Bureau of Investigation (NNI). The NNI conducted an extensive criminal investigation into the Church’s data practices, including a raid in 2017, which concluded in September 2025 without finding a single instance of wrongdoing or data abuse. Despite the lack of criminal evidence, the seized files were transferred to the NAIH rather than returned to the religious community.
CAP LC further raises concerns regarding due process and the rights of the data subjects. Throughout the proceedings, the actual parishioners—whose spiritual progress depends on these records—were reportedly denied the opportunity to testify or intervene. The submission notes that the State’s interpretation of data protection law effectively ignores the fundamental rights of the individuals involved, treating sacred religious communications as mere data to be expunged.
This case is presented within the broader context of Hungary’s 2011 Church Law (Act CCVI), which restructured the recognition of religious organizations into a four-tiered system. The report cites public statements by Deputy Prime Minister Zsolt Semjen, who reportedly acknowledged that the legislative framework was designed to prevent the recognition of specific minority groups such as the Church of Scientology. CAP LC argues that this politicization of religious recognition creates a dichotomy between “traditional” and “non-traditional” religions, resulting in asymmetric legal treatment.
The submission also references previous international interventions, including a 2018 communication from three UN Special Rapporteurs who expressed serious concerns regarding the seizure of confidential religious documents and the denial of occupancy permits. The continuity of these practices suggests that recommendations made during Hungary’s previous UPR cycle in 2021—urging the reform of discriminatory legislation and the combatting of religious intolerance—have not been implemented.
Consequently, CAP LC has formulated several recommendations for the UPR Working Group to transmit to the Government of Hungary. These include a call to immediately halt the destruction of the religious records and order the return of the seized property. The organization also recommends that Hungary amend its procedural laws to guarantee that data subjects in religious communities have legal standing to intervene in such cases. Furthermore, CAP LC urges the reform of the 2011 Church Law to establish objective and non-discriminatory criteria for religious recognition, ensuring that the state’s neutrality is maintained.
The Weaponization of Data Protection Laws to Violate Freedom of Religion or Belief
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