Abstract
The article examines the key issues of legal regulation of options in the civil law of the Republic of Kazakhstan and in common law countries. The author analyzes the provisions of the Civil Code of Kazakhstan, which limit the use of option agreements to the field of derivative financial instruments. Particular attention is paid to foreign practice, where options are widely used in lease agreements, real estate sales contracts, and ship chartering. In common law jurisdictions, options are studied through the concepts of irrevocable offer, consideration, and the distinction between unilateral and bilateral contracts. Doctrinal and practical approaches, including court precedents from England, Canada, and the United States, are discussed. The author concludes that it is necessary to expand the scope of option agreements in Kazakhstani legislation to ensure more flexible and effective protection of the parties’ interests. Keywords: option, contract law, civil legislation, Civil Code of Kazakhstan, common law, irrevocable offer, consideration, unilateral contract, court precedent, comparative legal analysis