Abstract
This research paper examines the pressing issues surrounding the implementation of the right to inclusive education in Oskemen's educational landscape through an international comparative legal lens. The primary objective of the study is to propose legal mechanisms for enhancing the national inclusion model by analyzing the advanced legislative experiences of Norway, Germany, and England. The research employs comparative legal analysis, statutory interpretation, and a systems approach. The analysis validates the effectiveness of Norway’s «adapted education,» Germany’s «resource-based transformation,» and England’s «legal accountability and SEND Code» models. The author identifies key barriers in Oskemen’s schools: lack of financial transparency, low legal status of specialists, and the weak legal enforceability of individual education plans (IEPs). The scientific novelty of the study lies in the justification for adapting the English «EHC Plan» and the German «mobile support» experience to the context of Oskemen. The paper concludes with specific recommendations to elevate the status of Psychological, Medical, and Pedagogical Consultation (PMPC) reports to mandatory state contracts and to transition to a voucher-based per-capita funding system for inclusive education. The findings provide a practical contribution to improving educational legislation and protecting the rights of children with special educational needs.