Аннотация
The growing threat to environmental human rights underscores the urgency of enhancing criminal law mechanisms for the protection of the natural environment, prompting scholars and legislators to seek more effective legal responses. The examination of foreign legislative experience and best practices emerges as a critical strategy for adapting national legal frameworks to contemporary environmental challenges. Recent developments within the European Union position its regulatory model as one of the most progressive globally, offering a benchmark for jurisdictions seeking to reform their environmental legislation. This study conducts a comparative legal analysis of current criminal law provisions on environmental offences in the EU, Kazakhstan, and the Russian Federation. The objective is to identify differences, strengths, and limitations across these jurisdictions. EU legislation has undergone significant advancement in recent years, notably through the expansion and clarification of environmental crime categories, the specification of penalties, and the broadening of the scope of liability. These reforms have been codified in newly adopted supranational legal instruments, such as Directive (EU) 2024/1203. In contrast, Kazakhstan and Russia, despite possessing foundational legal frameworks, require substantial modernization. This analysis may be of interest to policymakers, environmental NGOs, and legal practitioners working at the intersection of criminal and environmental law.