Аннотация
This article aims to support recommendations for modernizing Kazakhstan’s air quality management system by comparing the institutional frameworks of the EU, UK, Canada, and the USA. It uses interdisciplinary methods, including analysis of legal frameworks, monitoring systems, and tools like cap-and-trade. The study finds that European approaches, such as clean air zones and BAT standards, enhance transparency and reduce mortality, while North American models foster coordination and innovation. In contrast, Kazakhstan lags in setting effective standards, monitoring emissions, and involving the public in environmental efforts. Although Kazakhstan’s AQM system is based on the 2021 Environmental Code and Kazhydromet data, it faces challenges in coverage and coordination. Recommendations include stricter standards, digital monitoring, low-emission zones in industrial cities, and economic incentives to support modernization and reduce pollution.