A Comparative Law Analysis of Social Security and Insurance Against Occupational Accidents

İngilizce (OpenAlex)

This study examines the trends towards updating the legislation on compulsory social insurance against occupational accidents in the Republic of Kazakhstan from a comparative perspective. The analysis is carried out on the axis of the necessity of harmonization of insurance norms within the European Union (EU) and the transposition of International Labour Organization (ILO) standards into national law. In the study, the current insurance system in Kazakhstan was compared with the occupational accident and occupational disease insurance models applied in the Russian Federation, the European Union and Turkey. As a result of the examination, it was determined that the systems in Kazakhstan, Russia and Turkey were mainly compensation-oriented; on the other hand, it has been determined that prevention, risk management and rehabilitation functions have a more institutionalized structure in the European Union. Within the scope of the research, terminological inconsistencies and normative contradictions in Kazakhstan legislation were identified; the harmonization of national regulations with ILO standards and the legal infrastructure for the establishment of a common insurance area within the EU were evaluated. The scientific and practical contribution of the study is that it proposes a holistic approach that addresses the compensation, rehabilitation and prevention functions of insurance together. In conclusion, the article provides concrete legislative development recommendations based on comparative law findings, aiming to harmonize Kazakhstan's international obligations with national social protection priorities.