INTERNATIONAL LAW AND COMPARATIVE LEGAL STUDIES

Comparative Legal Analysis of Legislation on Lotteries and Lottery Activities in the Republic of Kazakhstan and the United Kingdom

Abstract

The purpose of this study is to conduct a comparative legal analysis of the key provisions regulating lottery activities in the Republic of Kazakhstan and the United Kingdom. The methodological framework of the research is based on general scientific and specialized legal methods, including the comparative legal method and the formal legal method. The analysis reveals fundamental differences in the approaches to the legal regulation of lottery activities in the two countries. The Republic of Kazakhstan applies a model of strict state regulation, which provides for the operation of a single operator, a limited list of permitted types of lotteries (instant and draw-based), and mandatory social contributions. In contrast, the United Kingdom employs a licensing model that allows the participation of commercial organizations, with a detailed statutory definition of a lottery and its types (simple and complex), as well as an emphasis on ensuring the random nature of processes. The identified differences are determined by the specific features of each country’s public policy in the field of gambling regulation and the protection of public interests. The Kazakhstani model is based on enhanced state control, whereas the British model is founded on a balance between entrepreneurial freedom and state supervision. The comparative analysis makes it possible to assess the advantages and limitations of each approach, as well as to identify potential directions for improving national legislation. It has been established that the legislation of Kazakhstan contains more imperative and detailed procedural requirements for conducting lotteries, including the mandatory establishment of draw commissions and the publication of draw results. In turn, British legislation is primarily focused on establishing prohibitions and licensing requirements governing the activities of lottery organizers and operators. The practical significance of the study lies in the possibility of using the identified foreign legal mechanisms to improve the legislation of the Republic of Kazakhstan, particularly in terms of regulating the licensing of lottery activities, clarifying the concept of a lottery, and differentiating measures of legal liability.