Environmental Pollution Liability: A Comparative Legal Study of EU, Kazakhstan and Russia.

This article focuses on a comparative legal analysis of criminal law provisions addressing environmental offences in the European Union (EU), Kazakhstan, and the Russian Federation, highlighting differences, strengths, and limitations in their approaches. The EU has recently advanced its environmental criminal law through Directive (EU) 2024/1203 and the 2025 Council of Europe Convention on the Protection of the Environment through Criminal Law, establishing comprehensive offence categories, corporate liability, and protections for whistleblowers and environmental defenders. In contrast, Kazakhstan and Russia maintain foundational but less developed frameworks, lacking criminal liability for legal entities, clear mens rea (mental element) distinctions, and institutional protections for environmental human rights defenders. The study underscores the need for Kazakhstan and Russia to modernize their legislation by incorporating corporate criminal liability, refining offence definitions, and enhancing enforcement mechanisms to better align with evolving international standards exemplified by the EU model.