Abstract
The rapid digitalisation of the economy and public administration under the "Digital Kazakhstan" program has been accompanied by the growing use of digital technologies by organised criminal groups, which threatens peace, justice, and strong institutions (SDG 16), as well as digital infrastructure (SDG 9). Despite growing scholarly attention, no systematic comparative analysis of Kazakhstan's cybercrime legislation against international frameworks has been conducted. This study examines the compliance of Kazakhstan's legislative and institutional system for combating cybercrime with international standards, primarily the Budapest Convention on Cybercrime, in order to identify regulatory and institutional gaps. The study employs normative legal research and a structured comparative legal analysis of Articles 272–274 of the Criminal Code of Kazakhstan against the legislation of Estonia, Poland and Turkey, using national legislation, international legal acts, official statistics of the Ministry of Internal Affairs of the Republic of Kazakhstan for 2020–2023, and peer-reviewed publications indexed in Scopus and Web of Science. The results show that registered cybercrimes increased from 2,130 in 2020 to 5,120 in 2022 (a 2.4-fold increase), cryptocurrency-related offences rose from 110 to 922, only 27% of cyber incidents are officially recorded, the share of cases reaching court fell from 34% to 27.7%, and only 18% of law enforcement officers have digital forensics training. The findings suggest that Kazakhstan's cybercrime legislation is fragmented and only partially harmonised with the Budapest Convention, particularly regarding the definition of cybercrime, organised cybercrime, cryptocurrency regulation, access to electronic evidence and international cooperation, and that its capacity for accountable and effective law enforcement remains substantially weaker than that of Estonia and Poland.