Foreign experience of environmental ombudsman institution implementation: comparative analysis

The article analyses the history of the development and formation of the environmental ombudsman institution architecture in global practice as a mechanism for protecting the ecological rights of individuals and citizens. It characterises various models of the environmental ombudsman institution using examples from New Zealand, Austria, Canada, and Hungary. The necessity of developing a scientific concept for the ecological ombudsman institution’s functioning in the state is substantiated. This study employs a comparative method to analyse the institutional development of environmental ombudspersons in four different jurisdictions: New Zealand, Austria, Canada, and Hungary. A systematic method evaluates the effectiveness of this institution in implementing the state’s environmental policy, and a historical method highlights specific stages in establishing the ecological ombudsman institution worldwide. The research base includes scientific works, legal acts, official documents, and websites concerning environmental policies in New Zealand, Austria, Canada, and Hungary regarding the activities of ecological ombudsmen. The article identifies four models of environmental ombudspersons. The Parliamentary Commissioner for the Environment in New Zealand is an independent official accountable to the parliament. Key institutional powers include evaluating state ecological policies, conducting extensive investigations, advising the parliament on environmental legislation, focusing on sustainable development, and utilizing comprehensive reporting mechanisms. Decentralisation, participatory approaches, transparent procedures for citizen appeals, and integration with federal ecological protection systems characterize the Austrian model. The Canadian model represents a unique approach to ecological oversight through integration into existing governmental audit structures. Hungary’s environmental ombudsman is part of a broader human rights ombudsman structure, focusing on environmental justice and addressing ecological inequality while ensuring a connection between the environment, the interests of future generations, and fundamental constitutional rights.