LOCAL SELF-GOVERNMENT REFORM IN KAZAKHSTAN: LESSONS FROM THE ESTONIAN MODEL AND THE SEARCH FOR FINANCIAL INDEPENDENCE

The article presents a comprehensive analysis of the formation and development of local self-government institutions (LSG) in the Republic of Kazakhstan and the Republic of Estonia. The relevance of the topic is due to the urgent need to improve the Kazakh legislation, since, despite the constitutional enshrinement of the right to LSG (Article 89), a special law regulating its organization and activities has not been adopted for decades, and the last bill was withdrawn from the Parliament in 2024. The work provides an in-depth comparative legal analysis, examines the theoretical foundations of LSG in the light of the provisions of the European Charter, the evolution of national legislation and constitutional norms on LSG in Kazakhstan. The key institutional problems of the Kazakhstan model are identified, such as the merging of public administration and self-government functions, unclear delineation of competencies, critical financial dependence of local budgets on central transfers and, as a consequence, a low level of citizen engagement. Based on the analysis of the successful Estonian experience, characterized by a high degree of autonomy, digitalization and financial decentralization, as well as on the basis of a summary of the opinions of scientists, practitioners and the results of a field study of modern self-government practices in Kazakhstan, specific proposals are formulated. The central idea is to reform the legal status of local self-government executive bodies. In particular, a conceptual solution is proposed to create local self-government executive bodies in the form of public funds of a rural or urban settlement. Such an organizational and legal form is designed to increase the financial sustainability, transparency and accountability of local self-governments, allowing for the accumulation of various sources of funding, including budget funds, private donations and grants, to effectively address issues of local importance.