Combating Cyberbullying Among Children: A Comparative Legal Analysis of Kyrgyzstan and Kazakhstan

The paper compares legal mechanisms addressing child cyberbullying in Kyrgyzstan (KG) and Kazakhstan (KZ). Using doctrinal and comparative methods, we analyze statutes, regulations, and institutional practices, along with recent survey evidence on prevalence, reporting behavior, and institutional trust. KZ has established a comprehensive framework: it defines bullying and cyberbullying, imposes administrative liability (including parental liability for minors), strengthens criminal penalties for sustained harassment, implements a rapid content takedown procedure, and mandates school prevention programs with helpline support. KG relies on general protections of honor, dignity, and health; has recently reintroduced administrative fines for online insults and defamation; and issues ministry guidelines on school prevention, but lacks a specific legal definition or unified protocol. We find low trust in school remedies and underreporting in both countries, especially KG, while KZ’s new measures improve visibility and early responses but raise implementation issues (e.g., proof of “systematic” conduct, due-process safeguards for removal, tailored measures for child offenders). Both systems require a balanced mix of sanctions, prevention, and support. We recommend that Kyrgyzstan codify clear definitions and enforcement procedures, and that Kazakhstan refine enforcement, transparency, and restorative options.