Diverging paths, converging goals: A comparative analysis of special educational needs (SEN) policy trajectories in Malaysia and Hungary

Abstract This comparative study examines the evolution, implementation, and outcomes of Special Educational Needs (SEN) policies in Malaysia and Hungary, two countries with distinct historical, cultural, and political contexts but shared commitments to inclusive education. Drawing on documentary analysis and secondary data, the paper explores how global discourses such as the Salamanca Statement and the UN Convention on the Rights of Persons with Disabilities (CRPD) have influenced national policy trajectories. Findings reveal that while Hungary, influenced by European Union frameworks, has undergone systemic reforms to shift from segregation to inclusion, it continues to grapple with ethnic overrepresentation and institutional inertia. Malaysia, navigating postcolonial and multi-ethnic dynamics, demonstrates policy ambition toward mainstreaming, while Hungary, shaped by post-socialist transition and EU integration, pursues systemic reform toward inclusion. Both nations face persistent challenges in infrastructure, teacher capacity, rural provision, and deep-rooted institutional practices though manifested through different mechanisms: ethnic overrepresentation and segregation in Hungary, and urban-rural disparities and resource limitations in Malaysia. Through the lens of policy borrowing and institutional isomorphism, the study argues that superficial policy convergence often masks deep-rooted implementation gaps shaped by local socio-political realities. This research contributes to comparative education by demonstrating how divergent historical and institutional paths in Malaysia and Hungary have led to convergent policy adoption under global norms, yet have resulted in divergent implementation realities shaped by distinct socio-political contexts.