LEGAL CHALLENGES OF DIGITAL INHERITANCE IN KAZAKHSTAN:A COMPARATIVE ANALYSIS OF EUROPEAN AND U.S. APPROACHES

Abstract

The rapid digitalization of social and economic relations has led to the emergence of new forms of property and personal data that remain insufficiently regulated within inheritance law. The purpose of this study is to examine the legal challenges associated with digital inheritance in the Republic of Kazakhstan through a comparative analysis of European and U.S. approaches. The research is based on comparative legal, formal legal, doctrinal, and systematic methods and relies on the legislation of Kazakhstan, the European Union, and the United States, as well as contemporary scholarly literature. The originality of the study lies in the development of proposals aimed at improving the legal framework governing digital succession in Kazakhstan. The findings demonstrate that the current legislation lacks comprehensive regulation of digital assets and post-mortem access to digital accounts. The study substantiates the necessity of introducing legal mechanisms for digital inheritance and incorporating selected foreign practices into national legislation.