Pension funds in the context of globalisation: Legal regulation and challenges in countries with different pension systems

The purpose of the study was to identify key issues in the legal regulation of the pension fund of the Kyrgyz Republic and to develop proposals for their effective resolution based on the analysis of international practices in various economic systems. The study involved an analysis of legislation using the formal-legal method, a comparison of pension systems in Germany, Sweden, Chile, and Canada through the comparative method, and modelling potential development scenarios for pension legislation using legal forecasting. The main findings demonstrated that the pension system in Kyrgyzstan remains reliant on state sources, limiting its capacity to adapt to changing international financial conditions. The primary challenges in legal regulation included the lack of flexible investment mechanisms and weak control over asset management. Comparative analysis also revealed that countries with diversified pension systems, such as Germany and Canada, pension systems are more resilient due to asset diversification and the utilisation of private investment funds. In countries like Sweden and Chile, there is a growing interest in private pension savings and the implementation of digital technologies for managing pension assets, contributing to greater transparency and efficiency in pension systems. Based on the analysis of international practices, recommendations were developed to strengthen the legal regulation of the Kyrgyz pension fund, including the adoption of international standards of financial transparency and the development of mechanisms to attract private investments into pension assets. The findings indicated the necessity for modernisation of the legal regulation of pension funds in Kyrgyzstan, considering international practices to ensure resilience, transparency, and the protection of participantsʼ rights