Comparative analysis of barriers and opportunities for inclusive education in Ukraine and the U.S.

This study comparatively examines how inclusive education is conceptualised, regulated, and implemented in Ukraine and the United States. It employs comparative qualitative content analysis of a primary corpus of 17 national and international legislative, regulatory, and policy documents, interpreted through contextual scholarly literature. The analysis is organised around five shared dimensions: conceptualizations of inclusion and educational need; legislative and policy traditions; funding, access, and implementation capacity; intersectional barriers; and responses to emerging social and educational challenges. The findings show that the U.S. framework provides enforceable disability-related entitlements but regulates access primarily through eligibility and the least restrictive environment rather than a statutory requirement for inclusion. Access also varies by race, socioeconomic position, disability category, and support intensity. Ukrainian reforms increasingly adopt rights-based and system-transformative principles influenced by international frameworks, although implementation remains constrained by unequal resources and war-related disruption. Importantly, wartime commitments to inclusion have been retained while attention has widened beyond disability categories to learners affected by displacement, trauma, and interrupted schooling. The comparison demonstrates that meaningful inclusion requires combining enforceable rights with institutional adaptability to changing and intersectional forms of educational vulnerability.