The Institution of the Commissioner for Human Rights (Ombudsman) provides non-judicial protection of citizens, acting as one of the key mechanisms for responding to unlawful actions or inaction by government agencies. The purpose of this article is to compare the practice of the ombudsmen of Kazakhstan, Sweden and Georgia and to identify foreign experience for the development of the national model of this institution. To achieve this goal, comparative legal analysis, analysis of regulations, official reports of ombudsmen and statistics of citizens' appeals were used. The results of the study showed that despite the similarity of the basic functions, the actual influence of the ombudsmen varies significantly and is determined by the scope of the mandate, the instruments of influence, the level of parliamentary participation and the degree of publicity of the activities. Based on the results of the analysis, a number of recommendations were formulated to strengthen the role of the Commissioner for Human Rights in Kazakhstan, including the development of parliamentary control over the implementation of recommendations, the use of publicity potential and the exercise of powers to appeal to the Constitutional Court, which makes it possible to increase the effectiveness of human rights activities.
