Comparative legal analysis of the draft information and digital codes of the cis countries

The purpose of this study is to identify key trends and features of digital legislation in the CIS countries to develop recommendations for modernizing the Russian legal system. The methodology is based on a comparative legal analysis of regulatory documents, including the CIS Model Code, Russian concepts, as well as projects in Kazakhstan, Kyrgyzstan, and Uzbekistan. The results of the study demonstrate that all the projects considered are aimed at overcoming the fragmentation of legislation, unifying terminology, and regulating artificial intelligence, blockchain, and big data technologies. However, common shortcomings were identified: terminological inconsistency, contradictions in the norms, insufficient specification of mechanisms for protecting personal data and regulating digital assets. Particular attention is paid to conflicts of principles, such as the balance between openness of information and confidentiality. It was found that the draft information and digital codes require revision in terms of eliminating legal gaps, harmonizing terms, and introducing flexible mechanisms for adapting to the dynamic development of the digital environment.