The legal regulation of silvicultural interventions – science-based practices for establishing, tending, and regenerating forests – serves as a direct indicator of a nation’s commitment to sustainable forest management (SFM). This study conducts a structured comparative legal analysis of legislative frameworks governing silviculture in five countries, each exemplifying a distinct governance model: Türkiye (prescriptive statecentric), Sweden (liberal, goal-oriented), Germany (federal, incentive-based), Canada (provincial jurisdiction with Indigenous rights), and Brazil (private-land focused, implementation-challenged). Employing the Institutional Analysis and Development (IAD) framework, the research systematically compares national legal regimes across six analytical variables: regulatory system, ownership-governance nexus, silvicultural standards specificity, enforcement architecture, adaptive capacity, and transnational norm integration. Primary legal texts were analyzed through directed content analysis, supplemented by secondary sources and recent jurisprudence. The analysis yields three principal findings. First, ownership structure operates as a constitutive element shaping regulatory architecture, resulting in five governance paradigms with functionally equivalent yet formally distinct silvicultural controls. Second, a cross-cutting ‘implementation gap paradox’ demonstrates that the two countries with the strongest constitutional protections, Türkiye and Brazil, exhibit the greatest divergence between de jure protections and de facto outcomes. Third, since 2020, climate adaptation has supplanted sustainable yield as the primary driver of forest law reform in Europe, while recognition of Indigenous rights has become the dominant reform impetus in Canada. The study introduces a ‘Regulatory-Institutional Alignment Framework’ to account for the differential effects of governance on the interaction among legal design, institutional capacity, enforcement integrity, and political commitment. These findings provide practical guidance for policymakers and legal researchers, with several reform proposals supported by comparative evidence.
Birben et al. (2026) studied this question.