This article was written based on the results of the author's PhD internship at the Dublin Institute of Technology, Ireland, in April 2016. The article provides an initial comparative analysis of inclusive education systems in Ireland and Kazakhstan related to special educational needs (SEN). Data were gathered for the Irish context through literature reviews, document analysis, site visits and interviews. Data for the Kazakhstan context were accumulated from relevant legal documentation, practice literature review and interviews. The aspects of inclusive education selected for comparative analysis in this article include: enabling legislation; types of schools; supports provided; training of teachers.