Abstract: International legal approaches to the regulation of voluntary accumulation pension systems, as established in the OECD's recommendation documents (in particular, the Recommendation on the Proper Structure of Defined Contribution Pension Plans 2022), as well as in the contractual obligations of the member states of the EAEU, CIS, BRICS, and SCO. The legal models of Germany, the Netherlands, and the USA are examined in their relation to the legal structure of the Russian Long-Term Savings Program (LSP). The organizational and functional distinctiveness of the LSP from mandatory pension insurance (MPI) and non-state pension provision (NSPP) is investigated, identifying the legal, financial, and social risks of implementing the program (including the absence of commission limits, the “10% of the subsistence minimum” rule, inflation, and behavioral risks), as well as the issue of cross-border portability of pension rights when a participant changes their permanent residence. A comparative legal analysis of international legal acts and approaches of international organizations (OECD, EAEU, CIS, BRICS, SCO) and national legal models (Germany, the Netherlands, USA); formal legal analysis of Russian legislation; and a systematic approach to risk classification are conducted. For the first time, the author has conducted an international legal analysis of the LSP as a multifunctional tool for household savings behavior, identifying a legal vacuum regarding the cross-border portability of pension rights, justified mechanisms for its elimination based on international experience, and proposed specific measures to enhance the social effectiveness of the program, including the introduction of auto-enrollment, limitation of NSPF commissions, reform of the “10% of the subsistence minimum” rule, and harmonization with obligations within the EAEU. Legally binding international treaties (within the EAEU and CIS) do not regulate voluntary accumulation pension programs, and OECD recommendations are non-binding, creating a legal vacuum during cross-border labor movements. The LSP is an independent institution that combines state support with market flexibility; however, its social effectiveness is diminished due to legal (lack of commission limits, inheritance uncertainty, “10% of the subsistence minimum” rule), financial (inflationary, commission, market) and social (demographic skew towards retirees, low financial literacy, inequality of access) risks. Measures for improving legislation in line with international experience have been proposed.

Keywords: Long-Term Savings Program, Non-State Pension Fund, Mandatory Pension Insurance, Non-State Pension Provision, international legal benchmarks, OECD, EAEU, cross-border portability, pension risks, social effectiveness