Zakaz polowania

Overview of Hunting Governance Models in Selected EU Countries

Hunting regulations across the European Union vary widely – from highly centralized state-controlled systems to models based on free-market principles and private property rights. As a reference point, Poland’s current system exemplifies a state-controlled monopoly. In Poland, all wild game (certain species of wild animals) is considered state property, and hunting districts of at least 3,000 hectares are imposed top-down by regional authorities regardless of land ownership, often without the knowledge or consent of private landowners. The State delegates hunting management to a single association (the Polish Hunting Association, Polski Związek Łowiecki, or PZŁ) which holds a monopoly on game harvesting. Until recently, landowners had virtually no means to object to hunting on their own land. Only a 2018 amendment (following a 2014 Constitutional Tribunal ruling) granted individual landowners a limited right to file a declaration banning hunting on their property. Notably, this declaration does not remove the land from the hunting district, meaning the district remains intact but shooting is supposed to be refrained from on that parcel. Hunting clubs leasing the districts are formally liable for crop damage caused by game and must pay compensation to farmers, but in practice such compensation is difficult to obtain and often merely symbolic. Poland’s model can thus be characterized as a “state-social monopoly”: membership in PZŁ is mandatory for all hunters and no private hunting grounds are permitted. The State Forests agency (Lasy Państwowe) also plays a key role by approving annual and multi-year game management plans and directly managing certain exclusive hunting areas.

Against this Polish baseline, the following sections examine the hunting law frameworks of several other EU countries – especially those neighboring Poland or with similar geography – with particular attention to the rights of landowners under each system.

The following article was produced as part of a project funded by a grant from the European Union under the SPLOT WARTOŚCI initiative. The programme is financed by the European Union. The views and opinions expressed are solely those of the author(s) and do not necessarily reflect those of the European Union or the European Commission. Neither the European Union nor the granting authority can be held responsible for them.

The project is financed by the European Union as part of the SPLOT project.

Germany

Primary Legislation: Bundesjagdgesetz (Federal Hunting Act).

Germany employs a lease-based hunting district system that blends private landownership with a legal framework imposed by the state. Under the Federal Hunting Act, every tract of land (with only narrow exceptions near residential areas) must be part of a hunting district, much like in Poland. There are about 70,000 hunting districts nationwide, averaging 450 hectares each. Districts are established administratively at the local level. A landowner with a contiguous property above a certain size (75 hectares, 81 ha in Bavaria) has the right to form a private hunting district (Eigenjagdbezirk) on their land. Smaller landowners are by law grouped into communal hunting districts (Jagdgenossenschaften), typically encompassing an entire municipality or locality. These communal districts are collectively managed by the landowners (with voting power proportional to land area), somewhat analogous to a condominium association, and in practice are usually leased out to local hunting clubs for terms around 9 years. In this arrangement, the landowners receive rent from the lessee (on average about €7,000 per district annually), while day-to-day hunting operations are carried out by the lessee. Oversight is exercised by state (Land) authorities under the Ministry of Agriculture. Unlike Poland’s single-association system, German hunting clubs may form federations at the state level, but there is no monopoly by any one hunting organization.

Historically, individual landowners in Germany had limited influence – they were automatically members of the Jagdgenossenschaft and could not unilaterally forbid hunting on their land. However, a landmark 2012 judgment of the European Court of Human Rights (ECHR) in Herrmann v. Germany held that forcing a landowner morally opposed to hunting to tolerate hunting on his property violated his rights. In response, Germany amended its hunting law in 2013 to add §6a, allowing a private landowner who conscientiously objects to hunting to apply for designation of their land as a “Befriedeter Bezirk” (hunting-free zone) for ethical reasons. This procedure requires the owner to state a justification (e.g. ideological grounds) and typically takes effect after any current lease expires, but it represents an important departure from the former compulsory system. (Notably, Poland’s 2018 amendment was modeled on the German solution, though the Polish law ultimately did not require owners to justify their beliefs.) Following the ECHR ruling and legal change, an objecting German landowner can thus opt out of hunts on their property – a significant expansion of landowner rights compared to the past. Organizations such as Wildtierschutz Deutschland have formed to assist landowners with the application process for establishing such no-hunting zones.

In Germany, the hunting club (lessee of the district) is generally responsible for wildlife damage compensation. For example, if wild boar destroy crops, the affected farmer files a claim with the lessee, who must pay damages; if they cannot agree on the amount, the matter can be taken to court. Thus, the German model ensures landowners a share in hunting revenues (rent) and a say through communal associations, and since 2013 even provides a mechanism for individual owners to exclude hunting on ethical grounds, something unmatched in Poland’s current system.

Austria

In Austria, hunting law is legislated at the state (Land) level, resulting in nine separate provincial hunting acts (which are largely similar in many respects). For example, the Hunting Law of Burgenland (eastern Austria) is one such statute:
https://www.ris.bka.gv.at/GeltendeFassung.wxe?Abfrage=LrBgld&Gesetzesnummer=20001124

Austria’s system is a leasehold hunting district model quite similar to Germany’s, but implemented under provincial laws. Hunting districts are generally formed at the municipality level – as a rule, lands within a municipality are aggregated into districts and then leased to local hunter associations. In 7 out of 9 provinces, the minimum landholding to establish an independent private hunting area (Eigenjagd) is 115 hectares (in the other two – Tyrol and Burgenland – it is 300 hectares). Owners of such large contiguous estates may hunt on their own land (after obtaining a hunting license) or lease the hunting rights out, whereas smaller landowners are by law grouped into communal hunting areas (Genossenschaftsjagdgebiet) of at least 500 hectares (if a municipality is smaller, a special Sonderjagdgebiet is established). These communal areas are usually managed by local hunter associations under lease agreements with the municipality or the landowners’ collective. A typical scenario is that a rural municipality of, say, 3,000 hectares signs a lease with a local hunting club for all private lands; in return, the landowners receive a rent payment which is distributed pro rata according to acreage. This rental income is also meant to compensate for crop damages by game, although for certain types of damage farmers can still seek additional compensation. In each province, wild game damage arbitration boards operate (usually under local authorities) to which farmers can appeal if a lessee refuses a damage claim. As in Germany, there is no single hunters’ monopoly organization in Austria – multiple associations exist and hunters are not required to join any particular one.

Landowner veto rights in Austria are limited. An individual owner whose land is part of a communal district cannot simply forbid hunting on their parcel at will – unlike in Germany (after Herrmann) or in Poland (post-2018). In 2016, the Austrian Constitutional Court confirmed that even a declared ethical vegetarian (vegan) landowner must tolerate hunting on their property if it lies within a communal hunting area (G 7/2016). The only practical way for an Austrian landowner to keep hunters off their land is largely theoretical – one would need to own more than the minimum (e.g. >115 ha), establish a private hunting area, and then personally refrain from any hunting on it. In general, almost all rural land is part of a hunting district, with some districts being state-owned (e.g. in federal forest lands) where the forestry administration conducts hunts itself.

France

Primary Legislation: Code de l’environnement (Environmental Code).

France has a mixed system that combines private property rights with a unique institution of communal hunting associations known as ACCA (Association Communale de Chasse Agréée). As a general principle under the Environmental Code, a hunter has no right to enter private property without the owner’s consent. However, the 1964 Loi Verdeille introduced a mechanism in certain areas whereby owners of small rural parcels are compelled to join these communal hunting associations. Today, ACCAs operate in 70 out of 100 departments in France. In those departments, any landowner holding less than 20 hectares in one block (or < 20 ha in lowland areas, < 100 ha in mountainous areas) is automatically included in the local ACCA and must tolerate hunting on their land without individual consent. Larger landowners (exceeding 20 ha in plains or 100 ha in uplands) have the option to exclude their land from the ACCA and either manage hunting there themselves or simply keep the land closed to hunting.

Following a precedent-setting ECHR judgment in 1999 (Chassagnou and Others v. France), the French law was revised to soften the compulsory aspect. The Code now allows any landowner to withdraw from an ACCA for personal reasons (convictions personnelles). The procedure is formalized: the owner must file a request to exclude their land at least 6 months before the end of the ACCA’s 5-year term, and the request cannot be refused. Once the land is excluded, the owner must post it with “Chasse interdite” (hunting prohibited) signs and must abstain from hunting there themselves. In practice, the influence a landowner has in France’s system depends on the size of their holding. Small landowners are part of ACCAs by default (though they may join the ACCA as members if they are hunters and thereby participate in its general meetings). Their individual objections generally do not block hunting, except through the formal withdrawal process described. Large landowners, by contrast, can establish their own private hunts (chasse privée) – creating what is known as a coto privé (private hunting district), which must be registered with the Prefect’s office.

Wildlife damage compensation in France is handled via a special fund financed by hunters. Each Departmental Hunters’ Federation (Fédération Départementale des Chasseurs, FDC) is responsible for assessing and paying crop damage caused by game (e.g. boar, deer) in its department. Farmers report damage to the FDC, which calculates the compensation based on official rates and pays it out (often subject to thresholds and caps – very small damages may not be compensated). This system is funded by annual fees and dues paid by hunters, rather than by the state. However, the hunting lobby continually strives to shift more of this burden to the government. As of 2024–2025, reforms are under discussion: proposals include creating a national compensation fund managed by the state and subsidized by EU rural development funds, with hunters’ contributions capped at 40% of the departmental federations’ budgets. Hunters have even suggested that landowners who ban hunting on their land should be required to financially contribute to such a fund. These debates illustrate the ongoing tension in France between hunting interests, the state, and property owners.

Czech Republic

Primary Legislation: Zákon č. 449/2001 Sb., o myslivosti (Act No. 449/2001 Coll. on Hunting).

The Czech Republic inherited a collectivized hunting system from the communist era, centered on compulsory creation of large hunting districts. In the post-1990 period, the system has evolved to resemble the Austrian model, acknowledging private landownership while still requiring communal management. The Czech model can be described as a communal lease system with a dominant national hunting association (ČMMJ, the Czech-Moravian Hunting Union). Unlike in Poland, membership in ČMMJ is not mandatory – to become a licensed hunter in Czechia one must pass a state hunting exam, but need not join the association.

Since 2002, the minimum size for a hunting district (honitba) is 500 hectares, though it is possible to establish fenced game enclosures (obora) as small as 50 ha for intensive game breeding and shooting. A landowner (or group of owners) with at least 500 ha of contiguous land can apply to have their own private hunting district, but owners of smaller parcels must by law form a “honební společenstvo” – a landowners’ association – to create a communal district. These communal districts are typically leased to local hunting clubs. Formally, the landowner-members of the district decide on the lease and management by majority vote in proportion to land area (“one hectare = one vote”), but in practice local hunters often dominate these decisions by collecting proxies from numerous dispersed owners. There is no simple legal procedure for an individual owner to exclude their land from an established district; consequently, a small landowner effectively must tolerate hunting on their property as long as it lies within a hunting district.

Responsibility for game damage compensation in Czechia lies with the hunting district’s lessee (usually a local hunting club). The lessee must pay farmers for damage (e.g. wild deer or boar ravaging a cornfield). If the hunter’s club and the farmer cannot reach an amicable settlement, the farmer may sue for compensation in court. In practice, this process is burdensome – lawsuits can drag on for years, and proving the club’s fault (for example, by showing they failed to cull enough animals) can be difficult. It is worth noting that as of 2025 the Czech government has been planning amendments to the hunting law aimed at strengthening landowners’ rights and clarifying compensation rules. (Indeed, a separate analysis by Czech authorities highlights conflicts over landowner rights and the need for reform in this area.) Overall, the Czech system remains closer to the centralized model than a free-market approach: landowners have some role through associations, but no individual veto, and the historical legacy of mandatory large districts persists.

Slovakia

Primary Legislation: Zákon č. 274/2009 Z.z., o poľovníctve (Act No. 274/2009 Coll. on Hunting).

Slovakia’s situation was comparable to Czechia’s, but modifications were introduced by a major reform in 2009. The minimum hunting district size in Slovakia is 1,000 hectares for small game and 2,000 hectares for large game. If a single landowner holds a contiguous estate meeting those criteria, they may establish an independent private hunting district. Otherwise, landowners must form a community (assembly of owners, zhromaždenie vlastníkov) to create a communal district. By law, a landowner cannot refuse to have their land included in a hunting district unless they completely fence off the property, thereby turning it into a formally closed area (nepoľovná plocha, where hunting is not allowed). In practice, most hunting districts in Slovakia are formed largely on state-owned forest lands belonging to the state treasury.

Before hunting can be conducted, a hunting club (or other authorized entity) must sign a hunting-use contract with the community of landowners for the district. Uniquely, Slovak law prescribes minimum annual lease payments to landowners: for example, at least €0.50 per hectare for agricultural land and €2–5 per hectare for forest land. Lease contracts are generally made for 15-year terms, and often payment is not in cash but in-kind (such as sharing a portion of the game meat or allowing landowners to participate in hunts). Importantly, owners of larger land areas are given a statutory right to join the hunting club that leases their district – the law requires that a landowner above a certain acreage must be accepted as a member of the club so they have the opportunity to hunt on their own land.

Game damage compensation in Slovakia is the obligation of the hunting district lessee, but it comes with conditions. A farmer claiming compensation must prove they had taken adequate preventive measures (such as fencing crops or using repellents). Moreover, the hunting club usually must have a separate agreement with the farmer delineating liability. If no such agreement exists, hunters can formally decline to pay damages by pointing to the landowner’s failure to protect their crops. This framework effectively incentivizes landowners to cooperate and make agreements with the hunting club in advance.

In terms of organization, Slovakia has a hybrid approach: it is a lease-based system combined with mandatory membership of hunters in a national chamber. All hunters must belong to the Slovenská poľovnícka komora (Slovak Hunting Chamber, SPK), which functions as a professional self-governing body and is required for obtaining and maintaining a hunting license. Separately, there is a voluntary social association (Slovenský poľovnícky zväz, SPZ) that hunters may join for traditional and recreational purposes. In summary, Slovak law attempts to balance state control with landowner inclusion (through contracts and mandatory club admission for large owners), but does not grant individual owners a straightforward opt-out unless they physically fence their land.

Hungary

Primary Legislation: 1996. évi LV. törvény a vad védelméről, a vadgazdálkodásról valamint a vadászatról (Act LV of 1996 on Wildlife Protection, Wildlife Management, and Hunting).

Hungary operates a state-led lease system with a strong central role – in many ways resembling Poland’s model. Hunting rights are vested in the state and delegated to authorized entities. The Ministry of Agriculture defines hunting districts (minimum area 3,000 ha) and allocates their use rights to either local hunting clubs (Polgári vadásztársaságok) or state-owned enterprises. As of recent data, about 83% of districts are leased to private hunting clubs, while the remaining 17% are managed by state forestry companies or special state-run hunting reserves.

Landowners in Hungary have very little say in the matter – wild animals are state property, and private lands are automatically included in the designated hunting districts by force of law. (In contrast to Poland, however, before a district is leased out the authorities must conclude agreements with landowners for the use of their land.) These agreements are often handled by local landowner associations or municipal bodies. Lease terms are long (typically 20 years), and the remuneration to landowners is token at best – on the order of 200–400 Hungarian forints per hectare per year (just a few euros, essentially symbolic). Often payment is made in-kind (for example, a share of game meat), or landowners do not even bother to collect the trivial amounts due. Every lease must be approved by regional authorities, and annual hunting plans require sign-off by the forestry administration – analogous to the Polish oversight by State Forests. All Hungarian hunters are members of a single national organization (the Országos Magyar Vadászkamara, OMVV), effectively a unified statutory chamber.

An individual Hungarian landowner cannot exclude their land from a hunting district. In theory, an owner’s only recourse would be to fence their entire property and create a private game park (vadaskert), but even that is considered a form of game management and does not remove the land from the hunting regime. Hungarian law instead emphasizes that hunting districts cover all lands, and owners must accommodate that unless they create a captive breeding enclosure.

When it comes to damage compensation, Hungarian law places the duty on the lessees but also involves the farmers. Lessee clubs are required to set aside financial security for potential crop damage claims. A 2017 amendment introduced a cost-sharing mechanism: now farmers themselves must bear 10% of the wildlife damage to their crops, while the hunting club pays the remaining 90%. This effectively reduced hunters’ financial burden by introducing a deductible for farmers.

It is noteworthy that Hungary’s hunting sector has a pronounced commercial character. Each year roughly 25,000 foreign hunters (many from Western Europe) visit Hungary, paying for the privilege to hunt as a hobby and to collect trophies (antlers, skulls of red deer, etc.). Local hunting clubs derive substantial income from organizing these paid hunts for foreign clients and from the sale of venison. In summary, the Hungarian model, like Poland’s, minimizes landowner involvement and prioritizes state control and organized hunting interests, tempered only by formalities such as land-use agreements and modest rent – and recently by shifting some damage costs to landowners.

Romania

Primary Legislation: Legea vânătorii și a protecției fondului cinegetic nr. 407/2006 (Hunting and Wildlife Fund Protection Act No. 407/2006).

Romania’s system is also a state-controlled lease model very similar to Poland’s in that private landowners have virtually no role in defining or leasing hunting grounds. The creation of hunting districts (fond cinegetic) is the responsibility of the central government. By law, every parcel of the country, regardless of ownership, is assigned to a hunting district. These districts are quite large: minimum 5,000 ha in lowland areas, 7,000 ha in hilly areas, and 10,000 ha in the mountains. Boundaries are drawn by the state forestry agency, after which the Ministry in charge of forestry grants management rights for each district to approved entities under multi-year contracts. In practice, the majority of districts are leased by local hunting organizations affiliated with the National Association of Hunters and Fishermen (AGVPS, a legacy organization from the communist era), but some districts are managed directly by the State Forest Administration (especially those covering state-owned forests) or by certain research institutions operating game management units.

Private landowners whose land falls within a hunting district are legally obliged to tolerate hunting on their property and have no right to oppose it (this is explicitly stated in Article 4(2) of the law). They are not consulted in the process of district designation or leasing. As for damages, the law stipulates that the hunting district lessee is liable for crop damage caused by game. In certain situations – for example, if damage occurred despite proper game management measures, or in areas where hunting is prohibited (such as nature reserves) – the State will pay compensation. However, in practice farmers face great difficulties obtaining compensation from hunting clubs. They must prove the hunters’ negligence (e.g. that the club failed to meet its culling quotas), and often disputes are only resolved through lengthy court proceedings. Reports indicate bureaucracy hampers farmers’ claims and that hunters seldom end up paying full compensation.

Romania’s organizational model features a strong central authority (with cull quotas for each species set annually at the national level based on spring wildlife censuses, and a requirement for a license/permit for each individual animal harvested) and an effective monopoly by AGVPS – the historical hunting federation which retained its powers after 1989. A significant source of income for AGVPS-affiliated clubs is commercial hunting tourism, including for large carnivores (bears, wolves) which until recently were legally hunted in Romania. Even though Romania’s system is among the most state-driven, it does provide a minimal form of stakeholder input: for instance, representatives of farmers can participate in the administrative councils of hunting districts, giving them some voice in game management decisions (these councils then submit plans for approval by regional authorities). By contrast, as we will see, Poland currently lacks any such formal role for landowners or farmers in its hunting governance.

Spain

Primary Legislation: Ley de Caza (Spanish Hunting Law).

Spain is characterized by a decentralized, privately-regulated hunting system with a strong role for landowners. While the national law provides a framework, each Autonomous Community (region) has its own detailed hunting regulations, which can vary. The overarching principle is that hunting may only be conducted on land designated as a hunting ground (coto de caza) and with the consent of the landowner. In practice, almost the entirety of non-urban land in Spain is covered by hunting grounds, because landowners generally either manage hunting or lease out their rights. There are different categories of hunting grounds: private hunting estates (cotos privados), as well as community or municipal hunting areas (cotos sociales or communal reserves managed often by local authorities or cooperatives).

To establish a coto privado (private hunting ground), a landowner or a group of owners must have at least the required minimum area, which varies by region and by game type (for example, a common threshold is 250 ha for small game, 500 ha for big game). The owner must apply for registration of the coto with the regional administration. Once registered, the owner essentially becomes the hunting rights holder for that land – they may hunt on it themselves (provided they have a license), grant permission to other specific hunters, lease the hunting rights commercially to outfitters, or even choose to leave the land closed to hunting entirely. In other words, Spanish law strongly upholds the landowner’s autonomy in deciding how hunting on their land is utilized or not utilized.

Owners of parcels too small to qualify as independent cotos are generally expected to attach their land to a neighboring coto (often a coto social). The law even permits owners of large private cotos to incorporate small enclaved parcels within their boundaries (the small inholdings that would otherwise be excluded) by offering compensation to those owners. In practice, this means a small landowner who is surrounded by a larger estate might be induced to join the larger coto for a fee, as otherwise their tiny area would be an unhuntable “hole” on the map. For small landowners who do not wish to participate in any coto and whose land is isolated (not enclaved), hunting on their land simply cannot occur legally – there is no forced inclusion. Such an owner could, as a protective measure, physically fence their property (coto cercado), which not only keeps out wildlife to some degree but also clearly signals that entry by hunters or anyone else is forbidden. Indeed, fencing a property (to certain specifications) results in a legal presumption that unauthorized entry is prohibited.

Compensation for game damage in Spain is not handled in a uniform way at the national level. It largely depends on the rules of the particular coto and the region’s regulations. Typically, the hunting rights holder (lessee) of the coto is liable for crop damage caused by game on that land. Some Autonomous Communities have established compensation funds funded by hunting license fees, but in many cases individual farmers must pursue their claims directly with the hunting lessee. Because Spain encompasses a wide range of situations – from wealthy owners of vast estates (latifundia) to small farmers participating in cooperative cotos – the practice is inconsistent. In regions like Andalusia, many large commercial estates (fincas) offer trophy hunts to paying clients, whereas in regions like Galicia or Catalonia, small-scale farmers often band together in communal hunting areas run by local clubs. The organizational model in Spain is highly decentralized: each Autonomous Community sets its own hunting rules, but generally private ownership rights take precedence. A common maxim is “La caza en coto privado depende de la autorización de los propietarios” – hunting on a private estate occurs only with the landowner’s authorization. The State’s role is mainly regulatory – issuing licenses, enforcing species protection (e.g. for protected wolves or bears), and ensuring sustainable quotas – rather than managing hunts directly. Spain’s approach thus represents the opposite end of the spectrum from Poland: landowner-centric and market-driven, with the government as an overseer rather than operator.

Italy

Primary Legislation: Norme per la protezione della fauna selvatica omeoterma e per il prelievo venatorio (Law 157/1992 on the Protection of Wild Homothermic Fauna and Hunting).

Italy has a public-regulatory model of hunting that is a legacy of old feudal hunting rights being nationalized. Landowners’ rights in Italy are significantly curtailed in favor of ensuring broad access for licensed hunters. Under Article 842 of the Italian Civil Code, a landowner may not forbid others from entering their land for hunting purposes, unless the land is enclosed by a legal fence. In effect, any duly licensed hunter in Italy is allowed to hunt on unfenced private land (with certain safety restrictions, such as maintaining a set distance from dwellings) without needing the owner’s permission. To prevent hunting on their property, an owner must convert it into what is called a fondo chiuso – an area fully enclosed by a fence meeting statutory standards and properly signposted. In practice, few farmers fence in large fields or woodlands, so the majority of private rural land in Italy remains open to entry by hunters.

Administratively, the country is divided into hunting districts known as Ambiti Territoriali di Caccia (ATC), and in Alpine areas Comprensori Alpini. Each region establishes a set of ATCs covering its territory and assigns registered hunters (holding a license) to specific ATCs. A hunter in Italy can generally only hunt within the ATC to which they are assigned (often their home district or where they have paid fees). Each ATC is governed by a management committee composed of representatives of various stakeholders – including farmers, landowners, hunters, and environmental conservation groups. These committees formulate five-year hunting plans for the district, setting quotas and measures, but the plans must be approved by the regional authorities. Through this mechanism, landowners (and farmers) do have some input in planning (by participating in ATC committees), but they cannot arbitrarily exclude hunters from their land unless, as noted, they physically close off the land. There are NGOs, such as Gruppo d'Intervento Giuridico, that assist landowners in lawfully establishing a fondo chiuso to exercise their right to keep hunters out.

Italian law also provides for private hunting preserves (azienda faunistico-venatoria, AFV, or agro-turistic hunting farms AATV). In these cases, a landowner with a very large estate that meets strict habitat and fencing criteria can obtain an exclusive right to manage game on that property and operate commercial hunting there. Such private reserves are relatively rare – only a few exist per region – and are exceptions to the general rule of open access.

Responsibility for crop damage by wildlife in Italy varies by region. In some regions, the ATC management bodies are responsible for paying compensation to farmers, funded by pools which hunters indirectly finance through license fees and mandatory insurance. In other regions, the regional government itself pays out damages from public funds. There are regional compensation funds (augmented by hunting license revenues) to cover legitimate claims by farmers, and hunters contribute via their fees and required liability insurance. If damage occurs inside a private AFV reserve, the private owner of that reserve must pay the compensation. Problems have arisen in recent years with booming wild boar populations causing significant agricultural damage and high costs to regional authorities (notably in Tuscany and Lazio).

Organizationally, Italy does not have a single national hunting association. Hunters may join one of several existing federations (often regionally or ideologically aligned), but membership is not mandatory to obtain a hunting license. A hunter needs only to pass the licensing exam and fulfill legal requirements; association membership is optional. In summary, Italy’s system prioritizes hunters’ access over landowner exclusion, reflecting an old principle that wildlife is a public resource. While landowners can participate in management planning and create fenced refuges, the default rule allows licensed hunters fairly broad access across private lands – a stark contrast to systems where landowner permission is central.

Lithuania

Primary Legislation: Lietuvos Respublikos medžioklės įstatymas (Hunting Law of the Republic of Lithuania).

After regaining independence in 1990, Lithuania adopted a model of state ownership of wildlife similar to other Central/Eastern European countries. Hunting districts are created centrally – the entire country is divided into hunting areas with a minimum size of 1,000 hectares. As of recent data, about 49% of these districts are in state forests (managed by the State Forest Enterprise), and 51% are leased to hunting clubs.

Until very recently, private landowners in Lithuania had virtually no say – their lands were included in hunting districts without consent or consultation. However, conflicts and activism led to legal changes. In 2015, the Lithuanian Constitutional Court ruled that owners of larger landholdings (over 15 ha) should be guaranteed the right to participate in hunting on their land. As a result, amendments to the hunting law were enacted to strengthen landowner rights. Now, if a landowner’s property lies within a hunting district, the law provides that if the owner holds a hunting license, they have the right to be accepted as a member of the hunting club managing that district (i.e. to join the lessee club that hunts on their land). If the club or lessee refuses to admit the landowner – or if the district is managed not by a club but by a state entity – then the owner gains the right to hunt on their own land independently. In other words, eligible landowners must be given a seat at the table (or the freedom to self-manage) in the game management of their property.

Furthermore, the law now explicitly guarantees landowners a right to compensation for game damage: under Article 18, a landowner whose land is used as part of a hunting district is entitled to compensation for damage caused by wild animals. Such compensation is to be paid by the hunting district’s lessee (usually the club) according to the terms set in their contracts or bylaws, although in practice the consistency of payments varies. Crucially, the amendments also granted landowners a right to object to hunting on their land. According to Article 8(4) of the Lithuanian hunting law, a landowner may now submit a written declaration banning hunting entirely on their property or imposing additional conditions on hunting. If an owner files such a declaration, their land remains within the formal boundaries of the hunting district, but it is designated as a no-hunting zone (“laikinai uždrausta” – temporarily prohibited area) within that district. In exchange, the owner forfeits any right to compensation for game damage on that land (similar to the rule in Poland). This change, implemented after 2015, closely mirrors the concept of Germany’s Befriedeter Bezirk and Poland’s 2018 opt-out: it gives individual property owners a decisive say over hunting on their land, at least with respect to allowing or forbidding it.

Lithuania’s system does not impose a monopoly association for hunters. In practice, hunters may belong to various local hunting clubs or associations of their choosing, but such membership is voluntary. The state issues hunting licenses (medžioklės bilietas) to individuals who meet the requirements (passing an exam, obtaining liability insurance, completing an apprenticeship, etc.), and holding a license entitles one to hunt subject to law, regardless of any club membership. Thus, since 2015 Lithuania has moved towards a more owner-inclusive model: larger owners can demand participation or even exclude hunting, and all owners (who wish to) can claim compensation – a notable shift from the earlier fully state-centric approach.

Latvia

Primary Legislation: Medību likums (Hunting Law of Latvia).

Latvia’s approach grants perhaps the greatest freedom to landowners among the countries discussed. Latvian law unambiguously states that the right to hunt is an attribute of land ownership – the landowner holds the hunting rights for their property. An owner can choose to hunt on their own land (if licensed) or to allow others to hunt there, but it is fundamentally the owner’s decision. Unlike the centralized systems elsewhere, Latvia does not automatically impose hunting districts over all land. In theory, anyone can create a hunting district (medību iecirknis) on their property, provided they have a sufficient area. The minimum requirement is 350 hectares of contiguous land for a single owner to establish a private district, or 1,000 hectares if multiple owners combine their lands. For certain game species, larger areas are required (for example, at least 2,500 ha are needed to have a district where one can hunt moose).

In practice, while it is possible for an owner to have a standalone hunting block, most landowners in Latvia enter into voluntary agreements with local hunting clubs that pool lands for hunting. The key is that these agreements are voluntary. An owner can simply refuse to include their land in any hunting lease – and if they do so, hunting on that land cannot legally take place. Many owners of very small parcels find it impractical to exercise hunting rights themselves, so they typically allow a local club to use their land, often in exchange for some benefit such as a small fee or the opportunity to join the hunting club (so they can personally hunt on neighboring lands). There are also instances of large private hunting estates (especially large forest tracts) where owners conduct commercial hunting operations on their own land.

Wildlife damage compensation in Latvia is not governed by a centralized scheme. The general principle is that the user of the hunting rights (i.e. the lessee or hunting club) is responsible for damage to crops or domestic animals. However, the specifics – such as the amount of compensation and procedures – are determined by the private agreements between the landowner and the hunting rights user. The law does set up municipal hunting coordination commissions (7 members including representatives of hunters, landowners, and local government) which, among other tasks, can adjudicate disputes over damage claims. In reality, though, hunters in Latvia almost never pay out damage compensation. Over the past decade, there have been virtually no recorded cases of a hunting club actually paying a farmer for losses. These local commissions may assess the damages, but then the issue tends to fade away without resolution. Several reasons underlie this: close local ties (officials may be reluctant to penalize clubs that they or their friends belong to) and the fact that many landowners themselves are members of the hunting clubs, leading them to tolerate a certain level of damage without complaint.

Latvia’s organizational model can be described as quasi-free-market or contractual. Hunting occurs on the basis of private agreements between landowners and hunters. The state sets only broad parameters – seasons, bag limits, and license requirements for protected species – but does not impose a uniform grid of hunting districts from above. The landscape of hunting territories is thus shaped by the parties themselves, which maximizes respect for property rights but can result in a patchwork of arrangements and some degree of chaos (for instance, no guaranteed comprehensive compensation system). In Latvia, the landowner’s prerogative is paramount: one cannot hunt where the owner has not given consent. This is fundamentally different from systems like Italy’s or Poland’s and represents an extreme on the spectrum favoring private property in hunting law.

Estonia

Primary Legislation: Jahiseadus (Hunting Act of Estonia, reformed in 2013).

In recent years Estonia undertook significant hunting law reform to strengthen landowner rights and modernize hunting management and compensation mechanisms. The current model in force since 2013 features large hunting districts (jahipiirkond) – each must cover at least 5,000 hectares in one contiguous area. Districts exclude cities, densely populated areas, and any zones where hunting is legally prohibited (such as strict nature reserves). Allocation of a hunting district to a user is done by the state’s Environment Agency (Keskkonnaamet) through a licensing decision. A crucial condition for obtaining a district license is that the applicant (usually a local hunters’ association) must secure the consent of landowners representing the majority of the land area in the proposed district. This ensures that a significant portion of landowners are agreeable to the hunting arrangement from the outset.

To further amplify landowner influence, Estonia created County Hunting Councils (jahindusnõukogu) in each county, composed 50/50 of representatives of hunting district license-holders and representatives of landowners, plus a government (state) representative. These councils have the power to approve the annual game cull quotas for each district and to advise on changes to district boundaries or any change of the hunting district’s license-holder. Moreover, if landowners owning the majority of a district’s territory collectively petition for the removal of a particular hunting club as the district manager, the authorities are obliged to revoke that club’s license and select a new manager for the district. This provides a potent check: landowners can effectively vote out a hunting club that is not managing game to their satisfaction.

Estonia’s law explicitly enumerates landowners’ rights in hunting. According to Article 6 of the Hunting Act, a landowner has the right, under conditions and to the extent provided by law, to:

In practical terms, a landowner who does not wish to have hunters on their property can submit a written statement banning hunting on their parcel, and hunters are legally obliged to respect that ban. The law provides limited exceptions – for instance, an owner cannot prevent entry to track a wounded animal (blood tracking) or to carry out an official cull for disease control – but generally the owner’s prohibition must be honored. There are NGOs in Estonia encouraging owners to exercise this right (such as the Jaht tapab! campaign, meaning “Hunting kills!”).

Compensation for wildlife damage in Estonia is addressed in detail. If a landowner has a contract with the hunting district’s license-holder specifying the terms of game management on their land (the law requires the license-holder to offer such contracts – essentially land use agreements – to landowners, per Article 25(1)), then any damage by game is compensated according to that contract. If no such contract exists – which might be the case for an owner who refused to grant permission but whose land still lies within a district – the law grants that owner a right to partial compensation from the hunting club’s funds by default. In addition, Estonia operates a state reserve fund for damage: the state (via Keskkonnaamet) will cover a portion of damages that meet certain criteria, for example damage caused by protected species (like wolves or bears) or cases where the damage exceeds what the hunters could reasonably prevent. This multi-tiered system ensures that landowners have recourse if wildlife from hunts causes losses, whether or not they have an agreement with the hunters.

There is no a requirement to belong to any association to obtain a hunting license. This means the hunting community can organize itself in multiple associations or clubs, and landowners can even form their own hunting groups if they wish. Estonia’s reforms thus represent a progressive balance: large districts for ecological effectiveness, but significant empowerment of landowners through consent requirements, governance participation, opt-out rights, and guaranteed compensation mechanisms.

Summary and Comparison

The above survey demonstrates a spectrum of hunting management models in the EU, particularly among countries with geographic or historical proximity to Poland. On this spectrum, Poland stands out for the almost complete exclusion of landowners from any decision-making in its hunting system. Polish landowners have no influence over the delineation of hunting districts (they may submit comments during the designation process, but this right is largely illusory and rarely leads to changes). They also have no say in who leases the hunting rights on their land or in the content of hunting management plans – Polish law provides for no formal participation by landowners, farmers, or even environmental stakeholders in setting culling quotas or plans (for instance, even when determining bird shooting limits in Natura 2000 areas, no conservation input is required). The sole concession to landowner rights in Poland is the limited ability since 2018 for an individual to opt out of hunting on their property, but even this does not remove the land from the district and is available only to individuals (not businesses or churches, for example).

By contrast, even in perhaps the most “state-dominated” system described – Romania – private stakeholders are not entirely ignored. In Romania, farmers’ representatives can sit on the administrative councils of hunting districts, giving them a role (albeit minor) in co-deciding hunting plans. Those plans must ultimately be approved by regional authorities, but at least some form of landowner input exists. In Poland, hunting plans are not subject to approval by any state or local authority; they are approved only by officials of the State Forests holding, who may themselves be hunters in the same district, raising conflict-of-interest concerns. Similarly, in Hungary, a very centralized system that pays little heed to landowner interests, the authorities must at least formally sign contracts with landowners for the use of their land for hunting. In Poland, landowners often are not even aware that a hunting district has been established on their property, nor do they know who the lessee (hunting club) is or how to contact them. This level of disregard for property rights is unique in the EU context.

In conclusion, pressures are mounting for Poland to eventually reform its hunting laws to align with 21st-century standards of governance, property rights, and wildlife protection. In designing a future reform, Poland can draw on the lessons of other countries – whether it be Germany’s and France’s court-mandated respect for objecting landowners, Estonia’s innovative consent-based licensing and compensation system, or Latvia’s market-driven respect for private hunting rights. Poland could also craft an entirely new model that better protects wild animals from unnecessary suffering and guarantees farmers and other landowners a meaningful say over what happens on their land. Transparency will be another key aspect – ensuring the public has access to information on how hunting is managed and how public funds (or hunter fees) are used in wildlife population control. The comparative overview above makes clear that a more balanced system – one that respects property rights, promotes safety and animal welfare, and remains ecologically sustainable – is not only possible, but already in place in various forms across Europe. Poland’s challenge will be to adapt these insights into a solution that fits its own social and environmental context.

overview of hunting models in selected EU countries