A Comparative Study of the Inclusive Education Curriculum in the United States and Finland: Implications for the Development of Iran’s Inclusive Education System

Background and Objectives: Inclusive education is one of the fundamental principles of contemporary education systems, emphasizing the equal right of all students, regardless of their abilities or disabilities, to receive education alongside their peers in mainstream schools. Despite the global acceptance of this principle, its implementation faces significant challenges, and different countries have followed diverse pathways toward its realization. This study aimed to conduct a comparative analysis of inclusive education programs in the educational systems of the United States and Finland based on complementary elements, including the role of teachers, instructional materials and resources, grouping and participation, time and place, and the learning environment, and to derive implications for the development of inclusive education programs within Iran’s education system. Methods: This study was applied in terms of its purpose and qualitative in terms of its nature. It employed George Bereday’s comparative education model through four stages: description, interpretation, juxtaposition, and comparison. In this study, given the differences in the social contexts of the United States and Finland and the differences in educational outcomes related to inclusive education, the “different social systems; different educational outcomes” strategy was adopted, and the United States and Finland were purposively selected. Data were collected through documentary analysis of reliable national and international sources, including laws, policy and regulatory documents, official reports, and scholarly articles. The data were analyzed using source triangulation to enhance the credibility and comprehensiveness of the findings. Findings: The findings indicated that, despite their different cultural and political backgrounds, both educational systems have embraced the principle of providing all students with access to the general education curriculum and reducing segregation. However, the mechanisms through which this principle is realized differ considerably. The United States follows a rights-based and legally grounded approach supported by legal frameworks and Individualized Education Programs (IEPs), whereas Finland adopts a preventive and system-oriented approach based on early intervention and a multi-tiered system of support. This difference is clearly reflected in the elements of the teacher’s role, instructional materials and resources, grouping and participation, time and space, and the learning environment. Conclusion: The development of inclusive education in Iran requires simultaneous progress on two fronts: strengthening legal and executive guarantees on the one hand, and integrating inclusive education into a broader policy framework of quality education, prevention, and teachers’ professional empowerment on the other. Rather than replicating a single foreign model, Iran should develop a contextually appropriate and locally adapted model of inclusive education that is consistent with the country’s educational capacities and requirements.