In addition to the documents included in this guide, the Law Library of Congress Global Legal Research Directorate prepared a comparative analysis titled Miranda Warning Equivalents Abroad (May 2016), which “contains short summaries describing warnings similar to the Miranda warning that are required in 108 jurisdictions around the globe.” The report notes that the
warnings specified in the surveyed jurisdictions vary, but typically include the right to remain silent and the right to legal counsel. A number of countries also specify that a person who is arrested or detained has the right to be informed of the reasons for the arrest or detention or of the charges being brought. In some countries the additional right to have these things explained in a language the detainee understands is explicitly stated. Commonwealth countries have traditional followed the English Judges’ Rules developed in the early twentieth century, and some continue to do so, while many Member States of the European Union (EU) have adopted an EU directive on the issue.
Points of variance among the countries concern the timing of the warning and whether the detainee is told that the fact of remaining silent will or will not be used in legal proceedings.
Countries surveyed that have no Miranda-type warning were not included.