This thesis examines and compares the State’s ownership of archaeological heritage in Switzerland and Turkey, two countries with contrasting political structures and archaeological contexts. The comparative analysis, which is based on both the movable and immovable parts of archaeological heritage, is later used to formulate general recommendations applicable to other countries. Such recommendations are built on the Model Provisions on State Ownership of Undiscovered Cultural Objects elaborated by UNESCO and UNIDROIT. The recommendations propose that States go further than the Model Provisions by enacting laws that explicitly delineate the State’s duties regarding archaeological heritage protection and by reinforcing the ownership regimes for such heritage.