The issue of the conceptual development of legislation on property rights to natural resources remains unresolved. The question is not one of determining the location of relevant norms within the legislative system, but rather of providing them with an adequate legal form, taking into account the special status of natural resources as special objects of legal regulation, the purpose of which is in no way limited to the needs of entrepreneurship and the market, or the interests of individuals. Finding an optimal balance between the natural resource basis and the civil law form in the development of legislation on property rights to natural resources is essential. The author proposes approaches to solving this problem.