当下,我国的附条件不起诉制度在运行过程中还存在较多问题,需要剖析域外先进经验来进一步探索。通过对域外几个比较成熟的国家和地区相关制度的了解和总结,比较不起诉制度在决定主体、适用范围、适用条件、适用效力和制约救济措施方面的差异和优劣,从而明确该制度在我国的出路和变革方向。 At present, there are still many problems in our country’s conditional non-prosecution system during operation, and we need to analyze the advanced experience outside the country for further exploration. Through the understanding and summarization of the relevant systems in several relatively mature countries and regions outside the country, the differences and pros and cons of non-prosecution system in determining the subject, scope of application, applicable conditions, effectiveness of application and restriction of remedial measures are compared, The way out for our country and the direction of change.