The article presents a comparative analysis of the mechanism for implementing the decisions of the ECHR, proposed by the Federal Constitutional Court of Germany in the “Goergulu case” in 2004 and the Constitutional Court of the Russian Federation in the judgment of July 14, 2015 No. 21-P. The author believes there is a difference between the German and Russian legal orders in resolving the problem of enforcing judgments of the ECHR, despite the presence of comparability factors of legal systems. This conclusion is caused by fundamental differences in the place of the Convention for the Protection of Human Rights and Fundamental Freedoms, decisions of the ECHR and the role played by national constitutional courts in the implementation of Convention standards. The author notes the existing differences in approaches to the implementation of the decisions of the ECHR in the national legal order among the national constitutional courts, but studying them can enrich the national experience and optimize their own practice.