Properly constructed criminal law provisions can prevent the destruction of heritage. The laws of the European Union are not an appropriate tool to reduce this phenomenon, although an analysis of criminal laws of individual countries may help in developing effective solutions in the Polish legal system. This article presents the criminal law solutions to protect against the destruction of heritage in France, Italy and Austria. Comparison of the provisions in these European countries allows the effective scope of protection of their cultural property to be indicated and to assess the possibility of including some of the standards to the Polish system of heritage protection.