The paper presents an analysis of the simulative action category and its representation in German and Udmurt. These languages are typologically different: German is an inflectional language, while Udmurt belongs to agglutinative languages. The modal meaning "simulative action" has its specific semantic features. Despite the fact that it is semantically close to the comparison meaning, it is also connected with the modality and influenced by subjective evaluation of a speaker. The representation of modal meaning "simulative action" covers all levels of the language system: morphological, lexical and syntactic. The simulative action meaning on the morphological level in the Udmurt language is expressed by the complex suffix -myask- and its combinations with the negative suffix -te-: -temyas'k-, -mteyas'k-. In German there are no specific affixes to express simulative action. Other linguistic means like comparative conjunctions kad', vyllem in Udmurt or wie in German are used very rarely and can be considered as additional ones. Linguistic means of the lexical level demonstrate a large diversity: German verbs sich verstellen, sich stellen, sich anstellen, vortauschen, sich aufspielen, heucheln, imitieren, simulieren, fingieren, Udmurt verbs analskyny, analtiskyny. In spite of wide range of semantically similar verbs, all of them except sich verstellen are used only in combination with other lexemes in restricted contexts. There are also some German lexemes derived from the verb scheinen. In both languages the semantics of the simulative action on the syntactic level can be expressed by syntactic units including an equivalent of the verb "to do" - karyny and tun. The authors specify the term "simulative action verbs" in Udmurt. They believe that the term is used incorrectly, when it comes to the verbal forms with suffixes -myas'k-, -temyas'k-, -mteyas'k-.