How does assisted dying work in other countries?

Assisted dying, a complex and ethically charged issue, has been legally implemented in various forms across the globe, offering different pathways for individuals facing unbearable suffering or terminal illness to end their lives with dignity. While critics often refer to it as assisted suicide, the terminology itself is a point of contention, reflecting deeply held beliefs about autonomy, compassion, and the role of medicine. In the United States, assisted dying is currently legal in 30 out of 50 states, alongside Washington D.C., showcasing a growing acceptance of this practice within the nation.

Oregon stands as a pioneer in this field, having established its Death with Dignity Act in 1997, nearly three decades ago. This landmark legislation has served as a foundational model for many other US states that have since enacted similar laws. The Oregon model strictly defines eligibility: individuals must be terminally ill, mentally competent adults who are expected to die within six months. The process requires the explicit consent of two physicians, ensuring a rigorous review of each case. Since its inception, the data from Oregon paints a compelling picture. Over 5,520 individuals have received prescriptions for a lethal dose of medication, with 3,691 ultimately choosing to end their lives through this means. A 2025 report highlighted that cancer was the primary diagnosis for 61% of those seeking assistance, followed by neurological conditions such as motor neurone disease (14%) and heart disease (11%). For the approximately 400 patients who opted for a lethal dose in the past year, the overwhelming majority (89%) cited loss of autonomy as a principal concern. Other significant reasons included the inability to engage in enjoyable activities, loss of dignity, and being a burden on family. A crucial element of the Oregon law, and indeed many other US states permitting assisted dying, is the requirement for self-administration of the lethal medication. This principle of self-administration is also mirrored in proposals being considered in England and Wales. It is noteworthy that around one in three individuals prescribed a lethal dose ultimately do not proceed with taking it, underscoring the profound personal decision involved.

While proponents of assisted dying in England and Wales point to Oregon’s consistent focus on terminally ill adults as evidence of its restricted application, opponents argue that certain safeguards have been loosened over time. For instance, the residency requirement has been removed, opening the option to individuals from outside Oregon. Furthermore, the number of assisted deaths has seen a substantial increase year on year, a trend that raises concerns for some.

Across Europe, a more diverse landscape of assisted dying legislation exists. Six countries have legalized some form of the practice: Switzerland, the Netherlands, Belgium, Luxembourg, Spain, and Austria, with France being the most recent addition. A key distinction in these European nations, when compared to proposals in England and Wales, is that eligibility is not solely restricted to the terminally ill. Switzerland holds the distinction of being the first country globally to establish a "right to die," legalizing assisted suicide in 1942. Uniquely, Switzerland permits foreigners to access assisted dying services through organizations like Dignitas in Zurich. Over the past two decades, more than 600 Britons have utilized Dignitas, with 43 deaths recorded last year alone. As in Oregon, the lethal medication must be self-administered in Switzerland.

The Netherlands and Belgium have had legalized assisted dying for over two decades, catering to patients experiencing unbearable suffering from incurable illnesses, including mental health conditions. Their laws have even been extended to children, making them the only European countries to permit this. Both nations embrace euthanasia, also known as physician-assisted dying. More recently, Spain and Austria have enacted legislation that allows assisted dying for both terminal illness and intolerable suffering. In Austria, the patient must self-administer the medication, while in Spain, a medical professional is permitted to administer it.

In stark contrast, parliaments in England, Wales, and Scotland have consistently rejected proposals for assisted dying. However, a significant development has occurred within the British Isles: Jersey. In July, the island’s government received Royal Assent for a bill that will introduce assisted dying. The implementation of this service is expected to take approximately 18 months, with the first assisted death anticipated in late next year. A crucial aspect of Jersey’s legislation is a one-year residency requirement, designed to deter "death tourism."

The Jersey law distinguishes itself from other jurisdictions in the British Isles by offering individuals the choice of how their assisted death will be administered. Eligible individuals can opt for a doctor to administer a lethal dose intravenously, a method also employed in Spain, Canada, New Zealand, and most of Australia. This form of assisted dying is, in effect, voluntary euthanasia and has become the preferred method in places where this option is available.

Conversely, the laws currently being debated in Westminster (England and Wales), Holyrood (Scotland), and Tynwald (Isle of Man) all stipulate that death must be achieved through self-administration, typically by ingesting a lethal dose of medication. The Isle of Man’s assisted dying bill made significant progress, passing through Tynwald in March of the previous year. As a UK Crown Dependency, similar to Jersey, the bill required Royal Assent to become law. This assent was initially declined by the UK Ministry of Justice earlier this year. However, Tynwald subsequently passed an updated bill, which has been resubmitted to the UK government for a second review. Should Royal Assent be granted, the Isle of Man anticipates its assisted dying service to be operational next year, with a five-year residency requirement in place.