How does assisted dying work in other countries?

For the first time in almost a decade, MPs will vote on giving terminally ill adults in England and Wales the right to assisted dying. Although it is illegal in most countries, over 300 million people currently live in countries that have legalized assisted dying.

Canada, Australia, New Zealand, Spain and Austria have introduced assisted dying laws since 2015 – when British MPs voted on the issue – with some allowing assisted dying for people who are not terminally ill.

A bill proposed in England and Wales includes protections that supporters say will make it the toughest set of laws in the world, with patients having to get approval from a High Court judge. On the other hand, critics say changing the law would be a dangerous step that would put the vulnerable at risk. They argue that the focus should be on improving patchy access to palliative care.

Ahead of Friday’s vote, we’ll take a look at the laws surrounding assisted dying in North America, Europe and Australasia.

Across the United States, assisted dying – which some critics prefer to call assisted suicide – is legal in 10 states as well as Washington. Oregon was one of the first places in the world to offer assisted dying to some patients in 1997, which means it has more than 25 years of experience. This became the model on which other US assisted dying laws were developed.

in Oregon, Assistance in dying is available to terminally ill peoplementally competent adults will die within six months – and must be signed by two doctors. Since 19974,274 people received a prescription for a lethal dose of the drug – including 2,847 (67%) deaths.

Two-thirds of patients in the state who asked for help in dying last year, suffered from cancer. About one in 10 people had neurological diseases, and about the same percentage had heart disease. Of the 367 patients who took a lethal dose of the drug last year, the vast majority (91.6%) said that The most important problem was the loss of autonomywhile others quoted:

• Loss of dignity – 234 patients (63.8%)
• Loss of control over body functions – 171 (46.6%)
• Fear of being a burden to family and friends – 159 (43.3%)
• Inadequate pain control – 126 (34.3%)
• Financial consequences of treatment – ​​30 (8.2%)

In Oregon, as in other US states that allow assisted dying, the lethal drug must be self-administered – the same is proposed in England and Wales. About one-third of people prescribed a lethal dose do not comply.

Oregon is important to supporters of assisted dying in England and Wales because they emphasize that since its introduction it has been limited to terminally ill adults. Opponents, however, say some rules have been relaxed. The residency requirement has been waived, meaning it is open to out-of-state applicants. The number of assisted deaths has also increased significantly over the years.

Canada is a country often mentioned by opponents of assisted dying as an example of the so-called a “slippery slope” – a place where, since assisted dying was introduced, it has been expanded and made available to more people. Medical Assistance in Dying (Maid) it was introduced in 2016, initially only for terminally ill people.

This provision was amended in 2021 and extended to people experiencing “unbearable suffering” due to irreversible illness or disability. It is yet to become available to people suffering from mental illness within three years, despite delays.

Critics say the more the law is expanded, the more vulnerable disabled and vulnerable people become. There has also been a dramatic increase in the number of people using Maid. Four out of 100 deaths in Canada currently receive medical attentioncompared to about one in 100 in Oregon.

Kim Leadbeater, the member of parliament who proposed the assisted dying bill in Westminster, says the Canadian system is not up for debate in England and Wales, where entitlements would be limited to the terminally ill.

In Europe, six countries have some form of assisted dying: Switzerland, the Netherlands, Belgium, Luxembourg, Spain and Austria. In all of them – unlike proposals adopted in England and Wales – assisted dying is not limited to terminally ill people.

Switzerland was the first country in the world to create a “right to die” when it legalized assisted suicide in 1942. It is one of the few countries that allows foreigners to access assisted dying through organizations such as Dignitas in Zurich. Over 500 Britons died at Dignitas over the last two decades, including 40 last year. The deadly drug must be taken on its own.

Both the Netherlands and Belgium legalized assisted dying more than 20 years ago for patients experiencing unbearable suffering from terminal illness, including mental health problems. It has since been extended to children – the only European countries that allow it. Both allow euthanasia – that is, physician-assisted death.

Recently, Spain and Austria have legalized assisted dying for both terminal illness and unbearable suffering. In Austria, medications must be self-administered, while in Spain they can be administered by a doctor.

Despite the differences, it is clear that entitlements to assisted dying are much broader in Europe than are proposed anywhere in the British Isles. Members of Parliament at Holyrood are due to debate a similar bill covering Scotland to the one voted on at Westminster.

A law that allows terminally ill adult patients to die if they have 12 months or less to live he almost passed all the stages in the Isle of Man Parliament. The legislation is likely to receive royal assent next year, and the first assisted death on the island could occur in 2027. There is a five-year residence requirement. Jersey has also committed to changing the law enabling assisted dying for terminally ill people.

Over the last few years, voluntary assisted dying has become legal in most of Australia. Patients must be terminally ill while in New Zealand and are expected to die within six months. In eligible parts of Australia, this period is extended to 12 months for people with neurodegenerative conditions.

In both countries, patients can self-administer the lethal drug. It may also be given by a doctor or nurse, usually as an injection into a vein.

Additional reporting by Anthony Reuben and Gerry Georgieva