A law on assisted dying could be passed in England and Wales as early as next year, with a private member’s bill on the issue set to be tabled in Parliament.
Sir Keir Starmer announced before the election that he would allow time in the Commons for a free vote on assisted dying – the process of giving someone medical assistance to end their life, typically if they have a terminal illness – after a campaign by TV presenter Dame Esther Rantzen.
Assisted dying is currently banned across the UK and can lead to prosecutions for crimes including murder and manslaughter.
While it is already legal in several countries worldwide, including Switzerland, Spain, the Netherlands, Canada and parts of the United States, the circumstances in which it is permitted differ.
Here are the countries where assisted dying is currently legal, as well as how it works in each nation.
Switzerland
The first country to have legalised assisted dying, the practice has been permitted by law in Switzerland since 1942.
Adults are eligible to request assistance in dying as long as they are not doing so with “selfish motives”, but the process is only legal if the patient is the one administering the medication to themselves. Otherwise, if a doctor administers the life-ending drugs themselves rather than just supplying them, it is classed as euthanasia, which is against the law.
Switzerland also draws people seeking assisted dying from around the world due to Dignitas, a non-profit which has run assisted dying clinics in the country since 1998.
UK membership of Dignitas jumped to 1,900 people in 2023, the organisation said, marking a 24 per cent rise on the previous year.
Dignitas also said 40 people from the UK ended their lives at its clinics in 2023, the highest level since 2019. It provided its service to nearly 600 Britons between 1998 and 2023.
The Netherlands
Assisted dying was legalised in the Netherlands in 2002.
The law there differs from Switzerland’s as it includes euthanasia – making the Netherlands the first country to legally permit the practice of doctors administering life-ending medications.
Meanwhile, terminally ill children can also request assisted dying from the age of 12, though they still require parental consent until they are 16.
Since the process was legalised, the number of reported cases of assisted death has increased almost every year, including a record total of 9,068 assisted deaths – where the medication is either supplied or administered by physician – last year.
That was five times higher than the total number of assisted deaths in the Netherlands the year the law was first passed, and also represented more than five per cent – the highest proportion in the world – of the country’s total deaths in 2023.
Belgium
Belgium also legalised assisted dying in 2002, and is alongside the Netherlands as two of the countries with the most widely encompassing laws on the matter.
It allows both euthanasia and assisted dying, for – as well as the terminally ill – people living with chronic, debilitating, and incurable physical or mental conditions that make dignified life impossible. Age restrictions are not in place, but parental consent is required for those under the age of 18.
Like the Netherlands, Belgium also allows advance directives so that assisted dying can be administered in accordance with the person’s wishes even if they are no longer conscious to confirm those wishes.
In 2023, more than 3,400 patients underwent euthanasia in Belgium a 15 per cent increase compared to the previous year.
Canada
In Canada, assisted dying was legalised as an option to “incurably ill” and mentally competent adults in 2016.
The law, which calls the practice “medical assistance in dying” and also covers physician-assisted deaths (euthanasia), was expanded in 2021 to include some people with chronic illnesses or disabilities, who “have enduring and intolerable physical or psychological suffering that cannot be alleviated under conditions the person considers acceptable.”
According to an annual report, 2022 saw 13,241 assisted death provisions reported in Canada, accounting for just over four per cent of the country’s total deaths that year.
That represented an increase of 31 per cent compared to the year before, with the total number of medically assisted deaths reported in Canada from the introduction of the country’s federal legislation in 2016 until 2022 standing at 44,958.
New Zealand
Both euthanasia and assisted dying were legalised in New Zealand in November 2021, under the End of Life Choice Act.
To be approved, patients must be terminally ill, aged 18 or older, in their final months of life and have their condition assessed by two doctors.
Almost three years on, nearly 2500 applications for a physician-assisted death in New Zealand have been filed, with just under 1,000 people having gone through with the practice as of September 2024.
Spain
Similarly, physician-administered and physician-assisted deaths have been permitted in Spain since the country’s Law on Euthanasia came into effect in June 2021.
The requirements include prospective adult patients having “a severe, chronic and debilitating condition” or “a severe and incurable disease”, as well as showing “the necessary competence to decide” to go through with the procedure.
According to a report released in November 2023, Spain had 173 requests for euthanasia presented in the first six months of the new law, with 75 of those being carried out.
The following month, local media cited Spanish health ministry figures in reporting that 288 assisted deaths were carried out in 2022, from 576 applications.
USA
While access to assisted dying in the US is not available nationwide, it is currently legal in multiple states.
Oregon was the first US state to legalise medically assisted dying, doing so in 1994, with California, Colorado, Hawaii, Maine, Montana, New Mexico, New Jersey, Vermont, Washington and Washington DC all since following suit with similar laws of their own.
Laws in the US are more like those in Switzerland than the likes of Canada, the Netherlands and Belgium, in that they only include physician-assisted deaths, with euthanasia prohibited.
Axios reported that as of earlier this year, several others states were also considering bills legalising assisted dying, which typically allow mentally competent people with six months or less to live to request prescriptions from a doctor that they can take at home if and when they decide to end their lives.
A study published in the Journal of the American Geriatrics Society in 2022 revealed that about 5,330 people had died with medical assistance in the US as of 2020, while 8,451 had received a prescription for life-ending drugs.
Where else has legalised assisted dying?
Other countries to with legislation in place that permits assisted dying include Austria, Luxembourg, Ecuador and Colombia.
Austria’s law, which took effect in 2022, requires people to produce a diagnosis of a terminal illness or permanent, debilitating condition, as well as assessment by two doctors and confirmation that the patient can make their own decisions. It excludes minors and those with mental health conditions, and does not cover euthanasia.
Colombia has permitted euthanasia since 1997. Since 2018 that has included for children over the age of six (with parental consent required until the age of 14), but it was only in 2022 that assisted dying was decriminalised where someone is “diagnosed with an injury or serious or incurable disease which causes intense physical or mental pain they find incompatible with living a dignified life.”
In Luxembourg, euthanasia and medically assisted deaths have been legal since 2009 where a person voluntarily requests it due to their suffering “from an incurable condition” that leaves them “constantly in unbearable physical or mental pain.” As well as mentally competent adults, the practice is permitted for those between the ages of 16 and 18, but requires parental consent.
Most recently, Ecuador decriminalised euthanasia and assisted dying in 2024, following Colombia to become the second South American country to do so. It allows the “option of ending the intense suffering caused by a serious and irreversible bodily injury or a serious and incurable illness.”
What countries are considering legalising assisted dying?
Alongside the UK, several other countries have also considered legalising assisted dying to various degrees in recent years.
In Australia, voluntary assisted dying had been legalised in every state, and a scheme permitting it will go into effect in the Australian Capital Territory next year, but the practice is not yet allowed in the country’s Northern Territory.
Emmanuel Macron backed a bill legalising both euthanasia and assisted dying in France, for end-of-life adult patients with incurable illnesses who are capable of making their own decisions. Its first reading was interrupted when the French president dissolved the Assemblée and called for snap elections in June, but new prime minister Michel Barnier has hinted that the issue could be back in the French Parliament soon.
Meanwhile in Germany, euthanasia remains illegal but assisted dying is understood to be something of a legal grey area.
The country’s Federal Constitutional Court lifted a ban on assisted dying in 2020, citing the right to personal freedom, but this is reportedly yet to lead to any legislation to regulate the practice.
