Approximately 400 million people globally reside in jurisdictions where assisted dying has been legalized, with significant variations in how these laws are structured and implemented. Recent years have seen multiple countries adopt or modify legislation permitting medical help to die, including Canada, Australia, New Zealand, Spain, Austria, and France, which adopted an aid in dying law earlier this year for adults with incurable conditions causing unbearable pain.
In the United States, assisted dying is permitted in 13 of 50 states plus Washington DC. Oregon, which legalized the practice in 1997, has become a model for other American jurisdictions due to its nearly 30 years of experience. Oregon restricts eligibility to terminally ill, mentally competent adults expected to die within six months, with approval required from two physicians. Since 1997, 5,520 people have received prescriptions for lethal medication, resulting in 3,691 deaths. A recent report indicated that among 400 patients who took lethal medication last year, 89 percent cited loss of autonomy as a key concern, with other factors including loss of dignity (65 percent), loss of bodily control (47 percent), and concerns about burdening family (43 percent).
Canada’s approach demonstrates significant differences from Oregon’s framework. Medical Assistance in Dying was introduced in 2016 for the terminally ill but was extended in 2021 to include those experiencing unbearable suffering from irreversible illness or disability. The uptake has been substantial, with roughly one in every 20 deaths now medically assisted compared to approximately one in 100 in Oregon.
European approaches vary considerably. Switzerland, the Netherlands, Belgium, Luxembourg, Spain, Austria, Portugal, and France permit assisted dying, with eligibility criteria differing widely. The Netherlands and Belgium allow euthanasia for patients experiencing unbearable suffering, including those with mental health conditions, and have extended access to children. Spain and Austria legalized assisted dying in 2021 and 2022 respectively, with differences in whether medical professionals or patients administer the lethal medication. In the British Isles, Jersey legalized assisted dying in July, with the first assisted death potentially occurring late next year, while England, Wales, and Scotland have rejected proposals.
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