Assisted Dying Laws Compared: US, Canada, Europe — SkimNews
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- Oregon legalized assisted dying in 1997 and remains the US model, with 5,520 prescriptions and 3,691 deaths recorded since inception; a 2025 report shows 61% of patients had cancer and 89% cited loss of autonomy as a key concern, with self-administration required.
- Canada introduced Medical Assistance in Dying (MAID) in 2016 for the terminally ill, then extended eligibility in 2021 to those with 'unbearable suffering' from an irreversible illness or disability — roughly one in 20 deaths nationally are now medically assisted, compared to one in 100 in Oregon.
- Six European countries — Switzerland, the Netherlands, Belgium, Luxembourg, Spain, Austria and now France — all permit assisted dying without restricting it to the terminally ill; the Netherlands and Belgium are the only European countries to extend it to children.
- Switzerland created a 'right to die' in 1942, the world's first such law, and remains one of the few jurisdictions allowing foreigners to access assisted dying via organizations like Dignitas in Zurich, which has helped more than 600 Britons die, including 43 last year.
- Jersey received Royal Assent in July for an assisted dying bill that breaks with Westminster by allowing a doctor to administer a lethal dose intravenously — effectively voluntary euthanasia — with the first assisted death possible late next year and a one-year residency requirement.
- The Isle of Man passed an updated assisted dying bill through Tynwald after the UK Ministry of Justice declined Royal Assent earlier this year; the bill has been sent back to the UK government for a second time and includes a five-year residency requirement.
- The Northern Territory became the last Australian jurisdiction to pass Voluntary Assisted Dying legislation last month, bringing Australia into near-universal coverage alongside New Zealand, where eligibility extends to 12 months for neurodegenerative conditions.
Why it matters: The UK debate at Westminster and Holyrood insists on self-administration and terminal illness, but Jersey has already diverged by allowing doctor-administered euthanasia and the Isle of Man's bill sits with the UK government for a second Royal Assent — meaning two Crown Dependencies are now outpacing the UK on scope. Meanwhile, Canada's trajectory from terminal-illness-only (2016) to 1-in-20 deaths assisted today is the case study both sides cite, making it the live experiment that will shape whether England and Wales tighten or loosen their own proposals.
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