Assisted dying laws now apply to an estimated 400 million people worldwide, but there is no single international model. The central differences concern who qualifies, whether the person must be terminally ill, whether a clinician may administer the medication, and how requests are assessed and reviewed.
Most countries still prohibit medical assistance to end a person’s life. Where it is permitted, laws are tightly contested because they balance personal autonomy and relief from suffering against concerns about coercion, disability rights, unequal access to care, and the scope of safeguards.
The terms matter: assisted suicide and euthanasia
Public discussion often uses assisted dying as an umbrella term, but legal systems distinguish between different acts.
- Assisted suicide generally means a person takes the life-ending medication themselves after receiving medical help to obtain it.
- Euthanasia generally means a clinician administers the medication.
- Medical assistance in dying is the term used in Canada and can cover more than one method.
- Aid in dying is used in some jurisdictions to avoid the term “suicide,” which critics and supporters may interpret differently.
The distinction has practical consequences. The model proposed for England and Wales, like Oregon’s, requires self-administration. Several European systems permit clinician administration in specified circumstances.
A global picture: the principal legal models
The supplied material identifies legal assisted-dying frameworks in parts of North America, Europe, Australia, and New Zealand. Their boundaries vary markedly.
| Jurisdiction or group | Broad eligibility approach described | Terminal illness required? | Who administers medication? |
|---|---|---|---|
| Oregon and comparable US states | Mentally competent adults with a terminal illness and a limited life expectancy | Yes | The patient |
| Canada | Initially limited to people near the end of life; later expanded to certain people with irreversible illness or disability causing intolerable suffering | Not always | Not specified in the supplied material |
| Switzerland | Assisted suicide available under its long-standing framework, including for some non-residents | No terminal-only rule described | The patient |
| Netherlands, Belgium, Luxembourg, Spain, Austria | Legal frameworks extend beyond terminal illness | No | Varies by jurisdiction |
| France | A recently adopted “aid in dying” law for adults with incurable conditions causing unbearable pain | Not described as terminal-only | Not specified in the supplied material |
The table should not be treated as a substitute for legal advice. Eligibility criteria, waiting periods, professional assessments and review mechanisms can change, and the source material does not provide the full statutory rules for every jurisdiction.
The United States: Oregon’s influential terminal-illness model
The source material describes assisted dying as legal in 30 US states and Washington, DC. Oregon’s law, in force since 1997, is particularly influential because later US legislation has often followed its basic structure.
In Oregon, a person must be:
- An adult;
- Mentally capable of making the decision;
- Diagnosed with a terminal illness;
- Expected to die within six months; and
- Approved by two doctors.
The medication must be self-administered. A clinician supplies the prescription, but the person must take the medication themselves.
Since the law began, 5,520 people had received a prescription and 3,691 had died after using the medication, according to the supplied material. The difference illustrates a frequently overlooked point: receiving a prescription does not mean a person will take it. Roughly one in three people prescribed the medication do not proceed.
Oregon’s 2025 reporting also suggests that loss of autonomy is a more commonly cited concern than uncontrolled pain. Cancer was the leading underlying diagnosis among people requesting assistance, followed by neurological and heart conditions. Reported reasons included fear of losing dignity, loss of bodily control and worries about burdening relatives or friends. Inadequate pain control was also reported, though less frequently.
Opponents point to changes including the removal of Oregon’s residency requirement and the rising number of assisted deaths over time. Supporters point out that the law has retained its core terminal-illness restriction since its introduction. Both observations can be true: a law may remain limited in one respect while its practical reach changes in another.
Canada: expansion beyond terminal illness
Canada’s Medical Assistance in Dying, commonly abbreviated as MAID, began in 2016. The supplied material says it was initially limited to terminally ill people and was broadened in 2021 to include people experiencing unbearable suffering caused by an irreversible illness or disability.
That expansion has made Canada central to the international argument over whether eligibility criteria tend to widen after legalisation. Critics describe this as a “slippery slope,” arguing that broader criteria can expose disabled people and others in difficult circumstances to pressure, whether direct or indirect.
A proposed extension to people with a mental illness has been put on hold, according to the supplied material.
Use of MAID has also grown sharply. The supplied material estimates that medically assisted deaths account for about one in 20 deaths in Canada, compared with roughly one in 100 in Oregon. These figures should not be read as a simple measure of demand: the systems cover different populations and have materially different eligibility rules.
Europe: broader eligibility, distinct legal traditions
European jurisdictions do not share one uniform approach. Switzerland, the Netherlands, Belgium, Luxembourg, Spain, Austria and, most recently in the supplied material, France have legal pathways for some form of assisted dying.
Switzerland
Switzerland legalised assisted suicide in 1942 and is unusual in allowing access for non-residents through organisations including Dignitas in Zurich. The supplied material states that more than 600 Britons have died at Dignitas over the past two decades, including 43 in 2025.
Its international accessibility makes Switzerland especially visible in countries where assisted dying remains prohibited.
The Netherlands, Belgium, Luxembourg, Spain and Austria
These countries are described as allowing some form of assisted dying without confining access solely to those expected to die within a short period. That is the sharpest contrast with Oregon-style laws and with the proposed framework for England and Wales.
Broader laws can be designed around suffering from serious and incurable conditions rather than a prognosis measured in months. The trade-off is that decision-makers must assess concepts that can be harder to define consistently, including unbearable suffering, irremediability and the availability of alternatives.
France
The supplied material reports that France adopted an “aid in dying” law in August 2026 for adults with incurable conditions causing unbearable pain. As this is a recent development, readers should check the enacted text and implementation timetable before relying on any summary of eligibility or process.
Australia and New Zealand
Australia and New Zealand are among the countries said to have introduced assisted-dying laws since 2015. Their inclusion signals the continued spread of legal models outside Europe and North America, but the supplied material does not provide sufficient detail to compare their eligibility thresholds or procedural protections accurately. It would be misleading to assume that either follows the Oregon, Canadian or Dutch model exactly.
What the international comparison does—and does not—show
Comparisons can clarify choices, but they cannot settle the ethical debate. A country considering legislation must decide which safeguards it regards as non-negotiable.
The recurring policy questions are:
- Eligibility: Should access be limited to terminal illness, or extend to incurable conditions and irreversible disability?
- Capacity: How should clinicians establish that a person understands the decision and is acting voluntarily?
- Administration: Must the person take the medication themselves, or may a clinician administer it?
- Safeguards: How many independent assessments are required, and what waiting periods or review processes apply?
- Alternatives: How can lawmakers ensure that palliative care, disability support, housing and mental-health treatment are available?
- Transparency: What data should be published on diagnoses, reasons for requests, outcomes and concerns raised during review?
A common mistake in this debate is to compare headline totals without comparing the laws that produced them. A higher proportion of assisted deaths may reflect wider eligibility, different reporting methods, population size, cultural factors, or changes in medical practice—not one simple cause.
What readers should check before relying on a legal summary
Anyone seeking information for themselves, a relative or a patient should verify the law in the relevant jurisdiction through current official or specialist advice. Useful questions include:
- Is the person required to be a resident?
- Is terminal illness required, and how is prognosis defined?
- Is self-administration mandatory?
- Are multiple clinical opinions required?
- Does the law cover physical illness, disability, mental illness, or more than one category?
- What palliative-care and support options must be discussed?
- Is there an appeal, review or oversight mechanism?
More jurisdictions have created legal routes to assisted dying since 2015. The more consequential fact is that they have done so in very different ways. The boundary between a narrowly terminal-illness model and a framework based on enduring, intolerable suffering remains a central dividing line.
Sources
- Assisted dying: How laws differ around the world, published 2026-09-11.
Meta: Assisted dying laws differ on eligibility, terminal illness, self-administration and safeguards across the US, Canada, Europe and beyond.