Tomorrow the Nuffield Trust will publish an in-depth analysis of
how other countries have implemented assisted dying and what
lessons MPs should consider ahead of the vote on the Bill a week
today.
While international experience has already informed the debate in
the UK, comparisons often focus on specific country examples and
a narrow set of legal differences. Our work provides a
comprehensive review of international evidence from 15
jurisdictions in 9 countries to show how assisted dying works in
different contexts, what uptake is like in different
jurisdictions, and how policy has evolved over time in places
with longer-standing laws.
The Nuffield Trust takes a neutral position on whether assisted
dying should be legal. This review does not make a judgement
about the effectiveness of different models, but it is designed
to inform debate and bring context to public understanding.
Key findings include:
- People who do not have a terminal illness can access assisted
dying in six of the countries we looked at. Of the systems we
reviewed, we found no examples where eligibility became more
narrow or restrictive over time, though some, such as Oregon in
the US, have remained relatively consistent. Among some systems
where assisted dying has been legal for over five years,
eligibility criteria have expanded, notably in Canada, Belgium
and the Netherlands.
- Regardless of eligibility criteria, the proportion of all
deaths which were assisted deaths has increased over time in most
countries, although assisted deaths make up only a relatively
small percentage of total deaths in any given year (ranging from
0.1 in New Jersey to 5.3% in the Netherlands in 2023).
- In almost all systems, assisted dying is publicly funded and
integrated into the health care system.
- Safeguards and requirements vary across different countries –
including how individuals' consent and decision-making capacity
is assessed, how practitioners are trained, and which staff are
permitted to provide assisted dying.
- Systems also vary in how they monitor and ensure compliance
with regulations. Some countries require a review of assisted
dying requests before they can be approved, while in other
countries such as the Netherlands, only a retrospective review of
decisions is undertaken.
Nuffield Trust Senior Fellow, Sarah Reed said:
“As assisted dying legislation is debated in the UK, the diverse
experiences of other countries offer critical learning. It can be
tempting to pick out individual international examples on
assisted dying to highlight a particular concern or benefit, but
drawing evidence from a broad range of health systems is
important.
“The variety of approaches we found reflects how different
cultural and political contexts impact how these services evolve.
The differences between countries are not just procedural – they
affect how individuals access and experience services, what roles
and responsibilities professionals hold, and how they affect the
system at large. If assisted dying is legalised in the UK, these
choices need to be carefully thought through.
“Our analysis also shows that there are some common themes when
countries implement assisted dying, including the way these
services are funded and the tendency for eligibility to expand
after implementation.”
