The United Kingdom’s recent vote to move toward the legalization of assisted dying represented a historic moment for the country — but it also mirrors a wider trend in Europe.
Countries are on a path to liberalize their laws to expand end-of-life options to include euthanasia and assisted suicide.
To some experts, the latest position in the U.K. reflects what is a growing and inevitable trend among Western European countries. Various forms of assisted dying are already legal in Austria, Belgium, Luxembourg, the Netherlands, Spain and Switzerland.
“It will not happen in all countries at once, but especially in Western Europe and Northern Europe, if there are no laws available yet, there will be an urge to have such laws,” said Martin Buijsen, professor of health law at the Erasmus University Rotterdam. “I think that’s inevitable.”
But to others, there are concerns that existing laws are already being pushed beyond their intended purpose, and fears that this slow trudge toward assisted dying being the norm could lead to harm — especially to vulnerable people.
In Switzerland, for example, the recent use of a suicide pod stirred controversy and led to several arrests, while in the Netherlands, young people with mental health conditions are also legally taking their own lives with help from the state.
“I have seen no jurisdiction in which the practice has not expanded, not one single jurisdiction,” said Theo Boer, professor of health care ethics at Protestant Theological University. “By imposing really strict criteria we can slow down the expansion … but they will not prevent the expansion.”
For the U.K. this was the country’s second attempt to pursue such a law. This time it heeded lessons from its first failed attempt (making the conditions more restrictive) — and perhaps from stories from across the Channel.
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Learning the lessons
Assisted dying can refer to both euthanasia and assisted suicide. In euthanasia, a physician or provider administers a patient a fatal drug to deliberately end their life; while for assisted suicide the patient is legally prescribed lethal drugs they must take themselves to end their own life.
In several of the countries that have legalized assisted dying, the number of people using it to end their lives is increasing. In 2023, 9,068 people died from assisted dying in the Netherlands — 5.4 percent of deaths that year. This is up 4 percent compared with 2022 and up 87 percent from 2013.
Similarly, in Belgium there were 3,423 cases of euthanasia in 2023, up 15 percent compared with the previous year and comprising 3.1 percent of total deaths in the country.
The Netherlands and Belgium were the first European countries to legalize euthanasia in 2002.
Some have raised the alarm at the increasing number of people choosing to end their lives, warning governments debating similar laws to be aware of this phenomenon.
“What I saw was not only the increase in the numbers — which for me was a sign that it was no longer the last exception, the last resort — but it became more and more a default way to die,” said Boer. “In addition to the numbers, we saw an expansion of the pathologies underlying euthanasia requests.”
Boer had initially supported the Dutch euthanasia law and was a member of the Dutch euthanasia review committee. But he has since become an outspoken critic of this law and has warned other governments debating similar bills of the possible “side effects.”
The rising number of patients — especially young people — with mental health disorders dying by euthanasia has also spurred fierce debate in the Netherlands, Buijsen said. The number of euthanasias for patients with psychiatric disorders doubled over the last five years, from 68 to 138. Similar debates arise around cases of minors and patients with dementia, he said.
But it’s not a one-size-fit-all. According to researchers at the University of Bologna, the proportion of euthanasia and assisted suicide on overall deaths “continues to vary widely” in countries where the practice has been legalized for years, “mainly due to the circumstances under which [they] were adopted into law and the different practices approved.”
Switzerland, for example, is one of the most popular destinations for foreigners looking to access assisted dying, and has been offering legal assisted suicide since 1942.
Political and social barriers
It has taken some countries several years to push their assisted dying laws over the finish line, amid opposition from conservative parties, religious institutions and highly emotive debates.
The Portuguese parliament approved an euthanasia bill four times over three years, but conservative President Marcelo Rebelo de Sousa vetoed all drafts. Eventually, the parliament overturned his veto in 2023 and forced him to sign the bill. But even today, the legislation has not been published in the country’s official journal, meaning it’s not in effect.
While in countries such as Italy and Ireland, the powerful presence of the Catholic Church has historically steered the conversation away from legalization for years. It’s only recently, however, that things are changing.
In Italy, the country’s Constitutional Court ruled in 2019 that assisted suicide was permissible when patients are able to make decisions and are in overwhelming pain. This led to Italy’s first case of assisted suicide in 2022 — despite there being no law to allow it.
While in Ireland, progress on the debate shows the Church’s influence on policy may be weakening. Irish MPs earlier this year endorsed a parliamentary report calling for assisted dying and presented a “Voluntary Assisted Dying Bill 2024” to the lower house in June.
But Ireland is also among a group of countries impacted by political upheaval. The Irish bill lapsed with a snap election and the dissolution of the Dáil. Similarly, France was debating an assisted dying bill earlier this year, but the process was interrupted by the dissolution of the government and subsequent snap election.
And in Iceland, MPs presented a bill on euthanasia in March 2024, but the government fell in October, leading to a parliamentary election in November.
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Timing is everything
Timing and a country’s political landscape play a crucial role in determining the success of such proposals. And while the issue does not fall neatly along party lines — some Labour MPs in the U.K. were very vocal in criticizing the change of law — a left-leaning government or parliament are much more likely to pass similar bills.
At the same time, conservative figures such as Boris Johnson and Marine Le Pen have spoken against euthanasia. In Spain, far-right party Vox challenged the country’s euthanasia law in 2023, but failed. Spain passed its law to legalize assisted dying in 2021.
“If the [U.K.] vote had been taken before general elections, the outcome might have been somewhat different,” said Buijsen. “You will need, in some way, a kind of a progressive majority in parliament in order to have these laws passed.”
The requirements of accessing assisted dying also vary greatly. While some countries, like the British bill, require the patient to have a terminal illness, others such as Belgium and the Netherlands only require that the patient is experiencing constant and unbearable suffering with no cure or prospect of improvement, including psychological suffering.
Other Western European countries to have approved assisted dying include Luxembourg in 2009 and Austria from 2022. Countries including Scotland, Jersey and the Isle of Man have started the debate and made attempts to introduce legislation in recent years.
In Germany, assisted dying falls into a gray area. The practice is illegal but the Federal Constitutional Court decriminalized it in 2020.
A geographical divide
While Western European countries are increasingly entertaining the assisted dying debate, Eastern and Central Europe are moving at a much slower pace. No countries in Eastern Europe have legalized assisted dying or are currently entertaining legislative proposals.
But that doesn’t mean the topic is not entering public discussions.
Veljko M. Turanjanin, law professor at the University of Kragujevac, in Serbia, said the country has seen several discussions to legalize euthanasia, as the public opinion and many medical professionals seem to be in favor. But the strong influence of the Orthodox Church has slowed progress, he said.
“I think in the state where the government and the Church are linked close, it will not be an easy task for the government to pass such kind of legislations,” Turanjanin said.
But when countries in the region do eventually move toward legalization, surrounding countries are likely to follow suit, he said.
“I think when [Serbia and Croatia] legalize euthanasia or assisted suicide, the other countries will do the same.”
