Across Europe, several countries have legalised assisted dying: Switzerland, the Netherlands, Belgium, Luxembourg, Spain, Austria, Portugal and, most recently, France.
Eligibility criteria vary widely. Some jurisdictions allow assisted dying for people who are not terminally ill, while others, including France, restrict it to adults with serious incurable illnesses nearing the end of life.
Portugal’s law was approved in 2023 but is not yet in force because of court and regulatory delays.
In 2025, Tuscany became the first region of Italy to establish a legal process for medically assisted suicide. Earlier rulings by the constitutional courts in both Italy and Germany removed criminal penalties for assisted suicide in certain circumstances.
The Netherlands and Belgium both legalised assisted dying more than 20 years ago for patients experiencing unbearable suffering from an incurable illness, including mental health issues. It has since been extended to children – the only European countries to allow this. Both allow euthanasia – or physician-assisted dying.
Spain and Austria legalised assisted dying for both terminal illness and intolerable suffering in 2021 and 2022, respectively. In Austria, the drugs must be self-administered, whereas in Spain a medical professional can administer them.
In England, Wales and Scotland, parliament has so far rejected assisted dying proposals.
But assisted dying has already been legalised in one part of the British Isles.
In July, Royal Assent was given to a bill in Jersey. Unlike at Westminster and Holyrood, the legislation was introduced by the Jersey government, which says it will take about 18 months to set up the service. The first assisted death could happen late next year. There will be a residency requirement of one year, in a bid to prevent so-called ‘death tourism’.
The measure, which most sets apart the Jersey legislation from the rest of the British Isles, concerns the manner in which those eligible for an assisted death can end their lives.
Individuals will be able to choose to have a doctor administer a lethal dose intravenously, as happens in Spain, Canada, New Zealand and most of Australia.
This is, in effect, voluntary euthanasia. It has become the preferred method of assisted dying in jurisdictions which allow this choice.
The laws proposed at Westminster, Holyrood and Tynwald – Isle of Man – all state that death must be by self-administration, which usually means the individual swallowing a lethal dose.
The Isle of Man assisted dying bill was passed by Tynwald (the Manx parliament) in March last year. As a UK Crown Dependency – like Jersey – it could not become law until granted Royal Assent.
This was declined earlier this year by the UK Ministry of Justice, but Tynwald has since passed an updated bill which has been sent back to the UK government for a second time.
If Royal Assent is granted, the Isle of Man expects the service to be operational next year. There is a residency requirement of five years.
