Euthanasia vs Assisted Suicide: Country Comparisons and Debates

Introduction: A Debate at the Heart of Medicine and Morality

As doctors, we pledge to heal, relieve suffering, and uphold life. Yet, in the quietest moments beside a terminally ill patient, the question arises: what if allowing death is more humane than prolonging pain? Euthanasia and physician-assisted suicide (PAS) sit at the intersection of clinical ethics, legal frameworks, and deeply personal conviction. This issue is increasingly global in scope—each country crafting its own path. In this article, we explore how different regions approach euthanasia and assisted suicide, the ethical and medical debates at play, and what the data reveals about practice, safeguards, and societal impact.

Chapter 1: Defining the Terms: Euthanasia vs. Assisted Suicide

• Euthanasia involves a clinician administering a lethal intervention (e.g. injection) with the intention of ending life.
• Physician-Assisted Suicide (PAS) or Assisted Dying, refers to providing means (e.g. prescription medication) for a patient to end life themselves.
• Medical Assistance in Dying (MAID) is an umbrella term used in Canada and elsewhere encompassing both practices.

Legality, procedural safeguards, and terminology vary widely across jurisdictions.

Chapter 2: Where Euthanasia and Assisted Suicide Are Permitted

Europe

The first country to legalize euthanasia in 2002 was the Netherlands, under strict conditions. That law requires voluntary and informed requests, unbearable suffering, and physician consultation. Officially, in 2023, 5.4% of all deaths in the Netherlands (9,068 cases) were attributed to euthanasia—up from about 1.2% in 2003

Belgium also legalized both euthanasia and PAS in 2002, extended eligibility even to minors with mature judgment, and by 2021 the rate reached 2.4% of all deaths

Other European nations that have legalized include Luxembourg (2009), Spain (2021), Portugal (2023), Austria (PAS in 2021), Germany (decriminalized PAS in 2020). Countries such as France, the UK, and Ireland are actively debating legislation with differing proposals and levels of public support

In Switzerland, active euthanasia (administered by another) remains illegal, but PAS is permitted if performed by the patient—leading to “suicide tourism” by foreigners

North America

Canada legalized MAID in 2016, including both PAS and euthanasia. By 2023, over 60,300 deaths had occurred under MAID, representing 4.7% of all deaths in the country; cancer accounted for 63% of underlying conditions

In the United States, federal law prohibits euthanasia, but PAS is legal in several states. Oregon (since 1997), Washington, California, Colorado, Hawaii, Maine, New Jersey, New Mexico, Vermont, and D.C. allow physician-assisted dying under legislation or court rulings, each with specific criteria and reporting requirements

Mexico’s Supreme Court also ruled criminalizing assisted suicide unconstitutional, paving the way for future legislative developments

Australia & New Zealand

In Australia, euthanasia (often called "voluntary assisted dying") is governed at the state level. As of mid‑2024, all states except the Northern Territory have legal frameworks: Victoria (since June 2019), Western Australia (2021), Tasmania, South Australia, Queensland, New South Wales, with ACT joining in November 2025

New Zealand legalized physician-assisted dying in a public referendum; its law took effect in November 2021. As of March 2022, 206 applications had been made and 66 assisted deaths performed

South America & Africa

Colombia's constitutional court decriminalized euthanasia in 1997, with formal guidelines appearing in 2015, and availability extended to children over 14. Reported cases rose from 4 in 2015 to around 99 in 2022

Most other countries in Asia, Africa, and South America still prohibit both euthanasia and PAS, though debates are emerging in India and South Africa

Chapter 3: Data Trends—How Frequently Are These Practices Used?

In jurisdictions with laws, the percentage of euthanasia/PAS among all deaths has climbed steadily:

• Netherlands: ~1.2% in 2003 → ~5.4% in 2023 Belgium: 0.78% in 2008 → 2.4% by 2018
• Canada: ~1,018 MAID deaths (0.38%) in 2016 → 2.5% by 2020 → 4.7% in 2023
• Switzerland: assisted suicides rose from ~297 in 2009 to over 1,196 in 2019 (~1.4% of deaths)

These rising trends reflect broader societal acceptance, improved access, and expanding eligibility criteria, though critics warn of potential “slippery slopes”

Chapter 4: Who Seeks Euthanasia/PAS—and Why?

Studies from Belgium and the Netherlands show major motives:

• Loss of autonomy or dignity, cited in over 50‑60% of cases
• Unbearable suffering, including physical pain, psychological distress, or inability to enjoy life’s activities

In Canada, data show cancer accounts for 63% of MAID cases; cardiovascular, respiratory, neurological, and other chronic conditions constitute the rest. The average age at time of death is about 77.6 years

Some regions show rising demand from non-terminal patients or those suffering from socioeconomic or psychological distress. In Canada, physicians report requests from homeless individuals, patients with obesity, and others in existential crisis—raising concerns about inadequate safeguards and equity

Chapter 5: Safeguards and Legal Requirements

All jurisdictions with legal euthanasia/PAS implement extensive safeguards, including:

• Minimum age (18 in most, but as low as 12–16 in Netherlands; no age limit in Belgian mature minors)
• Competent, voluntary and repeated request
• Serious, incurable medical condition causing unbearable suffering
• Informed consent, second independent physician evaluation, and often a waiting period (e.g. 10 days in Canada)
• Mandatory reporting to review committees, with legal enforcement if protocol deviates

These procedural checks aim to protect vulnerable individuals while respecting autonomy.

Chapter 6: Ethical, Clinical, and Social Controversies

Medical Ethics vs. Compassion

Physicians navigate competing obligations: the Hippocratic oath’s “do no harm” versus alleviating suffering. Many medical associations (e.g. the American College of Physicians) remain opposed or neutral, citing concerns that PAS may conflict with traditional roles as healers

Slippery Slope Concerns

Critics argue expanded eligibility (e.g. to psychiatric or non-terminal conditions) may normalize euthanasia, leading to non-medical or coerced cases. Ethical thinkers report that once legal, practices often broaden—with Belgium and the Netherlands highlighted as examples

Safeguarding Vulnerable Populations

Journalistic investigations in Canada reveal tension when vulnerable individuals—homeless, poor, or emotionally distressed—request MAID. Some clinicians report moral distress, noting potential systemic failures in protecting marginalized individuals

Cultural and Religious Dimensions

Countries with dominant religious or cultural traditions—like much of Africa, Asia, and the Middle East—are largely opposed, viewing euthanasia as contrary to faith-based sanctity-of-life principles. In contrast, secularized societies emphasize personal autonomy and dignity

Chapter 7: Emerging Debates and Legislative Developments

United Kingdom & Ireland

In England & Wales, assisted suicide remains illegal under the Suicide Act 1961, punishable by up to 14 years in prison. Despite this, UK public and physician opinion has gradually shifted, with current parliamentary bills proposing eligibility for terminally ill adults with judicial or medical review processes

Debates in Scotland and Ireland are ongoing. Draft legislation proposed for England & Wales includes multiple safeguards similar to Australia and Oregon models

Slovenia

In July 2025, Slovenia’s parliament approved assisted dying legislation following a referendum. However, the National Council vetoed the bill over philosophical and ethical concerns. Lawmakers must reconsider amendments

Hi-Tech Challenges: The Sarco Pod

In Switzerland, the recently used Sarco pod, a nitrogen-based machine enabling suicide without medical involvement, sparked arrest of its inventor and public ethical debate. It underscores evolving debates about autonomy versus medical supervision in assisted dying practices

Chapter 8: The Physician’s Role—Balancing Care, Choice, and Ethics

As doctors, how do we engage with euthanasia and PAS?

1. Understand Legality: Know your jurisdiction’s laws and procedural requirements.
2. Support Patient Autonomy: Respect informed and voluntary choices while ensuring capacity.
3. Safeguard the Vulnerable: Be vigilant to psychological, social, or economic coercion.
4. Promote Palliative Care: Ensure pain and symptom management are maximized before considering euthanasia.
5. Foster Ethical Reflection: Engage with colleagues and ethicists for ongoing dialogue and support.
6. Institutional Clarity: Advocate for separate assisted-dying services or opt-out clauses for conscientious objectors

Ultimately, euthanasia and assisted suicide challenge us to hold compassion and moral integrity in equal measure.

Conclusion: Towards Thoughtful Policy, Empathy, and Care

Euthanasia and assisted suicide represent one of modern medicine’s most profound ethical and clinical crossroads. Around the world, a patchwork of laws reflects deeply rooted societal values, evolving medical ethics, and political realities. Data show increasing utilization where permitted—but also growing complexity. The debate underscores the tension between autonomy and vulnerability, relief and responsibility, compassion and tradition.

As patient advocates, physicians must be prepared to navigate these murky waters with openness, care, and respect for both life and choice.