Voluntary assisted dying—Australia in an international context

Since 2017, highly prescriptive voluntary assisted dying (VAD) laws have been adopted in all Australian states and one self-governing territory. The unique features of the Australian model and salient differences between Australian states and territories are poorly understood internationally. In this article, we provide an overview of the distinctive features of the Australian model of VAD and engage in a detailed comparison with legislation regulating assisted dying or euthanasia in other jurisdictions. We focus on variations in the eligibility criteria for accessing VAD, the request and assessment process, and the permitted method/s of administration. We also consider different international regimes permitting conscientious objection and regulating institutional objection to participating in VAD. Several distinctive features of the Australian model—such as a differential timeframe to death for different medical conditions, express residency requirements, the prohibition on health practitioners initiating conversations about VAD, and legal restrictions on the availability of practitioner administration—have already served as models for other countries in enacting VAD laws. As other countries consider legalizing the practice, there is much to learn from the Australian model.