Jun 182025
By the UK DDPO Monitoring Coalition June 2025
Introduction
-
- The Equality Impact Assessment for the Terminally Ill Adults (End of Life) bill was published alongside the impact assessment on 2 May 2025.
-
- For a bill that proposes such fundamental changes to the practice of medicine in England and Wales, this was inexcusably late on in its passage through Parliament.
-
- Due regard for equalities impacts should occur at the beginning of any new initiative and inform the development of that initiative. An EqIA should not be treated as a bolt on extra.
-
- We have significant concerns about the content of this EqIA and agree with commentators who have raised concerns about its adequacy.1
-
- It takes at face value safeguards contained within the bill despite concerns raised by numerous professional bodies, organisations and individual witnesses as to their lack of strength.
-
- It also misses a number of potentially significant adverse equalities impacts and therefore also fails to propose measures to mitigate the risk of those.
-
- A criticism of the passage of the bill shared by doctors and Deaf and Disabled People’s Organisations (DDPOs) is the lack of engagement and account taken of our respective views, informed by expert opinion and lived experience, as well as those of other marginalised groups.2
-
- The EqIA is one example where our input would have been beneficial.
Summary of concerns
-
- Lateness of publication – the EqIA was published on 2 May, more than a month after the end of Committee stage and just two weeks before the first report stage debate.
-
- Coercion – the EqIA gives an inadequate assessment of risks of coercion and the strength of safeguards contained within the bill.
-
- Capacity – the EqIA fails to note question marks regarding the appropriateness of the bill’s use of the Mental Capaity Act (MCA) as a safeguard.
-
- Lack of disability understanding – mental health is inappropriately included as a separate category distinct from disability.
-
- Adverse equalities impacts gaps and omissions – there are a number of potential adverse equalities impacts relevant to the bill that are not included within the EqIA.
-
- These include:
-
-
- Disability – risk due to inadequate services to live
-
-
-
- Disability – risk of medical coercion
-
-
-
- Disability – risk from failure to exclude anorexia and voluntary stopping of eating and drinking
-
-
-
- LGBTQ+ – risk from fear of accessing palliative care services due to discrimination
-
-
-
- Racialised communities – lack of awareness and lower referral levels for end of life services
-
-
-
- Socio-economic disadvantage – risk of seeking assisted dying as a response to poverty
-
-
-
- Women – risk of coercion owing to inability to continue care-giving roles within the family
-
-
-
- Intersectional impacts for Disabled people experiencing socio-economic disadvantage; members of the LGBTQ+ community living with mental distress; women experiencing socio-economic disadvantage who are therefore at higher risk of domestic abuse
-
-
-
- Wider societal impacts including risk of an increase in non-assisted suicide rates and increased levels of disability hostility and hate crime
-
7. The EqIA is unfit for purpose and increases our already significant concerns regarding the adequacy of safeguards in the bill and its potential to cause adverse equalities impacts.
2 https://news.sky.com/story/its-simply-not-safe-a-thousand-doctors-write-to-mps-urging-them-to-vote-against-assisted-dying-bill-13380847
For the full document, download the Response to EqIA (.docx format)
