A group of influential medical and healthcare organisations has raised ‘significant concerns’ over proposed changes to the Assisted Dying for Terminally Ill Adults (Scotland) Bill.
Seven organisations, including the Royal Pharmaceutical Society (RPS) Scotland, have written to senior figures in the Scottish government raising concerns about the potential removal of key safeguards and the risk of inadequate scrutiny.
In December, an amendment was introduced to the bill allowing pharmacists to choose whether they participate in the assisted dying process or not.
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However, the organisations have said they are concerned about the Scottish government indicating that key provisions relating to ‘no duty to participate’ are not within devolved powers and may be removed from the bill at stage three.
These issues would instead be addressed later through a Section 104 Order - secondary legislation that the member organisations say may receive limited parliamentary scrutiny.
The organisations have raised four main concerns:
- Removal of key safeguards from primary legislation;
- Risk to professional confidence and public trust;
- Inadequate scrutiny of consequential provision (a Section 104 Order);
- Implications for safe and ethical implementation.
In a letter they said: ‘The prospect of removing matters of such professional, ethical, and legal significance from parliamentary scrutiny at stage three, and deferring them to secondary legislation after the Bill has passed, raises important questions about transparency, accountability, and the robustness of the legislative process.
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‘These protections are central to the safe, ethical, and fair delivery of care, and to the confidence of our medical workforce who may be affected by the legislation.’
Their joint letter was dated yesterday (23 February) and signed by RPS Scotland, the Association for Palliative Medicine (Scotland), the Medical and Dental Defence Union of Scotland, the Royal College of General Practitioners Scotland, the Royal College of Physicians and Surgeons of Glasgow, the Royal College of Psychiatrists in Scotland, and the Royal College of Surgeons of Edinburgh.
The Terminally Ill Adults (End of Life) Bill for England introduced a similar amendment in May 2025, exempting pharmacists from participating in supplying medication for assisted dying if this is what they choose.
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In December 2025, the RPS said in a policy report that pharmacy teams should be ‘fully integrated’ into palliative and end of life care so patients can access the medicines, support and joined up care that they need.
The report called for several reforms, underpinned by a need for improved information sharing and access to patient records across the multidisciplinary team.
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