Abortion Law: Comparative Approaches to Reproductive Regulation

Following the Supreme Court's decision in Dobbs v. Jackson Women's Health Organization (2022), the United States has become a patchwork of widely divergent state laws, ranging from near-total bans in some states to robust protection in others. This state-by-state variation is unique among comparable democracies and represents a dramatic shift from the near-uniform national standard that existed under Roe v. Wade.

The United Kingdom permits abortion up to 24 weeks of pregnancy under the Abortion Act 1967 when two doctors certify that specified conditions are met, with no gestational limit where there is a risk to the woman's life or serious fetal abnormality. Germany technically criminalizes abortion but permits it within the first 12 weeks following mandatory counseling and a three-day waiting period, treating the procedure as unlawful but not punishable.

France enshrined the right to abortion in its Constitution in 2024, allowing the procedure up to 14 weeks of pregnancy on request and later for medical reasons. Ireland repealed its constitutional abortion ban by referendum in 2018, subsequently enacting legislation permitting abortion up to 12 weeks of pregnancy on request and later in cases of risk to life or health or fatal fetal abnormality.