The transnational network of the surrogacy industry 1/3

Cover image: Photo project about surrogacy in Ukraine by María Volkova.

Patricia Simon, Queralt Castillo, Lisa Torosyan, María Volkova

The complex transnational surrogacy system set up across Europe includes dozens of subsidiaries, front companies, shell corporations, and foreign business registrations—some located in tax havens—and generates more than €17 billion annually. In Europe, altruistic surrogacy is legal—with regulations differing per country—in the United Kingdom, Denmark, Ireland, the Netherlands, Belgium, Portugal, Cyprus, and Greece. Commercial surrogacy is legal in Ukraine and Georgia.

At number 51 Vasil Barnov Street in Tbilisi, Georgia, just steps from the Chinese embassy, employees at the Georgian German Reproductive Center (GGRC) are finishing up for the day. Inside this prestigious assisted reproduction clinic, the sterile white light—mirroring the lab coats worn by medical staff—soon becomes overwhelming. In the waiting room, a few couples, dressed in hygienic shoe covers, speak quietly in Georgian. People enter and exit, some carrying documents to hand over at reception. Among them, several young women appear to be there either as egg donors or potential surrogate mothers—or perhaps just seeking information.

The atmosphere is heavy, burdened not only by the clinic’s intense heating system—compensating for the approaching Caucasian winter—but also by the gravity of the place. Every movement in the bustling reception area feels weighed down.

1,500 kilometers away, in the Ukrainian city of Kharkiv, the scene at the Feskov clinic is similar—though complicated by the near-daily bombings and proximity to the Russian border, less than 40 kilometers away. To adapt to the situation, this surrogacy clinic now offers a wider range of services: clients can send their genetic material by courier and plan for the baby to be delivered by the surrogate mother in Greece or Georgia (where commercial surrogacy is legal), avoiding travel to an active war zone. Clients can also select the baby’s sex, appealing to families with children of one gender who wish for another. According to staff—surrounded by portraits of plump, pale, blue-eyed infants—business is booming, with increasing numbers of Chinese and Arab clients.

The Russian invasion has also shifted the profile of surrogate mothers. Besides poor Ukrainian women, agencies now recruit from Kazakhstan, Tajikistan, Uzbekistan, and other nations. This trend is also visible in Georgia, where demand has soared since the war in Ukraine began, driving up prices. In this Caucasian country of just over three million people, finding young Georgian women willing to be surrogates is becoming harder—prompting clinics to look elsewhere.

An expanding business

Surrogacy is a growing global business—and everyone wants a piece of the pie. According to The Economist, the industry’s revenue rose from over €13.3 billion in 2022 to €17 billion in 2023, with projections topping €132.7 billion by 2032.

On April 23, 2024, the European Parliament voted to revise the EU’s anti-trafficking directive, including forced surrogacy under the definition of human trafficking. The proposal passed with 563 votes in favor, seven against, and 17 abstentions.

Yet European couples continue to travel to countries inside Europe but outside the EU, like Ukraine and Georgia, to have children via surrogacy. Upon returning home, nothing stops them from registering these children—though this is illegal. Human rights defenders like Maria Dmitrieva, director of the Center for the Development of Democracy, argue, “If the EU and its member states prohibit their citizens from engaging in surrogacy, we end this exploitation of women and minors. Only 5% of surrogacies are for Ukrainian couples—the rest are for foreigners.” In Georgia, 90% of clients are foreign.

Surrogacy is a growing global business—and everyone wants a piece of the pie.

Transnational chains

The United States remains the preferred destination for those with more resources, as it was the first country to legalize surrogacy and the one that has most promoted it through its audiovisual industry. Furthermore, the fact that in several states a judge determines the affiliation with the intended parents, rather than having to complete a consular registration or adoption process upon arrival in the country of origin—as it happens in other destinations—is an advantage for those who resort to surrogacy there.

However, more couples are now turning to Greece, Ukraine, and Georgia to get a baby. In Europe, the surrogacy industry forms a transnational chain of coordinated and interdependent players—from legal firms and intermediaries to clinics. Months of investigation across Spain, Greece, Ukraine, and Georgia reveal common patterns: complex corporate structures, companies registered under proxies, affiliations with international conglomerates, and incorporation in jurisdictions unrelated to their operations—including tax havens.

At the end of this journey toward parenthood—taken mainly by couples from countries where surrogacy is illegal—are women who carry babies in exchange for money, usually to escape or ease dire economic situations for their families.

“I had a one-year-old and couldn’t even pay for the room we lived in,” says Viktoriya, speaking from a struggling neighborhood on the outskirts of Kyiv. “So I decided to be a surrogate mother to buy a house for myself and my child.” She adds, “I had no say in anything—they [the doctors at the clinic] took all the decisions. I overheard them talking about us like we were ‘incubators.’ But the doctors and nurses were polite and kind. I had to take a test every month because smoking and drinking were forbidden. If I followed the rules, they gave me extra money,” she says, cradling her young daughter.

In Greece, altruistic surrogacy—surrogacy for which the surrogate mother is not directly compensated—has been permitted since 2002 for Greek couples and since 2014 for foreign couples as well. In the case of the Hellenic country, this procedure is regulated by law, and the rules are clear: there must be judicial approval specifying that the woman cannot carry a pregnancy, and surrogate mothers cannot be compensated with more than 20,000 euros for pregnancy-related fees.

Despite being supposedly altruistic, if one looks at the statistics, the data offers clues about who undergoes this procedure in Greece: only 35% of surrogate mothers are from the Hellenic country. The rest come mainly from Poland, Bulgaria, Georgia, Albania, and Romania. Of all the foreign women who choose to be surrogates, 81.7% come from Eastern Europe. Furthermore, several recent scandals in the country show that, despite having a clear law, the industry knows how to exploit legal loopholes.

In countries where commercial surrogacy is still illegal, industry players often push for “altruistic” surrogacy legalization. As Miguel González Erichsen, lawyer and founder of the Spanish agency Universal Surrogacy, explains, “The topic is still too controversial. As soon as money is mentioned, people pull back.” But once altruistic surrogacy becomes normalized—despite still being paid—it becomes easier to legalize the commercial model. “Sooner or later, it will happen,” he insists.

Click here for the next piece on Greece and the problems of altruistic surrogacy.

This report is part of the investigation into the surrogacy industry developed with funding from Journalismfund Europe and published in Spanish in lamarea.com.