The notion of the ‘selfless surrogate’ is perhaps the most insidious fiction devised by enterprising profiteers. Politically, it is often illustrated through carefully chosen anecdotes, for example the sister who carries a child for her sibling after cancer treatment or the mother who does the same for a daughter left infertile by chemotherapy. Such cases may well exist in isolated instances, yet no reliable data supports their prevalence.
The heart-warming stories serve as a gateway, where emotion trumps fact – a principle that applies in this industry as much as anywhere else. In reality, legalising so-called altruistic, or ‘non-commercial’, arrangements provides those profiting from the system with precisely the respectable façade they need to conceal an underlying business.
The reproductive industry still profits
‘Non-commercial’ does not mean unproblematic. All ethical, medical and human rights concerns remain, regardless of whether money changes hands. Nor does it answer the fundamental question of whether a child can be given away at all. In every case, a child changes hands, leaving the underlying dilemma unresolved. In practice, the supposedly non-commercial model quickly reveals that money continues to flow.
Costs for intermediary agencies and medical providers remain unchanged, including egg donation, transport, medication and IVF procedures – along with all the associated ethical concerns, from embryo selection to the consumption of embryos. For well-paid clinics, brokers and lawyers, nothing changes. They continue to profit just as they do in countries where commercial surrogacy is legal. A commercially driven infrastructure is thus allowed to expand unchecked. Only the incubator, the woman, is expected to become cheaper, as the sole party who is not meant to be paid.
Women are paid under a different label
Even that claim does not hold. In practice, money does reach the women involved; they would be foolish to give their bodies away for nothing. It is simply not called payment, but ‘compensation for expenses’. Internationally, such frameworks are known as ‘expenses-only’ arrangements. What qualifies for reimbursement is highly flexible. Travel costs, clothing, lost income and childcare at home during the pregnancy may all be included.
The term ‘loss of earnings’ refers to income forgone during pregnancy. In reality, this is typically calculated on the basis of average wages in the woman’s home country – if she was in paid work at all. That logic almost invites the search for women in countries where incomes are already low. In Ukraine, average monthly earnings for women are around €350. In Colombia, €200 is considered a reasonable income. In India, millions of women live hand to mouth. It is no coincidence that the market flourishes precisely in regions marked by poverty and especially by the poverty of women.
Mexico’s surrogacy hub lies in the state of Tabasco, one of the poorest regions in the country. If a woman’s annual income amounts to no more than €2,000 to €4,000, and she is offered €8,000 in ‘expenses’, the sum may appear modest by European standards but can represent several years’ income locally. For wealthy Europeans, it is a bargain, one that effectively exploits the economic vulnerability of women elsewhere. ‘Colonialism’ would be a mild description of what is taking place.
England as a case study in contradiction
In England, only altruistic surrogacy has been legal for three decades. Lobbyists have long argued for the legalisation of a commercial model, yet proposals were rejected in 2023 by a joint report from the Law Commission of England and Wales and the Scottish Law Commission. Even so, the number of children born through surrogacy remains uncertain. The commissions themselves acknowledge that not all such births are officially recorded. In 2021, for instance, around 450 cases were documented. Without mandatory registration, however, neither the number of private arrangements nor the sums involved is known.
Agencies such as Brilliant Beginnings operate openly, offering to match intended parents with surrogates and provide legal support for fees of £25,000 to £30,000, excluding the surrogate’s ‘expenses’ and medical costs. Although the business model labelled ‘altruism’ clearly generates revenue at multiple levels, such agencies are even recommended by public bodies, including the Scottish Government.
It remains unclear whether the surrogate receives any share of these agency fees. Another provider, Sensible Surrogacy, estimates total costs in England at a minimum of £50,000. Court rulings allow ‘expenses’ for the surrogate of up to £25,000, covering items linked to pregnancy such as clothing, antenatal classes, holidays, dental treatment, insurance and vitamins. In lower-income segments, this amounts to more than a year’s salary. The supposedly altruistic model thus serves as an entry point into a commercial market.
A gateway to the grey area
England also illustrates a familiar pattern: legalising an altruistic framework creates an environment in which illegal practices can operate beneath the radar. Authorities often struggle to distinguish between domestic illegality and services that are legal abroad, making enforcement difficult.
In 2022, the global surrogacy provider New Life Global came under scrutiny over allegations that it had put the health of its surrogates at risk. The company, headquartered in London, says it has facilitated the birth of more than 7,000 children worldwide. Its founder, Georgian physician Dr Mariam Kukunashvili, presents a lavish lifestyle on social media and has been involved in academic projects at the University of Cambridge as an expert on surrogacy in Georgia.
While in England the company frames its role as arranging meetings with parents ‘who are willing to talk about surrogacy/egg donation’, it operates clinics and offices in Georgia, Ukraine, China, India, South Africa, Mexico and Poland. In those jurisdictions, reproductive techniques are legal that cannot be officially offered to clients in England in the context of IVF, including the transfer of three or four embryos at the same time, sex selection and eugenic practices aimed at excluding embryos with illnesses.
Through targeted Facebook advertising in ten languages, the company has recruited young women globally, offering sums that in their home countries can represent several years’ income. In such a legal grey area, it becomes impossible to track which services are genuinely altruistic, where fertilisation procedures take place, or how funds are ultimately distributed. Operating from within the British legal framework appears to offer considerable advantages. Similar dynamics are likely to emerge in any country that introduces an altruistic model, effectively inviting the growth of a parallel commercial market.
Greek ‘altruism’
Greece provides a striking example of how an ostensibly altruistic system can be commercially exploited and abused once it is permitted. There, surrogates may receive up to €10,000 in ‘expenses’, and arrangements are supposed to require prior court approval under the supervision of a state authority.
In practice, the situation has been very different. In the summer of 2023, police on Crete dismantled a human trafficking and surrogacy ring linked to the Mediterranean Fertility Center. Investigators documented 182 cases of ‘exploitation of women in egg retrieval and surrogacy’ within a nine-month period alone. The operation was part of an international network of brokers. Women from abroad were brought to Greece to serve as egg donors and surrogates. During raids on 14 fully equipped, monitored apartments, authorities found around 30 women from Moldova, Ukraine, Georgia, Romania and Bulgaria.
Police estimate that the organisers retained around 70 per cent of the profits, while clients from around the world paid between €70,000 and €100,000 per child. Among those arrested were not only the 73-year-old clinic operator and a midwife, but also the head of the state authority responsible for overseeing assisted reproduction, who was subsequently dismissed by the Greek health minister for involvement in the scheme.
According to investigators, the network had been active for decades across several locations in Greece. Charges include human trafficking, facilitating the adoption of minors, the sale of genetic material and fertilised eggs, falsification of medical records, issuing fraudulent medical certificates for court use, sham marriages, fraud and bodily harm. With profits of €70,000 per child, the incentives are considerable. On paper, however, Greece – like England – continues to present a system built on ‘selfless’ surrogacy.