Illustration by Z. Coşkun Özcan. 

Wombs for Hire: Inside Europe’s Underground Surrogacy Networks

Unethical practices and differing legal regulations in the global surrogacy market—especially along the Turkey-Georgia-Northern Cyprus route—underscore the need for international oversight

∙ SEDA KARATABANOĞLU ∙ ZEYNEP YÜNCÜLER

25.12.2024

The global surrogacy industry is experiencing an unprecedented boom, raising ethical concerns across borders. As more couples turn to surrogacy as a path to parenthood, this assisted reproductive technology has evolved into a multi-billion dollar market.

According to recent research, the global surrogacy industry is projected to grow from $21.85 billion in 2024, to $196 billion by 2034. This explosive growth is primarily concentrated in Europe and North America, where surrogacy is legal and regulated.

However, the legal landscape of surrogacy remains a complex patchwork across nations, with some countries embracing it while others maintain strict prohibitions. This inconsistency in regulations has created gray areas.

Scientific research highlights the possibility of abuse arising from gaps in legal frameworks and disputes, whether surrogacy is legal or not. It points to unethical practices such as trafficking of women, coercion of both surrogates and prospective parents by agencies, lack of respect for bodily autonomy or informed consent, ‘sham’ procedures and multiple embryo exchanges.

Cross-Border Exploitation: A Dark Web of Surrogacy

Surrogacy-related abuse often happens in a region formed by three countries: Turkey, Georgia and Northern Cyprus.

While surrogacy remains illegal in Turkey, it’s perfectly legal in its northeastern neighbor Georgia and southern neighbor Northern Cyprus, creating a dangerous legal vacuum that enables exploitation.

The Hope for the Future Association, based in Tbilisi, Georgia, is one of the organizations reporting cases of abuse and illegal surrogacy in the country.

“Our organization has evidence of both Georgian and Turkish citizens being used as surrogate mothers, along with cases of children being transported across borders with falsified documents,” said Tamar Khachapuridze, the association’s director. “We’ve reported these to the prosecutor’s office. Despite a decade-long investigation by Georgian prosecutors, these cases remain collecting dust. It appears someone is working to keep these dark dealings under wraps.”

Khachapuridze cited a particularly alarming case involving a Turkish surrogate mother. After undergoing embryo transfer in Georgia, she was reportedly transported to Thailand three months before giving birth, where she delivered a baby intended for a single Chinese man.

This case directly violates Georgian law, which explicitly prohibits embryo transfer or any surrogacy procedures for women from foreign countries.

When we obtained the case number from Khachapuridze’s files and approached the Georgian Prosecutor’s Office with written questions about the existence and content of the investigation, our written inquiries and follow-up calls went unanswered.

Rusudan Nanava, a Tbilisi-based lawyer handling surrogacy cases, explained the wall of silence: “I doubt you’ll get any information from the prosecutor’s office. Criminal cases, especially those involving surrogacy, are treated with the highest level of confidentiality.”

Georgia’s Legislative Tug of War: Balancing Ethics and Economics

In a significant policy shift, the Georgian government is grappling with proposed legislation that could fundamentally reshape the country’s surrogacy landscape. The move comes amid growing concerns over human trafficking and exploitation in the industry.

“We’re seeing cases of law abuse, including human trafficking,” said independent member of parliament  Tamar Kordzaia. “While the government pushes for change through surrogacy laws, I believe we could address these issues through other regulatory measures.”

The controversial bill, introduced in June 2023, would effectively end commercial surrogacy in Georgia, permitting only altruistic arrangements. This shift would bar foreign couples—who currently make up 95 percent of intended parents—from accessing Georgian surrogacy services, restricting the practice to Georgian citizens only.

However, Kordzaia remains skeptical about the bill’s future, which has yet to take effect.

“This is moving at a glacial pace, despite the government’s ability to fast-track legislation when it wants to,” she said. “The economic implications are severe—both for medical facilities and the women who rely on surrogacy income. I suspect the bill will ultimately be withdrawn.”

In a country where 11.5 percent of women aged 18-65 live below the absolute poverty line, surrogacy has become a lifeline for many Georgian women struggling to make ends meet. Their stories paint a stark picture of economic desperation intersecting with the global fertility market.

Take Teona, a 42-year-old teacher and domestic violence survivor, who turned to surrogacy twice a decade ago. “As a woman, I wanted to help another woman who couldn’t have children,” she said, her

voice tinged with both pride and pragmatism. “Of course, there was financial motivation. My main goal was to buy my own apartment, and I did it—for my child’s future.”

Dr. Keti Gotsiridze, director of the Reproductive Health Center of the Chachava clinic, one of Georgia’s well-established health institutions, said according to the data research of her clinic, surrogacy practice contributes $300 million a year to health tourism. Gotsiridze said 90 percent of their clients are foreigners. Surrogate mothers are paid 25-30 thousand Euros; Chachava works with an average of 300-400 surrogate mothers a year.

For the time being, it seems that the new legislation to change the practice of surrogacy in Georgia has been shelved due to economic concerns. However, the question of how to prevent human trafficking, which has also emerged with the abuse of the existing law, remains unanswered.

Cross-Border Surrogacy Investigation Closes With No Charges Filed

A prosecutorial investigation has revealed an alleged surrogacy trafficking network spanning Turkey, Georgia and Northern Cyprus, highlighting the devastating human cost of unregulated fertility treatments.

The case began on Sept. 3, 2021, when Turkey’s Health Ministry received an anonymous tip about “F. IVF (In Vitro Fertilization) Center,” a fertility clinic in Istanbul’s affluent Beşiktaş district. According to the whistleblower, the clinic was targeting vulnerable young women, including minors, from the working-class neighborhood of Ümraniye with promises of financial gain through surrogacy.

The scheme was elaborate: Women were provided with fertility drugs to use at home for durations  ranging from two to 12 days. They were then allegedly trafficked to Georgia and Northern Cyprus using forged documents, with all expenses covered by the network. The fertility medications were reportedly sourced from pharmaceutical warehouses and distributed through a café in Üsküdar, serving as a front for the operation.

Despite the gravity of these allegations, the investigation faced significant hurdles. After a year-long probe, authorities could only identify one suspect, known as A.A., who allegedly recruited the women. The café implicated in the scheme closed its doors just one month before police surveillance began.

When we reached out to M.K., the lawyer who owned the café, he confirmed his ownership but denied any knowledge of the fertility drug distribution, claiming he was also a victim in the scheme.

Another crucial lead emerged regarding Dr. S.T., who allegedly treated the women at “F. IVF (In Vitro Fertilization) Center” and later deleted their medical records. However, police terminated the investigation, citing lack of evidence and the doctor’s clean criminal record.

When reached for comment, Dr. S.T. denied all allegations, dismissing the claims made in the investigation as baseless.

The case took another turn when the Istanbul Public Prosecutor’s Office dismissed the case in January 2023. The Provincial Health Directorate appealed, arguing that “the investigation was inadequate” and “the material and moral elements of the crime have not been fully established.” Nevertheless, on May 31, 2023, the Istanbul 7th Criminal Court of Peace rejected the appeal without explanation.

The case remains closed, leaving crucial questions unanswered about the fate of these young Turkish women, the conditions they endured, and the clinics involved in Georgia and Northern Cyprus. The Ministry of Health has remained silent on queries about similar reported cases, raising concerns about the scale of this cross-border surrogacy trade.

A Cross-Border Underground Surrogacy Network

A police raid in Istanbul in 2019 exposed a sophisticated trafficking network spanning Turkey, Georgia and Northern Cyprus. The operation revealed a complex web involving a Northern Cypriot ringleader and two Moldovan accomplices who coordinated the trafficking of Turkish women for surrogacy purposes.

During the raid, police discovered large quantities of fertility drugs. According to detained suspects’ testimonies, these hormones were supplied by the Northern Cypriot kingpin and administered to potential surrogate mothers recruited from Turkey. The women were then trafficked to clinics in both Northern Cyprus and Georgia, with one prominent facility identified as “IVF Tours Georgia” in Tbilisi.

To verify whether this clinic continues to engage with Turkish women five years after the raid, we conducted an undercover investigation. Posing as potential surrogates from Turkey, we contacted “IVF Tours Georgia” via email. The response was swift and telling: Not only did they accept our inquiry, but they immediately began discussing financial arrangements and medical screenings. This exchange revealed a striking fact: Despite Georgian law restricting surrogacy to Georgian citizens, the clinic openly offered services to Turkish nationals, highlighting the persistent nature of this illegal cross-border trade.

Lack of Oversight Fuels Surrogacy Concerns in Northern Cyprus

In Northern Cyprus, a growing surrogacy industry operates within a complex web of legal ambiguity and insufficient oversight, despite having well-crafted regulations. Former health minister (2018-2019) and Republican Turkish Party MP Filiz Besim warns that human trafficking cases persist due to inadequate supervision.

“While we have meticulously drafted laws permitting surrogacy, the lack of oversight remains a critical issue,” Besim said. “Our unique position outside international law, due to our unrecognized status, has created vulnerabilities that are being extensively exploited. This has led to the emergence of illicit international networks involved in human, women, and child trafficking.”

Deputy Besim emphasizes that women—particularly from Caucasian countries—are being brought from abroad as surrogate mothers in violation of laws. He notes that due to insufficient oversight, questions remain about the agreements, facilitators, and conditions under which these women are transported.

Our anonymous field interviews and observations reveal serious concerns about surrogacy practices stemming from the country’s lack of oversight. A troubling gray area has emerged where low-income women face potential exploitation. Women may be pressured into surrogacy due to financial hardship, raising ethical concerns about the commodification of women’s bodies and children’s rights.

International organizations like U.N. Women have voiced similar concerns about surrogacy practices in regions like Northern Cyprus, citing these risks and inadequate oversight. They stress the importance of protecting surrogate mothers through proper safeguards: ensuring they are fully informed, free from coercion, and fairly compensated for the risks they undertake.

Surrogacy became legal in Northern Cyprus in August 2016 under the Law Regulating Human Cell, Tissue, and Organ Transplantation Rules. A new, more robust bill was drafted in April 2023, though Parliament has yet to convene to discuss these changes.

Northern Cyprus has emerged as Europe’s leading destination for reproductive treatments. The industry’s prominence is evident in everyday encounters in the capital, Lefkoşa, where stories of successful surrogacy arrangements—including a recent case involving a European couple—are commonplace.

While official statistics remain undisclosed, artificial intelligence analysis estimates approximately 500 surrogacy arrangements occur annually in Northern Cyprus. According to LaingBuisson, a London-based healthcare market research firm, the country handles about 11 percent of all egg donation treatments in Europe.

Social Media’s Underground Surrogacy Market

Despite legal bans and restrictions, a thriving underground surrogacy market in Turkey continues to operate in plain sight. There are numerous advertisements openly seeking surrogate mothers on social media platforms such as Instagram and Facebook.

In one of these advertisements, we wrote  to a woman who said  she could  be a surrogate mother, with a request to have a child. Ten years ago in Turkey, the woman said she had been a surrogate mother once and explained how the process would work and offered us two methods to help her conceive:

“The child could be from my egg and your husband’s sperm. Would you be okay with that after birth? We’d never need to know each other. We wouldn’t even need a transfer. We could handle it ourselves – inject your husband’s sperm directly into my uterus. Or, we could select healthy eggs and have your and your husband’s eggs transferred to me.”

Most alarmingly, she assured us that certain private clinics would perform these procedures clandestinely, promising there would be “no issues” with birth certificates—a clear indication of document fraud.

The desperation of infertile couples seeking parenthood through these illegal channels may be understandable, but the risks are severe. These back-alley procedures not only endanger the health of all parties involved but also expose them to serious legal consequences. The combination of medical risks and criminal liability creates a potential storm of challenges for vulnerable individuals.

The Delicate Balance: Finding a Legal Middle Ground

Is there a way to craft ideal legislation that prevents exploitation while acknowledging the deep human desire for parenthood? Attorney and professor Dr. Özlem Yenerer Çakmut believes the answer lies in nuanced regulation rather than absolute prohibition.

“We can’t simply ignore the profound yearning of those who dream of experiencing not just parenthood, but the entire journey—from pregnancy to birth,” Yenerer explained. “These are couples who want more than adoption; they want to be part of every moment, every milestone.”

“The challenge lies in striking a delicate balance between regulation and prohibition,” she continued. “A blanket ban isn’t the answer, especially in societies where having children carries immense social and cultural weight. While we can’t legitimize illegal practices, we can work toward meaningful legislation that protects all parties involved while acknowledging these deeply human desires.”

There is also a section of the world strongly opposed to surrogacy. At its forefront stands the Casablanca Declaration, a document signed by 100 experts from 75 countries in March 2023, calling for a universal ban on surrogacy practices.

Leading this charge is Olivia Maurel, herself born through surrogacy in 1991, who has emerged as one of the movement’s most compelling voices.

“Standing against surrogacy means advocating for its universal abolition,” Maurel declared with conviction born of personal experience. “This isn’t just about abstract principles—it’s about defending the fundamental rights of women and children, about protecting human dignity in its most basic form. Surrogacy, by its very nature, undermines these essential values.”

For some, surrogacy represents a last resort in their journey to parenthood. A 46-year-old woman living in Georgia, who chose to remain anonymous, shared the challenging aspects of this process. After having her uterus and ovaries removed due to health issues, she and her husband decided to pursue surrogacy six years ago.

The woman described maintaining close contact with the surrogate mother both before the transfer and throughout the pregnancy. “I monitored her doctor visits, tests and medications regularly. I ensured she maintained a healthy diet, and I was present during the birth. I was with my baby from the moment of delivery.”

Despite being a challenging and costly process, she pursued surrogacy to fulfill her dream of motherhood. “If surrogacy is the only path to becoming a mother, you must give it your all, learn to manage your emotions, and stay focused on your goal. The difficulties and pain are temporary; the love for a child is permanent,” she said.

E.U. Redefines Surrogacy Regulations

Recent legal scholarship challenges the traditional binary approach of outright bans versus complete legalization. Instead, experts advocate for a nuanced international framework that transcends cultural and moral absolutes while protecting fundamental human rights. This perspective emphasizes the critical need for comprehensive national legislation in countries where surrogacy exists, whether legal or not, to safeguard the rights of both women and children.

Amid this contentious landscape, the European Parliament Council took decisive action on Jan. 23, 2024, reaching a provisional agreement to classify exploitative surrogacy practices as human trafficking. The measure was formally adopted on May 27, 2024.

The new framework imposes strict penalties on those who exploit women through forced surrogacy or deceptive practices, while establishing comprehensive support systems for victims. E.U. member states must implement these protections into their national legislation within two years.

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The production of this investigation is supported by a grant from the IJ4EU fund. The International Press Institute (IPI), the European Journalism Centre (EJC) and any other partners in the lJ4EU fund are not responsible for the content published and any use made out of it.

This reporting was supported by the International Women’s Media Foundation’s Howard G. Buffett Fund for Women Journalists.

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