Written evidence submitted to the United Kingdom Parliament
by the International Coalition for the Abolition of Surrogate Motherhood [EDF0055]
Paris, 8 January 2026
On behalf of the International Coalition for the Abolition of the Commodification of Women’s Reproductive Capacities, uniting organisations across multiple countries and continents, we are writing to express our serious concern regarding the current regulatory approach to egg donation and egg freezing in the United Kingdom.
We submit that women do not currently undergo egg donation or egg freezing with genuinelysufficient, transparent, and non-misleading information, and that the existing regulatory framework fails to provide meaningful safeguards. Rather than offering protection, it facilitates and legitimises practices that expose women to significant medical, psychological, and social risks, while shifting responsibility and risk onto individual bodies.
Our responses to the questions are based in part on the work of Diane Tober, particularly her book Eggonomics: The Global Market in Human Eggs and the Donors Who Supply Them (2025), which documents how economic pressures and systemic inequalities shape women’s participation in the egg market.
1. What are the short and long-term health impacts of donating or freezing eggs and embryos and to what extent are they sufficiently researched and understood?
The immediate health risks associated with egg donation or freezing are relatively well documented but they are often downplayed in both clinical and commercial discourse. Shortterm effects are primarily linked to hormonal stimulation, ovarian hyperstimulation syndrome (OHSS), and the egg retrieval procedure itself. Donors undergo high doses of gonadotropins to induce hyperovulation, which commonly leads to severe abdominal pain, bloating, nausea, migraines, and mood disturbances such as anxiety, irritability, or depressive episodes. Clinics frequently present these effects as temporary or mild. OHSS can range from mild to severe and may include fluid accumulation, blood clots, kidney failure, and even hospitalization.
Moderate to severe cases are underreported, particularly among young, healthy donors considered “low risk.” The egg retrieval procedure, performed under anesthesia or sedation, carries further risks of infection, hemorrhage, and injury to nearby organs. Many donors report returning to work or studies the following day without proper medical follow-up.
Tober’s key point is that although these risks are scientifically recognized, their true frequency is difficult to determine because donors are rarely followed long-term and often exit the healthcare system after donation.
The long-term health impacts of egg donation, by contrast, are largely unknown and insufficiently researched. There is no comprehensive, longitudinal study on the enduring effects of egg donation. Major areas of uncertainty include hormone-dependent cancers, with hypotheses about ovarian, breast, or endometrial cancer, but studies remain contradictory, sample sizes are small, and follow-up periods are insufficient. This lack of data is often presented as a lack of risk, masking genuine uncertainty. Concerns about future fertility also persist; while clinics assert that donation does not deplete the ovarian reserve, some donors report prolonged irregular cycles or difficulties conceiving later in life. These experiencesremain anecdotal and are not systematically studied. Long-term psychological effects, such as regret, anxiety about genetically related children, or distress when donation is financially motivated, are similarly overlooked in clinical research because they fall outside the biomedical framework. The under-research of long-term impacts is not due to scientific impossibility but to structural disinterest: once the egg is retrieved, the donor disappears from the healthcare system. With regard to the children conceived through purchased eggs, there is emerging evidencesuggesting that they may be more likely to experience health problems, which further reinforces the need for independent, long-term research and the application of a precautionary principle in this field.
2. Whether the counselling provided ahead of egg donation is adequate to ensure informed consent, including of potential health impacts?
Counselling prior to egg donation or egg freezing cannot currently be considered sufficient to guarantee genuinely informed consent. While legal consent is formally obtained through the signing of consent forms, informed consent in a substantive sense requires a clear understanding of risks, alternatives, and scientific uncertainties. Under current practices, this standard is not met.
Pre-procedure counselling is frequently selective and biased. Medical risks are often described in vague terms such as “rare” or “minimal,” or compared to common medical procedures in ways that trivialise their seriousness. Long-term uncertainties, particularly concerning the cumulative effects of hormonal stimulation, repeated cycles, and potential impacts on future fertility, are rarely explained in detail. As a result, a majority of donors report inadequate information: in a study by Tober et al. (2020), 55.2% of participants did not feel well informed about potential long-term risks. In addition, 66.5% of respondents reported inconsistency between their egg donation experiences and expectations based upon what they had been told in the informed consent process. This suggests lack of uniformity of the informed consent process across clinics There is also a structural conflict of interest inherent in current counselling arrangements.
Counselling is commonly provided by clinic staff or intermediaries whose primary objective is donor recruitment and treatment provision, rather than independent protection of donors’ interests. Testimonies from donors indicate that some felt discouraged from asking too many questions or perceived hesitation as a lack of commitment, further undermining the voluntariness of consent.
Economic and social vulnerabilities further compromise genuine choice. Many egg donors and women who freeze their eggs are students, precarious workers, or migrants, for whom financial need and limited alternatives constrain the ability to refuse. In these circumstances, consent is shaped not by autonomous decision-making but by structural pressure. Donation and freezing are often presented as “opportunities” rather than as medical interventions carrying significant risk. Moreover, counselling rarely includes meaningful discussion of alternatives, such as choosing not to donate, delaying the decision, taking extended reflection periods, or accessing alternative forms of financial or social support. The absence of such information further narrows the scope of choice.
Under the UK regulatory framework, the Human Fertilisation and Embryology Authority (HFEA) requires licensed clinics to provide specific information to donors and to offer counselling prior to consent, in accordance with the Human Fertilisation and Embryology Act 2008. However, there is no legal requirement for egg donors or women freezing their eggs to take up counselling, and its content, duration, and independence are not standardised. While some clinics make counselling mandatory, this remains discretionary rather than enforceable.
Finally, we would like to remind you that the eggs sold may be reused for surrogacy purposes, a use over which donors have no control or decision-making power. This lack of control over the future of the oocytes reinforces the issues of consent, traceability and dignity for the women concerned. Taken together, current counselling practices do not ensure genuinely informed consent. They obscure scientific uncertainty, minimise risk, and operate within a commercial environment that prioritises recruitment and throughput. Without independent, mandatory, and non-directive counselling that explicitly addresses structural pressures and alternatives, informed consent remains largely procedural rather than substantive.
3. What level of compensation / payment should be provided to egg donors, if any?
The framing of financial compensation for egg donation as a neutral reimbursement for time and inconvenience is misleading. In practice, compensation functions as a powerful economic incentive within a reproductive market shaped by gendered and socio-economic inequality. It cannot be assessed independently of the structural conditions under which egg donation takes place.
Under the current framework, there is no ethically defensible level of payment. Low or capped compensation risks normalising exploitation under the rhetoric of altruism, while obscuring the invasive nature of the procedure, the medical risks involved, and the long-term uncertainty borne exclusively by women. Conversely, higher compensation increases the likelihood of economic coercion, particularly for women facing financial insecurity, thereby undermining the voluntariness of consent.
As long as egg donation operates within a profit-driven fertility industry, where clinics and intermediaries derive financial benefit while health risks are externalised onto donors, compensation cannot be disentangled from coercion. The system relies disproportionately on women in precarious socio-economic situations, transferring medical, emotional, and relational costs onto individuals while institutional actors remain insulated from long-term responsibility.
This dynamic raises serious concerns under international human rights law. The Convention on the Elimination of All Forms of Discrimination against Women (CEDAW) obliges states to protect women from practices that exploit their reproductive capacities or reinforce structural inequality. When financial need becomes a determining factor in reproductive decision-making, consent cannot be considered free in any meaningful sense, calling into question compliance with obligations relating to bodily integrity and non-discrimination.
Egg donation should therefore be recognised as a form of reproductive exploitation, given its time-consuming, invasive, and physically and emotionally costly nature. Empirical examples include women undergoing repeated donation cycles to finance their studies, managing medical complications without adequate follow-up, and receiving no post-donation healthcare coverage. These realities contradict the notion that compensation merely offsets inconvenience and instead point to a structural failure of protection. In light of these considerations, the appropriate regulatory response is not to recalibrate compensation levels, but to reassess the legitimacy of egg donation under current conditions. Without addressing the underlying inequalities that shape consent, any payment regime risks perpetuating exploitation rather than safeguarding women’s rights.
4. What evidence is there, if any, of vulnerable women being encouraged into egg donation or egg freezing?
Vulnerable women are not only present in large numbers within this market but are actively and systematically encouraged to participate in it. According to Tober (2025), the typical profile of egg donors consists predominantly of young women aged 18 to 30, often university students, women with low or unstable incomes, migrants, or women with limited social protection and no access to comprehensive health insurance. Among the 898 compensated donors studied, the primary motivation for donating eggs was financial debt, and the compensation they received was mainly used to pay bills and reduce that debt.
Compensation for egg donation can therefore constitute a significant financial incentive. Even in the UK, where compensation is intended to be “ethical” and limited, economic coercion remains a concern. For women facing financial hardship, £985 per donation cycle can represent a substantial sum, especially since most donors undergo more than one cycle. Among 717 donor responses, 56 (8%) reported having completed more than the ASRM-recommended six-cycle limit. Of these, 26 donors completed between 10 and 19 donations. The fact that women go far beyond the recommended donation limit, even when fully aware of the medical risks, shows that they do so primarily for financial reasons.
The presence of payment alone is not the central ethical issue; rather, it is the way payment operates within constrained choices. Many donors explicitly state that they would not have undergone the medical risks of egg retrieval if they had access to other forms of Financial support. This suggests that consent is shaped by necessity rather than free preference. Under Article 3 of the Palermo Protocol, such conditions constitute exploitation, since economic vulnerability is explicitly recognized as one of its defining factors. In this framework, consent functions as a legal mechanism that sanitizes exploitation, as one cannot meaningfully consent to one’s own commodification.
From a feminist and socialist perspective, this raises profound concerns about exploitation, insofar as women’s reproductive capacities are transformed into means of survival within structurally unequal economic systems. However this vulnerability is instrumentalised, because there is a true process of recruitment through marketing and advertising. Egg donation agencies and fertility clinics target spaces associated with young and financially insecure women, such as university campuses, online student forums, and social media platforms. Advertisements frequently combine emotional appeals to altruism (“help a family have a baby”) with empowerment-oriented language (“take control of your body,” “make a meaningful choice”) and explicit financial incentives (“pay your tuition,” “earn fast money”) (Tober, 2025). Egg freezing, although often framed as a choice of affluent, career-oriented women, is also a practice shaped by vulnerability. Women are encouraged to freeze their eggs not because of present infertility but because they are warned of inevitable future regret. This rhetoric is particularly evident in corporate-sponsored egg freezing programs, especially in sectors such as technology and finance. While presented as empowering benefits, these programs subtly pressure women to delay motherhood in order to conform to workplace norms that remain hostile to pregnancy and caregiving. Rather than addressing structural inequalities in employment, egg freezing shifts the burden of reproductive risk onto individual women, encouraging them to undergo invasive and costly procedures to adapt to unjust conditions.On a global scale, evidence also points to the recruitment of women from economically disadvantaged regions into transnational egg donation markets. These women often receive lower compensation, face weaker regulatory protections, and lack access to long-term medical care. In such cases, vulnerability is intensified by global economic inequality, turning reproductive labor into a form of extractive practice that mirrors other exploitative global markets. Taken together, these patterns demonstrate that vulnerable women are not incidentally involved in egg donation and egg freezing markets but are central to their functioning.
Economic precarity, gendered expectations, and unequal access to resources create conditions in which women are encouraged—often subtly, sometimes overtly—to put their bodies at risk in order to secure financial stability or future reproductive possibilities. The fertility industry is creating two reproductive social classes: the buyer class and the supplier class. The supplier class is made up of women who put their eggs and wombs up for contract. Furthermore, compensation levels vary sharply along racialized lines. Donors meeting highly valued criteria—such as elite education, specific racial or ethnic profiles, or particular physical traits—can receive dramatically higher payments. Tober’s studies show that White and Asian donors are paid the most, between $75,000 and $100,000, while Black, Hispanic, and other donors receive much less, with the highest reported compensation around $21,000.
Black donors report the lowest payments overall, at a maximum of $12,000. These disparities demonstrate that egg donation selection processes, which favor women based on racial, health-related, or social characteristics, are not neutral but reflect deeply embedded eugenic logics. As scholars note, the U.S. human egg market exposes class, social, and racial inequities unlike any other commodified organ or tissue, illustrating how capitalism operates through women’s differently positioned bodies, resembling what Dorothy Roberts calls a “racialized caste system” underlying reproductive stratification.
5. Is the regulatory regime on advertising as it applies to egg donation and people wishing to freeze their eggs or embryos sufficient?
The current regulatory regime governing advertising is inadequate. Promotional materials frequently sanitise or omit medical risks and uncertainty, while emphasising emotional fulfilment and empowerment. Egg donation and egg freezing are marketed as lifestyle or consumer services rather than invasive medical procedures with potentially lifelong consequences.
An illustrative example of the ethical shortcomings of the current regulatory regime can be found in the site EggDonorUk that opens with the slogan: “Make dreams come true with egg donation.” This framing immediately positions egg donation as a moral act oriented toward fulfilling the desires of others, while rendering invisible the medical, physical, and psychological risks borne exclusively by women who undergo the procedure. In the section entitled “Why donate?”, the first two justifications presented are “altruism” and “Financial compensation.”
First, describing as altruistic a practice that exposes women to significant medical risks in order to fulfil the reproductive aspirations of others reproduces a longstanding patriarchal narrative. Appeals to altruism have historically been used to normalise women’s bodily sacrifice and to obscure relations of power and extraction. As a feminist organisation, we consider it outrageous and deeply outdated that such rhetoric remains legally permissible in fertility advertising.
Second, the prominence of “financial compensation” as a motivating factor further reveals the structural logic of the egg market. While UK law formally caps compensation, presenting payment as a persuasive argument demonstrates that the system relies on women’s economic vulnerability to secure egg supply. This is particularly concerning given that egg donation advertising disproportionately targets younger women and students—groups more likely to experience financial precarity.
Together, the juxtaposition of altruism and financial compensation exposes a regulatory contradiction: egg donation is publicly framed as a moral gift, while privately sustained through economic incentive. As Tober shows, this dual discourse is characteristic of reproductive markets that seek to mask exploitation through ethical language. The system therefore remains fundamentally dependent on women’s vulnerability—both moral and economic—while regulatory bodies continue to treat such advertising as acceptable. This raises serious doubts about whether informed consent can genuinely exist within a framework that simultaneously moralises sacrifice and monetises reproductive labour. Stronger regulation is urgently needed to prevent misleading advertising and to ensure that women are not drawn into these practices through partial or idealised representations.
CLOSING REMARKS
Despite the UK’s reputation for ethical regulation, current oversight largely treats egg donation and egg freezing as practices to be managed and optimised rather than critically assessed. Advertising remains legal and persuasive, medical risks are routinely minimised, success rates are poorly contextualised, and the long-term impacts on donors and on women who freeze their eggs remain under-researched and inadequately monitored. As a result, consent is framed as an individual choice, while the broader conditions shaping that choice—including gender inequality, economic precarity, and cultural expectations of female sacrifice—are left unexamined. This raises serious doubts as to whether informed consent, in any robust sense, can exist within the current framework.
This submission therefore argues that:
● women are systematically under-informed about risks, failure rates, and long-term consequences;
● current safeguards are procedural rather than substantive; and
● regulatory reform must move beyond improved disclosure to questioning the legitimacy and continued expansion of these practices themselves.
Accordingly, we recommend eliminating financial compensation and suspending these activities until the health consequences for women and for children born through these techniques have been thoroughly, independently, and longitudinally studied.
We thank you for your attention to these matters and for considering this submission.
Yours sincerely,
Marie Josèphe Devillers – Ana-Luana Stoicea-Deram – Berta O. García
Co-Presidents of the International Coalition for the Abolition of Surrogacy