The International Coalition Against Surrogate Motherhood (ICASM) and CSO Democracy Development Center write in urgent concern to Minister for Foreign Affairs of Ukraine regarding the Articles of Ukraine’s draft Civil Code that support surrogacy. українською
Letter text is:
Dear Minister Sybiha,
The International Coalition Against Surrogate Motherhood (ICASM), a coalition of 60 organizations across 20 countries on four continents, writes in urgent concern regarding Articles 1524 and 1527 of Ukraine’s draft Civil Code (Bill No. 69927, Verkhovna Rada).
These provisions establish a legal framework for the transfer of gestational parenthood to commissioning parties in cases of embryo transfer into the body of another woman, without once using the word surrogacy. Article 1524(2) assigns parental status to the commissioning spouses. Article 1527(2) extends this logic to single men, granting fatherhood through transfer of an embryo into the body of another woman – a woman who is not named, recognized, or legally protected anywhere in the text. The pregnant woman is erased from legal existence at the moment of birth. This is not an absence of regulation: it is institutionalization by deliberate omission.
This legislative architecture is directly incompatible with EU Directive 2024/1712, which explicitly classifies the exploitation of surrogacy arrangements as a form of human trafficking and requires Member States – and candidate countries committed to EU accession – to treat it as such. It is equally incompatible with Report A/80/158 submitted to the UN General Assembly in October 2025 by UN Special Rapporteur on violence against women and girls Reem Alsalem, which documents surrogacy as a systemic form of violence against women and calls on all states to move toward prohibition.
Ukraine controlled more than a quarter of the global surrogacy market before 2022. Since the full-scale invasion, displacement has created conditions of acute vulnerability for millions of women, documented by ICASM member and partner organizations including Democracy Development Center. Codifying surrogacy through civil law at this moment would entrench exploitation precisely when Ukrainian women are most exposed to it.
ICASM and Democracy Development Center call on the Ministry of Foreign Affairs to use its institutional weight in Ukraine’s EU accession process to advocate within government for the removal of Articles 1524(2) and 1527(2) from the draft Civil Code, and for their replacement with provisions explicitly prohibiting the use of another woman’s body for gestation on behalf of third parties in all forms.
Yours sincerely,
Marie-Josèphe Devillers, Ana-Luana Stoicea-Deram, Berta O. Garcìa Co-Presidents, ICASM – International Coalition Against Surrogate Motherhood, Maria Dmytrieva, Democracy Development Center (Kyiv)