Country guide · Intended parents

Which surrogacy country fits your passport? Ukraine, Georgia and Armenia for UK, Irish, Australian, US and Canadian couples

For most couples, the passport matters more than the program country. Ukraine, Georgia and Armenia all put both intended parents on the local birth certificate, and with Novaparent the price is the same in all three. What changes is the step you take at home: a parental order in the UK, a citizenship application in Australia, a CRBA in the US, proof of citizenship in Canada, and a law that is enacted but not yet in force in Ireland.

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Andrew KhodonovychFounder of Novaparent · 26 October 2026 · 8 min read

Couples usually start by asking which country is best. Our answer is that it depends on your passport, because the same Ukrainian, Georgian or Armenian birth certificate leads to five different procedures at home. This guide puts both halves side by side: what your home country requires, and what each program country gives you.

Check these two situations first

  • Residents of New South Wales, Queensland or the ACT: your state makes a commercial surrogacy arrangement an offence even when it is entered overseas. Speak to an Australian surrogacy lawyer before anything else. We do not enrol couples while that exposure exists.
  • Irish couples: the Health (Assisted Human Reproduction) Act 2024 has been enacted but its international rules are not yet in force. Once commenced, it treats compensated programs abroad very differently. See an Irish solicitor before any embryo transfer.

1Your passport at a glance

For UK, US, Canadian and most Australian couples, joining a lawful compensated program abroad is not an offence. The legal work happens when you bring your child home, and it is different for each passport.

PassportIs a program abroad lawful for you?How your child becomes a citizenThe step at homeWatch out for
United KingdomYes. UK offences target commercial brokering by third parties, not intended parents abroadBritish by descent through the genetic British father when the surrogate is unmarried; otherwise registration as a British citizenParental order under section 54 of the HFEA 2008Surrogate's consent is valid only after 6 weeks; apply within 6 months of the birth
IrelandYes, while the 2024 Act's international rules are not in forceThrough the genetic father after a court declaration of parentage; the passport followsDeclaration of parentage for the father; guardianship for the motherCommencement of the 2024 Act could change the rules for new arrangements
AustraliaDepends on your state: an offence for NSW, Queensland and ACT residentsCitizenship by descent, by application to Home AffairsCitizenship registration, then the first passportConfirm your state's position with a lawyer before the transfer
United StatesYesConsular Report of Birth Abroad (CRBA) and passport at the US EmbassyUsually none; some attorneys advise a confirmatory parentage judgmentPhysical presence: 5 years (2 after age 14) if one spouse is not a citizen
CanadaYes. The AHRA payment ban governs conduct in CanadaProof of Canadian citizenship from IRCCProvincial declaration of parentageA parent born abroad needs 1,095 days in Canada before the birth (Bill C-3, in force since 15 December 2025)

Summary of our country guides, reviewed June 2026. Not legal advice; rules change, and your own facts matter.

2What each program country gives you

All three countries make the intended parents the legal parents at birth, and the surrogate has no parental claim. The differences are how fast the birth certificate is issued, where surrogates come from, and the security context.

Program countryLegal basisBirth certificateSurrogatesContext
UkraineFamily Code, Article 123 (since 2002)Both parents, immediately after the birthFrom western and central Ukraine onlyOngoing war; births in Kyiv or Lviv with a contingency plan for every program
GeorgiaStatutory since 1997Through the civil registry, usually within 1–2 weeksGeorgian or from neighbouring countries, matched by our partner agency in TbilisiNo conflict
ArmeniaFamily Code and the law on reproductive health; no court stepBoth parents from birthSince July 2024, from outside Armenia (for example Georgia or Kazakhstan)No conflict

The price does not change with the country: Standard from $47,000 (your own embryos, one transfer), Comfort from $60,000 (one IVF cycle, up to three transfers) and Prestige from $75,000 (up to three IVF cycles, unlimited transfers). Plan on two to four weeks in the program country after the birth for documents and the passport. The full breakdown is on our cost page.

3Matching your passport to a country

UK couples can use any of the three; the parental order process at home is the same. The detail that matters most is the surrogate's marital status. If she is married, her husband is treated as the legal father under UK law, so the child is not automatically British and needs registration first. We plan this before the transfer. Couples who want the registry done on day one tend to choose Ukraine; couples who want the war question off the table choose Tbilisi or Yerevan. Full detail: surrogacy for UK couples.

Irish couples should time the decision with a solicitor, because the 2024 Act distinguishes arrangements made before and after commencement. Today the father establishes parentage in court and the mother relies on guardianship. Full detail: surrogacy for Irish couples.

Australian couples outside NSW, Queensland and the ACT join programs lawfully and apply for citizenship by descent; the genetic link is the evidence Home Affairs relies on. Either Georgia or Ukraine works well, and the price is identical. Full detail: surrogacy for Australian couples.

US couples go through the same CRBA appointment whichever country they choose. Under the State Department's 2021 policy, a married couple's child qualifies when either spouse has a genetic or gestational link and the transmission rules are met. Embryos already stored in the US can be shipped by a partner courier for about $3,000–$4,000. Full detail: surrogacy for US couples.

Canadian couples should check their citizenship track first. Parents born or naturalised in Canada pass on citizenship as before; a parent born abroad must show 1,095 days of physical presence before the birth. Full detail: surrogacy for Canadian couples.

Settle these before the embryo transfer

  • Which of you will be the genetic parent, and does that parent meet your country's citizenship rules?
  • For US and Canadian parents: your physical-presence history in the US or Canada.
  • For UK couples: whether the surrogate is married, and what that means for the first passport.
  • For Australian and Irish couples: written advice from a lawyer in your state or in Ireland.
  • The document set for home: birth certificate with apostille, certified translations, the surrogacy agreement and DNA evidence.

4Frequently asked questions

Is surrogacy abroad legal for couples from the UK, Ireland, Australia, the US and Canada?
For UK, US and Canadian couples, joining a lawful compensated program abroad is not an offence. In Australia it depends on the state: residents of New South Wales, Queensland and the ACT commit an offence even overseas. Irish couples can join programs while the international rules of the 2024 Act are not in force, but should take legal advice on timing.
Which program country is fastest for the birth certificate?
Ukraine and Armenia register both intended parents on the birth certificate from birth. In Georgia the certificate is issued through the civil registry, usually within one to two weeks. Overall, couples spend about two to four weeks in the program country after the birth for documents and the passport.
Does the program country change what we must do at home?
Not much. The step at home is set by your passport: a parental order in the UK, a CRBA in the US, proof of citizenship in Canada, citizenship by descent in Australia and a declaration of parentage in Ireland. The program country mainly changes the timing of the local birth certificate and the security context.
Why does the surrogate's marital status matter for UK couples?
Under UK law a married surrogate's husband is treated as the legal father at birth. The child is then not automatically British and needs registration as a British citizen before the first passport. With an unmarried surrogate, the genetic British father is the legal father and the child is usually British by descent.
Do we need a lawyer in our home country?
For UK, Irish and Australian couples, yes: a specialist solicitor or lawyer handles the parental order, the Irish declaration or the state-law check. US and Canadian couples often need no court step, but a short consultation with a family lawyer before the transfer is inexpensive insurance. Novaparent prepares the full document file for them.

Not sure which country fits your passport?

Book a free call with Andrew. We will check your citizenship route first, then the medical picture, then the country — and send you a written summary to take to your lawyer.

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Note: This article is general information, not legal advice. It summarises our country guides as reviewed in June 2026. Citizenship and parentage rules change and depend on your own facts — confirm your situation with a qualified lawyer in your home country before starting a program.

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