Surrogacy is not a commodity: real failure cases of underground surrogacy in the United States, Southeast Asia and China

📅 April 12, 2026  |  ⏱ Reading time is about 14 minutes  |  📁 Laws and regulations · Risk warning

When many prospective parents decide to take the surrogacy route, they silently make a calculation in their hearts:As long as you spend enough money, choose a legal country, and sign a formal contract, you will definitely be able to have a baby.

This logic holds true when purchasing goods. In the matter of surrogacy, there is a fundamental misjudgment.

At its core, surrogacy is a life process, not a transaction. The survival of the embryo, the response of the uterus, accidents during pregnancy, changes in laws, and the integrity of the institution—any link that is out of control may wipe out years of expectations and hundreds of thousands of investments. The deeper risk is that some choices not only cost you money, but also your personal freedom, and even permanently lose the opportunity for recovery.

This article combs through three types of real cases in the United States, Southeast Asia, and China. The purpose is not to persuade families to quit, but to help willing families establish a true perception of risks.

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United States·Legal surrogacy
Although the law is perfect, there are still institutions that close down
Cases of medical failure and out-of-control costs
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Southeast Asia·Grey/Illegal
Sudden policy changes, personal arrests
Loss is not just money
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Domestic and underground surrogacy
No contract protection, children have no identity
The client is exposed to criminal risks at any time

1. The United States: The surrogacy market with the most complete laws in the world still loses money and worries

The United States is one of the countries with the most mature surrogacy legal system in the world. The surrogacy laws in California, Nevada, Washington and other states are quite complete. The validity of the contract is protected by the court, and the parental rights can be established before birth. However, these systems guaranteeCompliance with legal procedures, rather than the controllability of life processes.

Case 1: The surrogacy agency collapsed after collecting money - SurroGenesis incident (2009, California)

United States · Institutional Bankruptcy · Real Events
Millions of dollars in escrow money wasted

In 2009, SurroGenesis, a surrogacy agency based in Visalia, California, declared bankruptcy. During the operation of the institution, the large amount of custody funds paid by the entrusting families were diverted to maintain daily operations, instead of being separately deposited in a third-party trust account as agreed.

More than 100 commissioned couples were affected by the bankruptcy, and some families suffered losses exceeding $100,000. Some of these couples are in the midst of the surrogacy process—the surrogate mother is pregnant but cannot pay the medical expenses; others have lost all of their upfront costs and the process has been terminated.

This incident prompted California to introduce stricter regulatory requirements for escrow accounts. However, for the victims at the time, the road to recovery was extremely long, and most people could only partially recover their funds.

Nature of risk:Surrogacy fees are usually paid in a centralized manner and the amount is huge. If the custody account lacks independent supervision, the client will have almost no means of self-insurance if the agency fails to operate well. Even in the most regulated surrogacy states in the United States, the financial soundness of the agency is still the primary evaluation factor.

Case 2: Surrogate mother refused to hand over the child - "Baby M" case (1988, New Jersey)

United States · Custody disputes · Groundbreaking jurisprudence
After the child was born, the surrogate mother regretted it

This is the most far-reaching case in the history of American surrogacy. In 1986, Mary Beth Whitehead of New Jersey signed a traditional surrogacy agreement with the Sterns, using her own eggs as a surrogate for conception. The agreement stipulated that the child would be handed over to the Sterns after birth.

After his daughter was born, Whitehead refused to fulfill the contract and fled to Florida with the child. The Sterns sued and endured a lengthy trial that received widespread national attention.

The New Jersey Supreme Court ultimately ruled that the surrogacy contract was invalid (violated public policy), but based on the best interests of the children, custody was awarded to the Sterns and Whitehead was granted visitation rights. The lawsuit lasted for two years, and both parties suffered huge psychological trauma and legal expenses.

Nature of risk:The Baby M case occurred in a traditional surrogacy scenario (the surrogate mother and the child are genetically related), which is also an important reason why modern surrogacy agencies generally turn to "gestational surrogacy" (using the client's embryos). Even so, emotional entanglements and temporary regrets can occur in any country and any type of surrogacy.

Case 3: Sudden changes in the legal environment—the impact of U.S. state policies on the validity of surrogacy contracts

United States · Legal changes · Ongoing risks
Same country, different states, completely different

The legality of surrogacy in the United States is highly dependent on state legislation, and varies greatly from state to state. Michigan will not complete the revision of surrogacy laws until 2024. Previously, surrogacy contracts were invalid in the state and may face criminal penalties; Louisiana maintains a strict restrictive stance on surrogacy.

In 2022, the U.S. Supreme Court overturned Roe v. Wade, and many states immediately introduced strict abortion bans, affecting the "right to choose in case of fetal abnormality" clause in surrogacy contracts. Due to legal restrictions in the state where the surrogate mother is located, some commissioning families are unable to exercise their contractual rights when the fetus is detected with severe chromosomal abnormalities, and are forced into unsolvable ethical and legal dilemmas.

Some clients who signed contracts in non-friendly states have spent tens of thousands of dollars in additional legal fees on the paternity determination process because their contracts cannot be protected by local courts, and the results are still uncertain.

Core understanding of surrogacy in the United States:The legal protection in the United States is real, but it guarantees "procedural compliance" rather than "certainly being able to hold the child." Institutional bankruptcies, medical failure (repeated unsuccessful transplants), complications during the surrogate mother's pregnancy, and legal changes, each can result in substantial losses that are often non-refundable. The total cost of surrogacy in the United States is generally between US$150,000 and US$250,000. Any failure will result in a real loss of millions of RMB.

2. Southeast Asia: gray and illegal zone, where you lose more than just money

In the early 2010s, a large number of commercial surrogacy agencies for foreigners appeared in Thailand, Cambodia, Laos, Vietnam, Nepal and other places. Low fees (usually 1/5 to 1/10 of those in the United States) and looser legal controls have attracted a large number of client families from Australia, Israel, Europe and China. However, in the following years, these countries successively introduced bans, and the surrogacy market in the entire region was close to collapse in a short period of time. The cost of this collapse is shared by the client, the surrogate mother and the child.

Case 1: "Baby Gammy" - Australian couple abandoned baby with Down syndrome (Thailand, 2014)

Thailand · Events of International Concern · 2014
The child was left behind because he was not wanted.

In 2014, Australian couple David and Wendy Farnell commissioned Thai surrogate mother Pattaramon Chanbua to conceive twins. After the children were born, one of the baby girls was healthy, while the other baby boy, "Gammy", was diagnosed with Down syndrome and congenital heart disease.

The Australian couple took their healthy baby girl and left Gammy in Thailand. Unable to pay for medical expenses, Pataramon raised more than AU$260,000 through online crowdfunding to raise Gammy on his own.

After the incident was exposed, it attracted global media attention. Subsequent investigations found that Gammy's commissioned father, David Fanell, had a record of child sexual assault, and that the Thai surrogacy agency had serious loopholes in the background check.

This incident directly prompted the Thai government to issue a ban in 2015, completely prohibiting the provision of commercial surrogacy services to foreigners.

Case 2: "Baby Factory" - The son of a wealthy Japanese businessman hired 16 surrogate mothers in Thailand (2014)

Thailand · Regulatory loopholes · 2014
Surrogacy is used as a mass copying tool

In August 2014, Thai police discovered 13 babies in an apartment in Bangkok, all of whom were born to Japanese male Mitsutoki Shigeta (grandson of the founder of Japan’s SoftBank) through different Thai surrogate mothers. After the investigation was expanded, it was confirmed that it had employed at least 16 surrogate mothers and had given birth to more than 13 babies. Shige himself claimed that he hoped to "give birth to hundreds of offspring."

After the case was exposed, the Thai police classified it as "illegal use of commercial surrogacy" and launched an investigation. However, because Thailand did not have a clear law prohibiting commercial surrogacy at the time, the relevant handling fell into a legal vacuum. This incident became one of the triggers for Thailand’s final legislation banning commercial surrogacy by foreigners.

Case 3: Large-scale arrests in Cambodia—the client, agency, and surrogate mother were all criminalized (2018)

Cambodia · Criminal Risk · 2018
Go in as a client, come out as a defendant

In 2016, the Cambodian Ministry of Health issued a letter warning that surrogacy "violates human dignity" and announced that relevant personnel would be held criminally responsible. From 2017 to 2018, many Chinese and Australian surrogacy agencies were arrested by the police in Cambodia, including a large-scale raid on the "surrogacy network" in Phnom Penh in 2018, in which 33 pregnant women were detained.

Some pregnant women were detained during pregnancy and were unable to receive normal prenatal check-ups and medical care. After the birth of their children, they faced difficulties in identifying their identities, and some babies were unable to leave the country for a time.

In these cases, all the fees paid to the intermediary (usually between RMB 300,000 and RMB 600,000) were wasted; more seriously, the client who had entered Cambodia to cooperate with the process was listed as an informed participant by the authorities in some cases and faced the risk of being detained.

Case 4: Sudden policy changes in India and Nepal - children trapped in foreign countries (2015)

India/Nepal · Sudden Policy Change · 2015
The child is born, but cannot return home

In 2015, India announced a ban on providing surrogacy services to foreign singles and same-sex couples (it will be further expanded to a complete ban on commercial surrogacy in 2022). In the same year, Nepal announced a total ban on foreign surrogacy following the earthquake.

When the ban came into effect, a large number of clients were pregnant or had just given birth. The Israeli government chartered a special flight to urgently pick up 26 Israeli surrogate babies stranded in Nepal. Clients of other nationalities are trapped in the triple dilemma of "the child cannot go through exit procedures, the surrogacy contract cannot be performed, and the fees paid cannot be recovered."

Some families stay in Nepal and India for several months, incurring additional accommodation, legal and visa fees. Whether they can successfully bring their children back home still depends on the outcome of individual case negotiations.

Core understanding of surrogacy in Southeast Asia:When choosing surrogacy in countries where the law is unclear or expressly prohibited, the risk faced by the client is no longer a question of "whether to lose money or not", butPersonal freedom, criminal prosecution, stateless status of childrenWait for more serious consequences. Policies can change overnight, but pregnancy cannot be put on hold. What’s behind the low price is not the price/performance ratio, but the risk being transferred.

3. Underground surrogacy in China: It is expressly prohibited by law. Once something goes wrong, there is no guarantee.

China's current laws clearly prohibit surrogacy. The "Measures for the Administration of Human Assisted Reproductive Technology" stipulates that medical institutions are not allowed to implement surrogacy, and violators will have their licenses revoked; those who engage in surrogacy agencies may face administrative penalties or even criminal prosecution. However, the domestic underground surrogacy industry chain has never disappeared—it has simply gone underground, growing in a soil with no legal protection at all and pushing all risks to the commissioning families.

Case 1: A surrogate mother was extorted during pregnancy and had to pay more to give birth (comprehensive media reports from many places)

Domestic China · Contract cannot be enforced · Comprehensive reports
It’s useless even if you sign a contract, underground agreements are not protected by law

The "contract" of domestic underground surrogacy does not have any legal effect, which means that the agreement between the two parties cannot be enforced through judicial channels. This feature is systematically exploited by some surrogacy agencies and surrogate mothers.

According to investigative reports by the Southern Metropolis Daily, Beijing News and other media over the years, one type of situation that occurs more frequently in domestic underground surrogacy is: the surrogate mother in the middle and late stages of pregnancy requires the client to pay additional fees, ranging from tens of thousands to more than 100,000, for reasons such as "insufficient living expenses" and "compensation for physical discomfort". However, the client often has no choice but to submit because the contract is invalid and cannot go to court.

In more extreme cases, when the surrogate mother is about to give birth, she threatens to "don't go to the hospital if she doesn't pay", forcing the client into a desperate situation. Once the client refuses to pay, the fierce conflict between the two parties may evolve into a criminal incident at any time, and the client, as the client of "illegal surrogacy", is already in an illegal state.

Case 2: The intermediary took away the money and ran away, leaving both children and money behind.

Domestic China·Intermediary Fraud·Many Cases
The agency lost contact after payment, and pursuing a lawsuit is a luxury.

In 2023, police in Guangdong, Zhejiang and other places uncovered many cases of fraud in the name of "surrogacy services". The institutions involved generally adopt the following model: publish "successful cases", "real pregnant mothers" and other content on platforms such as WeChat and Xiaohongshu to attract customers, collect "upfront medical fees", "matching fees" or "deposits" ranging from tens to hundreds of thousands of yuan and then lose contact.

Since the entrusting party itself is in an illegal entrustment position, reporting to the police faces the worry of self-evident illegality; even if a crime is reported, it is often difficult to recover the full amount of the money paid. Some victims were even administratively punished for "participating in surrogacy activities" after calling the police.

According to incomplete statistics, among the underground surrogacy fraud cases publicly reported by domestic media from 2022 to 2024 alone, the victim's loss in a single case ranged from 100,000 yuan to 2 million yuan.

Case 3: There was no household registration after the child was born, and the client was in long-term difficulties.

Domestic China·Identity Dilemma·Continuing Impact
The child is born, but legally "does not exist"

Children born through underground surrogacy face severe obstacles to household registration recognition under China’s current system. Surrogate mothers usually do not want to leave their names on the birth certificate. The genetic relationship of the commissioned father requires DNA testing to prove, and it is more difficult for the commissioned mother (non-gestational carrier) to be legally recognized as the legal mother.

According to the case records of legal aid agencies, many children born through underground surrogacy were unable to complete household registration and were unable to enter school, seek medical treatment (enjoy medical insurance), or apply for any documents within several years, forming de facto "black children."

In order to solve the household registration problem, the entrusting family often needs to pay extra legal fees far beyond expectations, and the success rate is extremely unstable. The results vary depending on the region and the case, and are unpredictable. Throughout the entire process, the client is always exposed and may be held accountable by the administration.

Core understanding of underground surrogacy in China:The risk of underground surrogacy in China is not fundamentally a commercial risk;legal risks. The client's own illegal status means that they cannot seek full legal protection as a victim in any dispute. If something goes wrong, at least there will be no way to recover property losses, and at worst, you will face administrative penalties; and the identity of the child may remain with him throughout his life.

Written at the end: Surrogacy is not a transaction that can be "insuranced"

Back to the original question: As long as I spend money, choose a legal country, and sign a formal contract, will I be able to have a baby?

The answer to the above case is clear:uncertain.

In the United States, you face the financial risks of institutions, the real probability of medical failure, and the uncertainty caused by differences in laws among states; in the gray zone of Southeast Asia, you face policies that may change at any time, threats to personal safety, and the dilemma of children unable to return home; in domestic underground channels, you face a completely unprotected legal vacuum and potential criminal risks.

What can really reduce risk is not "choose the cheapest" or "choose the most expensive", but:

Risks cannot be eliminated, they can only be understood, managed, and fully informed. A good surrogacy agency will not tell you "guaranteed success", but will tell you "what will we do if it fails".

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