The UK Parliament recently opened an inquiry into egg donation and egg freezing. Their inquiry examines whether women donating and freezing their eggs do so with sufficient information about the process, health impacts and consequences and whether the current regulatory framework provides sufficient safeguards to people who go through these procedures. Below is our submission as it also appears here and the full publication here.

From: Center for Bioethics and Culture (CBC)
Website: cbc-network.org
Date: 11/18/2025

Executive Summary

The Center for Bioethics and Culture (CBC) welcomes the opportunity to provide evidence to the Women and Equalities Committee regarding the ethical, medical, and social implications of egg donation and elective egg freezing. Our longstanding work examining the commercialization of women’s reproductive capacities—referred to as “eggsploitation”—indicates persistent concerns related to health risks, informed consent, compensation practices, and regulatory gaps. The peer-reviewed literature and interviews with firsthand accounts of those harmed by egg “donation” and egg freezing support the need for enhanced oversight, long-term health and safety monitoring and reporting, standardized counseling procedures, and protections for vulnerable populations. This submission expands on those issues and offers recommendations for legislative and regulatory reform.

1. Health Impacts of Egg Donation and Egg Freezing

Short-term health risks

Unlike women receiving fertility treatment, egg “donors” are rarely considered patients and, as a result, often receive inadequate care and attention. However, because egg “donors” are dealing with medical personnel in a clinical setting, they frequently fail to understand upfront that they are not patients and thus enter into egg donation arrangements on terms that are less than fully understood. For both egg “donors” and freezers, ovarian stimulation and egg retrieval involve known short-term medical risks, including ovarian hyperstimulation syndrome (OHSS), bleeding, infection, and complications related to anesthesia. Severe OHSS is statistically uncommon, but severely underreported. Published donor-focused studies confirm that it remains a serious and underacknowledged risk. Additional risks aside from OHSS encompass loss of fertility, ovarian torsion, stroke, renal disease, early onset menopause, ovarian cysts, and, in rare instances, mortality.  Of the medical complications that are known, they are rarely documented in the medical literature, as the individuals and organizations tasked with safety and oversight are also the ones who stand to profit from egg donation. Lupron, a drug commonly used in the first step of the egg donation process to stop ovarian function and thus medically induce menopause before hyperstimulation of the ovaries, is a synthetic hormone not approved by the FDA for use in fertility treatment. It has a Category X rating, which means if a woman gets pregnant while taking the drug, there will be harm to the developing fetus. This is extremely concerning with respect to egg “donors,” who are very fertile and may not be compliant with instructions not to be sexually active during ovarian stimulation. Unlike those who donate organs or blood, there is no requirement to track these women in a central database. After the extraction process concludes, the women serving as egg donors fade from view, with no documentation preserved about them or the eventual destination of their eggs.

Long-term health outcomes

Most concerning is that to date there has been no major peer-reviewed medical research on the long-term effects of egg harvesting on the health of the young women who provide their eggs. This makes it impossible for women to give true, meaningful, informed consent relative to the health and psychological risks involved. There is a significant lack of large-scale, long-term data on egg donors’ and egg freezers’ health outcomes. Existing evidence reviews consistently emphasize uncertainty regarding potential long-term effects on fertility, menstrual and endocrine health, and cancer risk. This absence of robust, longitudinal research undermines the ability of potential donors to make truly informed decisions.

Finally, for egg freezers, while egg quality is “frozen” in time, complications for pregnancy at an older age increase.

Risks associated with elective (“social”) egg freezing

Elective egg freezing is frequently marketed to safeguard future fertility; however, live‑birth outcomes vary substantially with age at freezing and number of eggs stored. Success rates from selective clinic-reported datasets may not reflect population-level outcomes, and success is only measured in live birth rates. A woman may need anywhere from 10 to more than 25 eggs to improve the odds of having just one live birth later. Messaging from clinics overstates likely success, which contributes to unrealistic expectations.

It is important to remember that a fertility clinic is a business with financial goals. If doctors at the clinic benefit financially from recommending more extensive or additional egg-freezing cycles, it can introduce a bias into their medical recommendations. Marketing campaigns from fertility companies often emphasize the decline of fertility with age, promoting egg freezing as a way to “freeze time.” This can encourage younger women to freeze their eggs earlier than medically necessary, potentially leading to expensive procedures and financing arrangements driven by a company’s financial model. Knowing that many women will need multiple cycles to retrieve an adequate number of eggs, there is a financial incentive for clinics to recommend more cycles. Package plans and financing options often reflect these “multi-cycle norms,” which can be financially advantageous for clinics. Further, some clinics offer discounts for friends who freeze together or offer free egg freezing if a woman donates half of her eggs. A marketing scheme that sounds enticing, knowing that many women will need more than one retrieval procedure in order to secure the necessary amount of eggs to help improve the success of a live birth later. This model either sets women up for many retrieval procedures, increasing their health risks, or sets a woman up for disappointment and failure. This model captures women who are altruistic by nature, capitalizing on financial need and completely downplaying the role she has in the life of another child. She is giving away her genetic material, which might become her son or daughter.

2. Adequacy of Counseling and Informed Consent

Peer-reviewed studies highlight inconsistencies in the quality and comprehensiveness of counseling provided to egg donors and women pursuing egg freezing. Common concerns include:

  • Understatement of medical risks and uncertainties.
  • Emphasis on financial or lifestyle benefits.
  • Limited discussion of psychosocial implications.
  • Lack of validated comprehension tools within consent processes.

Standardized, audited consent protocols—including comprehension checks and independent counseling—are required to ensure donors and patients receive accurate, balanced information. However, we ask, how can women truly give informed consent when long-term health risks remain unknown?

3. Compensation and Commercialization

Financial compensation for egg “donors” raises well-documented ethical concerns. Egg “donors” in the USA are recruited through ads in online classifieds, social media, and college newspapers, offering anywhere from $5,000 to $100,000 USD. These ads rarely, if ever, make any mention of the potential health risks involved, nor do they reveal that no long-term studies have ever been conducted. Such information is essential for decision-making and consent to be truly and fully informed.  Egg donation often involves poorer women providing eggs to wealthier couples. The unequal power dynamics of poverty and wealth are inherently coercive. Research demonstrates that monetary incentives may disproportionately influence decision-making among economically disadvantaged women, creating risks of undue inducement. We know women who have “donated” eggs to help pay for education, housing, and other bills. International analyses show that compensation structures can generate market-driven pressures that erode voluntary, informed consent. Any policy reform must critically examine how payment systems contribute to exploitation and inequity.

4. Vulnerable Women and Targeted Recruitment

Evidence indicates that women experiencing economic hardship, limited educational opportunities, or social marginalization are more likely to be targeted for egg donation recruitment. These recruitment strategies—especially through social media and student-focused channels—encourage participation based on financial incentive rather than informed, autonomous decision-making. Regulatory protections are needed to prevent predatory targeting and ensure ethically sound recruitment.

Ads commonly target specific racial, physical, and intellectual characteristics—giving parents the opportunity (or at least the illusion that they may be able) to create a custom-made, designer child. Eggs with less desirable traits that are deemed unwanted are often used for scientific research, creating a new market of abuse of poor and uneducated women. Their eggs are adequate for research purposes but not baby-making. The largest sums of money are generally offered for donors of very specific educational, physical, or ethnic traits, not only perpetuating but actually incentivizing—literally paying more for—traits that a couple or an individual desires.

5. Advertising and Marketing Practices

Clinic advertising often presents egg donation and egg freezing as empowering, low-risk, or without consequences. Analyses of UK and international clinic websites show significant inconsistencies in the accuracy and transparency of risk and success rate information. Recruitment and marketing remain unregulated, allowing for exploitation and misleading claims. Stronger regulation—particularly requiring disclosure of age-specific success rates and medical risks—is crucial to prevent misleading or coercive messages. Clinics seldom disclose how few women return to use their eggs—only 10-16%. Patients should understand that egg freezing does not guarantee future fertility; it is not an insurance plan. It is neither a reproductive insurance nor a certainty. Studies indicate that live birth rates per frozen egg can be as low as 2–12%, depending on the woman’s age at freezing. All marketing and advertising should clearly list known risks and provide real data about success.

6. Donor Information, Identity Release, and Family Support

As UK policy shifts toward greater transparency and access to identifying donor information, providing adequate psychosocial support for donors, recipients, and donor-conceived people becomes increasingly vital. Research shows that identity disclosure involves complex emotional, relational, and legal considerations. Legislative reforms should include funding for counseling for donors and recipients, as well as for donor-conceived individuals, clear protocols for mediated contact, and stronger national registries. Donor-conceived individuals are often completely excluded from this conversation.

7. Legislative and Regulatory Framework

The Human Fertilization and Embryology Act of 1990, although foundational, no longer aligns with the technological advances or commercial dynamics of today’s fertility industry. Major gaps include: limited long-term donor health monitoring, restricted oversight of advertising, recruitment, and compensation, insufficient regulatory tools for cross-border fertility markets, and limited enforcement powers for the HFEA.

Modernization of the legislative framework should prioritize women’s health, and the health of those children born from assisted reproductive technologies (ART) like egg “donation” and freezing, while addressing the expanding commercial ecosystem of reproductive technologies.

Recommendations

A. Research, Registries, and Surveillance

  1. Establish a national, mandatory long-term registry for egg donors and egg-freezing patients. This should also include a list of those conceived through these technologies, since we know that children born from ART have increased health risks.
  2. Fund longitudinal cohort studies tracking fertility, endocrine health, mental health, and cancer outcomes over 10–20 years.

B. Strengthening Counseling and Consent

  1. Standardize consent processes using validated comprehension instruments once long-term health data is realized.
  2. Require independent counseling, separate from financial or recruitment discussions.

C. Regulation of Compensation and Recruitment

  1. Remove financial compensation for egg “donation.”
  2. Restrict targeted recruitment through student-focused or financially incentivized marketing channels.

D. Advertising and Public Information Controls

  1. Require accuracy and transparency in clinic advertising, including age-specific success data and clear risk disclosure.
  2. Introduce pre-approval or audit mechanisms for advertising materials.

E. Donor Identity and Family Support

  1. Expand psychosocial support services for donors, recipients, and donor-conceived individuals.
  2. Strengthen central registries to support identity-release policy frameworks.

F. Modernizing the HFEA Framework

  1. Update HFEA statutory powers to oversee advertising, cross-border arrangements, and long-term monitoring.
  2. Enhance data-reporting requirements and enforcement mechanisms.

Conclusion

The available evidence—combined with CBC’s extensive work documenting the experiences of egg “donors” and women navigating egg freezing—demonstrates the urgent need for strengthened regulation, improved safety monitoring, and enhanced protections for vulnerable women. The Committee’s review presents a critical opportunity to ensure that reproductive technologies are governed by ethical, transparent, and health-protective standards. CBC remains committed to supporting the Committee’s work and providing additional material as needed.

References

  1. Tober D, et al. “Egg donor self-reports of ovarian hyperstimulation syndrome.” BMC Women’s Health (2023).
  2. Woodriff M, et al. “Advocating for longitudinal follow-up of the health and welfare of oocyte donors.” Reproductive BioMedicine Online (2014).
  3. Cahn N. “Fully Informed Consent for Prospective Egg Donors.” AMA Journal of Ethics (2014).
  4. ASRM Ethics Committee. “Financial compensation of oocyte donors: an Ethics Committee opinion.” Fertility and Sterility.
  5. Gürtin ZB, et al. “The marketing of elective egg freezing: A content, cost and quality analysis.” Human Fertility (2020).
  6. “Independent Review of the Human Fertilization and Embryology Act: Final Report” (2023).
  7. Pennings G, et al. “Socioeconomic influences in donor recruitment and compensation.” Human Reproduction.
  8. Harper J, et al. “Long-term health outcomes for egg donors: gaps and needs for research.” Reproductive BioMedicine Online.
  9. Frith L, et al. “UK fertility clinic website information on egg donation and freezing.” Health Communication.
  10. Greenfeld DA. “Egg donor recruitment and the ethics of targeting vulnerable populations.” Women’s Health Issues.
  11. Center for Bioethics and Culture.3 Things You Should Know About Egg Donation. Available at: https://cbc-network.org/wp-content/uploads/2022/02/3_Things_You_Should_Know_About_Egg_Donation-Center_for_Bioethics_and_Culture.pdf
  12. Center for Bioethics and Culture.What You Should Know About Egg Freezing and Selling (2025). Available at: https://cbc-network.org/wp-content/uploads/2025/08/What-you-should-know-about-egg-freezing-and-selling-2025.pdf
  13. Center for Bioethics and Culture.Comprehensive Report on the Risks of Assisted Reproductive Technology. Available at: https://cbc-network.org/issues/making-life/making-life-2/

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