Georgia vs Cyprus Surrogacy: Is It Really a Choice?

Georgia and Cyprus are often listed together as lower-cost options near Europe, but for most international intended parents they are not a like-for-like choice. Georgia is open to foreign heterosexual couples under a written law that names the intended parents on the birth certificate. The Republic of Cyprus allows only altruistic surrogacy and requires the intended mother to live in Cyprus, so most visiting parents cannot use it. Programmes marketed in the north of the island operate without a recognised legal framework, and UK government travel advice updated in August 2026 warns about them. Read our full pages on surrogacy in Georgia and surrogacy in Cyprus for the detail behind this comparison.

Georgia vs Cyprus side by side

Georgia is open to heterosexual couples, uses compensated surrogacy and registers the intended parents at birth without a court. The Republic of Cyprus is restricted to residents, allows expenses only, and requires Council and court approval before embryo transfer. Northern Cyprus has no legal framework, and its birth documents are not recognised by the UK.

Cost figures are estimates built from published price lists and a consultant's range, used only as a cost basis. They are not quotes.

Georgia: open to heterosexual couples, with political risk

Georgia allows surrogacy for heterosexual couples under Article 143 of its 1997 Law on Health Care, which was unchanged when we checked on 5 October 2026. The intended parents are registered on the birth certificate under statute, without a court order. The main risk is political: a 2023 bill to ban foreigners was withdrawn, but could return.

Article 143 of the Law on Health Care (opens in new tab) says that when the child is born, the couple are the parents and the surrogate has no right to be recognised as the mother. Under Order No. 18 (opens in new tab) of the Minister of Justice, the registry names the intended parents if it receives a clinic document confirming the embryo transfer and a notarised contract signed before IVF. The same order defines a couple as "a woman and a man". Georgia's 2024 Law on Family Values adds that same-sex unions registered abroad have no legal force there, so same-sex couples and single people are excluded.

Cyprus: residence required in the Republic, no framework in the north

The Republic of Cyprus permits altruistic gestational surrogacy only with Council and court approval, and only where the intended mother has permanent or habitual lawful residence in Cyprus. Visiting parents do not meet that test. In the north there is no legal framework, and UK travel advice updated in August 2026 sets out serious risks.

Under Law 69(I)/2015 (opens in new tab), the intended mother and the surrogate must live in Cyprus; only the surrogate's requirement can be waived. The intended mother must be medically unable to carry a pregnancy, assisted reproduction for women has an upper age limit of 53, and the surrogate must already have a child and may act no more than twice. Payment is limited to expenses and lost earnings, and an 11-month bank guarantee is required before embryo transfer. Commercial arrangements and advertising are criminal offences.

Most programmes marketed to international parents, including male couples and single men, are in the north. The UK Foreign, Commonwealth & Development Office's Cyprus travel advice (opens in new tab) says clinics there are not regulated, there is no legal framework for surrogacy arrangements, and the surrogate has parental responsibility. GOV.UK also says a child born through surrogacy in Cyprus is not automatically British. Its entry guidance (opens in new tab) warns that entering the Republic through the north, for example via Ercan airport, is treated as illegal entry. In August 2026 a BBC investigation reported that at least 30 children may have been conceived with the wrong donors at clinics in the north.

Who each option suits

Georgia suits a heterosexual couple with a medical reason for surrogacy who can accept some political risk. The Republic of Cyprus suits only couples or single women who already live there lawfully. We do not recommend programmes in the north for anyone, because parentage, travel documents and clinic standards rest on no recognised law.

• Heterosexual couples living abroad: Georgia is the realistic option of the two.
• Residents of Cyprus: the Republic's altruistic route may be open to you, with legal advice from a Cyprus-qualified family lawyer.
• Same-sex couples, single men and single women living abroad: neither country offers a lawful route, so look at the alternatives below.

Alternatives if neither fits

If Georgia's eligibility rules or Cyprus's residence requirement rule them out, Canada is the destination we rate as open to all profiles, using an altruistic model at a moderate cost. The United States offers compensated surrogacy with strong state-level protections at a much higher cost, but since August 2026 it is uncertain for parents where neither is a US citizen.

• Surrogacy in Canada: altruistic, open to couples and single parents (Quebec excluded for non-residents), about US$70,000–125,000 and 18–36 months.
• Surrogacy in the USA for international parents: compensated, rules set state by state, about US$170,000–300,000 and 15–30 months; check the August 2026 executive order on the baby's US passport if neither of you is a US citizen.

Greece is also restricted to residents since its 2025 law change, so it is not a substitute for Cyprus. Some parents ask about Ukraine, which still permits surrogacy for married heterosexual couples, but we explain in our Ukraine surrogacy status update why we do not recommend it during the war. Parents in the Americas may find our Mexico vs Colombia surrogacy comparison useful. Whatever you choose, confirm how your baby will gain citizenship at home using our citizenship, passport and parentage guide, and compare every country on the destination comparison hub.