Ms Tracy O'Keeffe:

As regards models for recognition of international surrogacy, it is an issue with which countries across the world, and in Europe in particular, have had to deal, especially in recent years. We are not aware of any country that has found a specific model or legislative framework. To the best of my knowledge, most countries deal with it in their existing family law framework. Adoption in particular has been used as a route to parentage in international surrogacy cases, particularly in European jurisdictions.

As regards a pre-birth or post-birth model, the Health (Assisted Human Reproduction) Bill provides for a two-step process in respect of surrogacy taking place in Ireland, consisting of the pre-conception stage and then the post-birth parental order. A pre-birth approval may not be sufficient, but that is getting into questions of policy.