I. Comparison of Surrogacy Laws and Policies in Jihad and China, which one is more friendly to Chinese people?

First give you a "pulse table", a glance to understand the two countries in the"Who can do it, how do you sign it, who gets the kids, what are the restrictions"Key Differences (as of 2025):

You'll see: Kazakhstan is more"Stable.", but the threshold is more like"Access"(b) Kyrgyzstan."Loose."Democratic Republic of the CongoCross-border compliance details to nip atThe following is a "dismantling" of the laws of the two countries. The laws of the two countries are "taken apart" and put into human terms.

1. Laws on surrogacy in Kazakhstan: strictly regulated and suitable for legal couples

• Who can be the "principal":Sections 54-59 of the Code spell out the subject matter of the contract as"Husband and wife (principal)"This means that contracts, registration of parental authority, liability for abandonment, etc., are carried out on a "conjugal" basis. This means that contracts, registration of parental authority, liability for abandonment, etc., are carried out on a "conjugal" basis. Single persons and same-sex couples cannot be contracted as "couples" under the local legal framework.
• How the contract is signed:Surrogacy contractMust be in writing and notarizedThe ART provider is usually required to sign a service contract with the ART provider, so that the rights and responsibilities of all three parties are clearly defined.
• (c) "Hard targets" for surrogate mothers:20-35 years of age with at least one healthy biological child; if married.Written and notarized consent of spouseThis is a "red line" in practical screening. This is a "red line" in practical screening.
• How paternity rights fall:Article 59 makes it clear that after birth, the parents of the child are legally recorded as "husband and wife (commissioners)", and the mother's column on the medical birth certificate may beWrite directly "the woman's attorney.". A surrogate mother has no right to assert parental rights as a guardian.
• Can foreigners do it:The Code does not prohibit foreign contractors; the Kazakh e-government portal provides information and instructions on surrogacy, indicating that the system is open to the public. In practice, foreign couples can contract and give birth locally, but the key is the connection of the documents for returning to the country.

Why do I call it "stable"?--Because contracts, notarization, and registration are in the code.full link closure: subject of contract = husband and wife, parental rights = husband and wife, abandonment/multiple births = joint responsibility of husband and wife, it's all written in the text; once you go by the law and the hospital process.The space for disputes is then minimizedThe

2. Kyrgyz surrogacy laws: flexible policies and greater inclusiveness

• The declaration of rights is very "broad":Article 57, paragraph 5, of the Health Protection Act:"Citizens (the law defines 'citizen' earlier to include foreigners residing temporarily or permanently in the country), regardless of medical indications and marital status, have the right to become parents through surrogacy."That's a fairly open statement in the region.
• How exactly:Article 104 requires the notarization of the surrogacy contract, that the surrogate mother be 20-35 years of age and pregnant, that spousal consent be given if she is married, that the commissioning party bear the costs of medical care during the pregnancy and after the birth, and that the commissioning party be recorded directly in the birth registry as the parent, etc., and the rules of practice are similar to those of Kazakhstan.

That's the "price of flexibility": it's very accommodating on paper, but you have to make compliance a priority.strike the right pose(residency, contracts, notarization) to get going.

II. Legal safeguards for key links: paternity determination and the process of registering the child in the home country

Whether KZ or KG, the common substrate of legal design is:Contract first - medical implementation - birth registration directly records the commissioning party as the parent.This determines two of the most sensitive aspects for Chinese families:

1. Parental rights are recognized locally

• Kazakhstan:Article 59 states directly that the parents are "husband and wife (principals)"; the birth certificate may refer to the "mother" as the woman's principal. This is done locally.Original registration of parental rightsThe
• Yoshikuni:Article 104, paragraph 7, specifies that the birth is registered as the parent of the commissioner; there is also a provision restricting the commissioner's "abandonment of the child", which protects the rights of the newborn child.

2. Repatriation of children and household registration (the relevance of The Hague/Apostille)

Starting from November 7, 2023, mainland China has acceded to and implemented the Hague Convention on Legalization, and Chinese and foreign official documents are generallyApostille (additional certificate) only.It can be used across borders, dramatically reducing the time and cost of "dual certification". It means to you:Faster cross-border recognition of birth certificates, court/notarized documents.

3. My Attitude and Suggestions on this Part

• miss (feel wistful about the absence of sb. or sth)Married heterosexual couples "going steady": Kazakhstan is more like a"Highway.", with clear rules and fewer disputes, but the barriers to entry (marriage, medical opinions) and process discipline are stronger and more restrictive.
• Single/special family structure(including LGBT individuals operating as "singles"): Kyrgyzstan's law is more inclusive in its formulation but more rigorous in its implementation.
• No matter what country you go to: put"Parental Rights at Birth + Hague Certification + Domestic Settlement List"Three things strung together in a chain.Line up risk points before negotiating prices/hospitalsThe

III. In-depth analysis of the total cost of surrogacy in Kyrgyzstan and Kazakhstan

Let's get one thing straight: neither country is a "bargain", but compareSurrogacy in the United States At a cost of $100,000 to $150,000, Central Asia is stillCost-effective route. In general, Kazakhstan is more"Steady, full, tight process"and slightly higher prices; Kyrgyzstan is more"Inclusive and flexible", with wider price bands. The table below is a comparison of the range of publicly quoted prices in the 2025 market (primarily from the public agency/intermediary page with clinic price lists, which are reference budgets):

Note: The above is the market reference price, which varies greatly from package to package; the specific offer is based on the current contract list of the clinic/organization.

1. Breakdown of surrogacy costs in Kazakhstan (updated for 2025)

If the keywords you want are"Stabilize, close the loop, and reduce the rip-off", the standardized overhead in Haguk basically looks like this (the intervals are cross-takes of mainstream public quotes):

E-Government Kazakhstan makes it clear that the commissioning party should cover the costs of the surrogate mother's pregnancy checkups, labor and delivery, and medical care related to the 56-70 day postpartum period (with complications extending to 70 days) - that's why maternity care is one of the biggies in the regular package.

How do I read this table?

• The "hard costs" are mainly composed ofIVF/PGT, surrogate mother compensation, maternity care, legal documentsFour blocks make up the composition.
• Common packages totaling $60-75K USD typically include one IVF + 1-2 transplants, surrogate mother screening, pregnancy management, labor and delivery, and legal and birth registration; prices can go up to $70K and up if you add PGT, donor egg/sperm, or multiple transplants.

2. Cost components of surrogacy in Kyrgyzstan

Yoshikuni's prices are more"Loose."But you have to look at the "what's included". Below is a list of packages available in the last few months and what they consist of:

Two details, don't overlook:

1. Many "all-inclusive" packages include only 1 migration by defaultIn some cases, it is stated that a second transplant is required to make up the difference; others explicitly include "two transplants".
2. The launch of e-Apostille means a shorter certification chain, but it does not mean "zero cost/zero documentation" - translations, notarizations, excerpts from hospital records, birth certificates, etc. still have to be prepared.

3、How to recognize "contract traps" and avoid unnecessary hidden costs?

A short summary:

Budgeted and wanting process stability - Kazakhstan's Full Link Clarity + Strong Constraints is good value for money (but accept a slightly higher total price).
Budget-sensitive, or requiring more flexible legal formulations (e.g., single path) - Kyrgyzstan is able to offer a richer mix of "equal budgets," but contractual terms and compliance details must be in place.

IV. Comparison from IVF Success Rate to Chinese Services

When it comes to cross-border assisted reproduction, the technology is the "hard core" and the experience is the "stability of the walk". Both must be passed.

1. In vitro fertilization (IVF) versus genetic screening (PGT) techniques

Let's start with "can it be done and how mature is it".

Kazakhstan (KZ)

Older centers have more and newer equipment, and routine IVF/ICSI, Time-lapse culture, PGT-A/M/SR are basically available. Take IRM (Institute of Reproductive Medicine) in Almaty as an example: the official website openly provides aCGH/FISH and other embryo genetics testing programs, and describes itself as PGT-aCGH program."The average effective rate is about 621 TP3T."(Note: the term "efficiency" varies from center to center and usually refers to pregnancy/transfer success rates rather than live birth rates.) IRMs also have their own cryobanks for sperm/eggs/embryos and surrogate mother/donor databases, making the process more systematic.

Kyrgyzstan (KG)

The last two years have been "filling in at a fast pace". Like the DOC University Clinic (Bishkek), the external labeling can do IVF/ICSI, PGT, egg supply / sperm supply and pregnancy management, and for Chinese-speaking clients haveChinese Pages and Chinese Docking Channels(very language-anxiety friendly); and Delta Bishkek, which opened in April 2024 and is operated by a Russian Delta/NGC team based in Bishkek. If you prefer to be close to Bishkek and want to be exposed to the "Russian team's technology", Delta is an alternative "player".

More importantly, the text of the law includes "assisted reproduction and surrogacy" in the parent law: Article 104 of the new law of January 2024 explicitly allows IVF, embryo implantation, artificial insemination, and the use of surrogates; there is no explicit provision on the possibility of gender selection in Article 104 of the Law on Protection of Health, which is available in the public domain/the relevant Acts. There is no explicit provision in the publicly available Law on Health Protection/relevant acts prohibiting this behavior, and this year two parents chose their sex in Kyrgyzstan.

Dragon-phenix twins/twin babies:Don't be sidetracked by "multiple births = better value". The latest guidelines from the European Society for Reproduction (ESHRE) emphasize thatPriority single embryo transferThere is no single "clinical condition" that automatically proves that double embryo transfer is better, and controlling multiple births is the key to safety and outcome.

Technical & Compliance Highlights at a Glance

2. DOC vs IRM, Delta

IRM (Almaty/Astana/Shymkent)

• Advantage:Chained, many leaders, open PGT protocols, Cryobank+ provider pool, mature processes; patient convenience modules such as "accommodation/transportation guidance for foreign patients, online payment" (which reduces local chores).
• Attention:Success rate please ask for a clear definition of caliber (clinical pregnancy/heart buds/live birth).Avoid looking at "advertised numbers."The

DOC University Clinic (Bishkek)

• Advantage:The page provides a direct Chinese language interface, emphasizing "one-stop medical assistance".Low communication costs; suitable for families who are traveling abroad for the first time for medical treatment and need to be accompanied by a Chinese-speaking person.

Delta Fertility

• dominanceDelta Fertility / NGC Reproductive Medicine System in Moscow / St. Petersburg, which is part of the Russian reproductive technology export chain, has a technological endorsement in terms of embryo laboratories, equipment configuration.

3、Facilities for Chinese customers: visa, language and escort services

"Whether or not you can enter the country smoothly and communicate well" will directly affect your sense of fitness.

Arrivals and flights

Language and Accompaniment

• The hospitals in KZ/Leia are predominantly Russian/Khazi/English speaking, and the Head Center supports translation assistance and reception services for foreign patients.
• KG's DOC provides Chinese pages/docking, which is closer to domestic communication habits.
• No matter what country.Please prepare electronic copies of key medical records/previous labs in advance in both English and Chinese.The

V. How to choose a reliable surrogacy agency and service provider?

Don't mistake "can do" for "can do with confidence". It's the screening criteria that determines whether or not you'll be able to do it.

1、Directly operated organizations vs. intermediaries: what are the advantages and disadvantages of each?

Recommended Reading:Recommended surrogacy agencies in Kyrgyzstan

Bi-national compliance "red lines"

• KZ:Surrogacy agreements need to be in writing and in accordance with the elements of civil law, with clear attribution of parental authority, and within the framework of articles 54-59 of the Code on Marriage and the Family; the Government's eGov has a page on the main points of surrogacy contracts (which, in practice, are mostly notarized).
• KG:Article 104 requires agencies to be licensed and contracts to be notarized; and prohibits unregistered subjects from advertising surrogacy-related advertisements inside or outside the country (including on the Internet).

2. Examining the process of surrogate mother screening and pregnancy management

This is the "foundation" for success and safety.

• Medical and Psychological Evaluations (surrogate mother's end):Surrogate mothers are required to complete an assessment of past maternal history, a basic physical examination, screening for infectious diseases, a psychological assessment and access to independent legal advice; the safety of the mother and fetus should also be prioritized whether or not to set up a single embryo transfer strategy.
• Management of Pregnancy (Consensus Approach):Emphasis is placed on individualized follow-up rhythms with key time-point services not missed (e.g., early pregnancy documentation, systematic ultrasound at 20-24 weeks, glucose tolerance, late pregnancy assessment, etc.).
• Multiple birth control:Prioritizing singleton transplants to keep the twin rate down is a safer option for both surrogate mother and baby.
• Fee escrow and information transparency:Surrogate mother reimbursement is recommended to go to a third-party escrow account; milestone payments are aligned with key clinical nodes to avoid "pay first, pay later".

Conclusion: Kyrgyzstan or Kazakhstan?

1. Portrait of the population suitable for the choice of Kazakhstan

• Legitimate couples(those who can provide marital/infertility, etc. material in the country) - easier to meet the local code requirements for who it applies to, with the shortest straight line of compliance.
• Older but wanting to "play it safe"--With many well-established centers and mature PGT and Cryobank packages, it is possible to go for PGT followed by single-embryo transfer to keep the risk under control; however, it is still necessary to be wary of "publicizing the success rate", and live births are the king.
• Tight schedule, easy commute--Northwest departures have direct flights from Urumqi ⇄ Almaty and 30-day visa waivers to reduce entry/exit friction.

2. Portrait of the population suitable for choosing Kyrgyzstan

• Legitimate couples, singles, or the LGBT communityThe new KG law is clear and accommodating in its policy text; Article 57 gives "reproductive rights regardless of marital status" and Article 104 regulates ART and surrogacy, notarization and licensing requirements, with clear boundaries and high tolerance for error (but avoiding "unlicensed intermediaries"). (but avoiding "unlicensed intermediaries").
• Strong demand for Chinese language services/smooth communication--Centers such as DOC and Deltas are more friendly to Chinese-speaking customers, so you can feel more at ease when you go abroad for the first time; entry is usually done through e-Visa, and individual visa waivers only cover certain conditions, so be sure to check before you go.
• Budget sensitive but receptive to "more verification"--Medical quotes may be more cost-effective, but need to put the three-piece qualification, notary, and escrow package in place.