Written evidence submitted by Dr Giulia Cavaliere (UCL) [EDF0016]

 

1. About the author

1.1. I am Dr Giulia Cavaliere, Lecturer in Engaged Philosophy at University College London (UCL). My research lies at the intersection of applied ethics and political philosophy, with a particular focus on the ethics of assisted reproduction, fertility governance, and inequality in access to fertility services.

1.2. My work examines how fertility treatment (such as IVF) and fertility preservation (such as egg freezing) are regulated in high-income countries, and how eligibility criteria, funding arrangements, and public narratives shape individuals’ reproductive options. A central concern of my research is how reproductive governance interacts with social inequality, gendered expectations, and changing reproductive lifecourses.

1.3. I submit this evidence in my capacity as an academic, drawing on published research and normative analysis in applied ethics and political philosophy. I also briefly share my personal experience of egg freezing, solely to illustrate aspects of current governance arrangements and not as standalone evidence.

 

 

2. Scope of this submission

2.1. This submission draws on peer-reviewed research, including my published and forthcoming work on reproductive ageing, fertility governance, and inequality of opportunity in access to fertility services. It focuses on egg freezing, rather than egg donation, as the two practices raise distinct ethical and regulatory issues.

2.2. The submission addresses the following questions:

 

3. Evidence of vulnerability and encouragement into egg freezing

(Inquiry Question: “What evidence is there, if any, of vulnerable women being encouraged into egg donation or egg freezing?”)

3.1. This submission argues that evidence of women being ‘encouraged’ into egg freezing should not be understood solely in terms of explicit pressure or improper conduct by clinics. It should also take account of the structural and normative conditions within which decisions about egg freezing are made.

3.2. Decisions about egg freezing occur against the background of socially structured reproductive lifecourses in high-income countries (Cavaliere & Fletcher, 2021, 2027). Factors such as employment insecurity, housing costs, delayed partnership formation, and gendered expectations around care constrain the timing of family formation for many women. These constraints are neither reducible to individual preference nor to individual vulnerability alone (Cavaliere & Fletcher 2027).

3.3. At the same time, institutional arrangements—including the public funding of ‘medical’ egg freezing but not ‘social’ egg freezing—tend to support narratives that present age-related fertility decline as a foreseeable and individually manageable risk, rather than as something shaped by social conditions (Cavaliere & Fletcher 2027).

3.4. The effect of these arrangements is to shift responsibility for managing reproductive risk onto individuals. For women who are unable to start a family earlier in life due to structural constraints, egg freezing may therefore appear as the only available means of preserving a chance of biological parenthood (Cavaliere & Fletcher 2027).

3.5. While decisions concerning egg freezing are shaped by social norms and gendered expectations, women’s capacity to choose autonomously can co-exist with these influences. Socially influenced choices can still be autonomous where decisional capacity and freedom from coercion and manipulation are preserved (Cavaliere & Cesarano 2025). At the same time, vulnerability can arise not because women are unable to choose for themselves, but because the options realistically available to them are restricted by social and institutional arrangements (Cavaliere & Fletcher 2027).

3.6. From the perspective advanced here, evidence of vulnerable women being encouraged into egg freezing should therefore be understood broadly. It includes not only interpersonal influence or marketing practices, but also the cumulative effects of eligibility criteria, funding arrangements, and public narratives about age, responsibility, and fertility, which shape the context in which decisions about egg freezing are made.

 

4. The regulatory regime on advertising and information provision

(Inquiry Question: “Is the regulatory regime on advertising as it applies to people wishing to freeze their eggs or embryos sufficient?”)

4.1. Assessing the adequacy of the regulatory regime on egg freezing advertising requires more than checking whether individual claims are factually accurate. Advertising operates within a broader context already placing significant responsibility on individuals to manage age-related fertility decline. As such, it does not merely inform choice but also interacts with existing pressures and expectations surrounding reproductive timing (Cavaliere & Fletcher 2027).

4.2. From the perspective advanced here, the concern is not that women are misled or coerced, but that advertising may contribute to normalising a governance framework in which structurally produced constraints are managed through costly private solutions (Cavaliere & Fletcher 2027). This is especially salient for women with fewer financial resources.

4.3. An adequate regulatory regime should therefore require advertising to be context-sensitive, ensuring that information about egg freezing reflects uncertainty, limits of effectiveness, and the social and policy environment in which decisions are made.

 

5. The effectiveness of the existing legislative framework in safeguarding interests

(Inquiry Question: “Whether the existing legislative framework, including the Human Fertilisation and Embryology Act 1990, is effective in safeguarding the best interests of those undergoing treatment for egg donation or egg or embryo freezing?”)

5.1. The Human Fertilisation and Embryology Act 1990 establishes the statutory framework for assisted reproduction in the UK. Assessing whether this framework safeguards the interests of those undergoing egg freezing requires attention to how it shapes the broader governance context in which reproductive decisions are made.

5.2. The Act itself does not set substantive policy criteria concerning reproductive timing, age-related fertility decline, or the distinction between ‘medical’ and ‘social’ reasons for egg freezing. These arise through policy decisions, funding arrangements, and regulatory practice operating within the statutory framework.

5.3. Within this framework, current governance arrangements place significant responsibility on individuals to anticipate and manage age-related reproductive risk (Cavaliere & Fletcher 2027). Although these features are not mandated by the Act, they are implemented within the regulatory structure it creates.

5.4. From the perspective advanced here, safeguarding women’s interests therefore requires attention to how this statutory framework is operationalised in practice, including how licensing conditions, regulatory guidance, and advertising standards interact with funding rules and eligibility criteria to shape the context in which decisions about egg freezing are made.

5.5. This concern is compatible with recognising women’s autonomy. Women’s decisions to freeze their eggs can be autonomous even under constrained circumstances. However, safeguarding interests involves more than ensuring that decisions are formally voluntary (Cavaliere & Cesarano 2025). It also requires assessing whether governance and social arrangements create time pressure and make certain choices appear necessary rather than genuinely optional.

5.6. In this respect, while the legislative framework provides important safeguards relating to oversight, consent, and clinic regulation, it is less well equipped to address the structural sources of pressure identified in this submission. Strengthening safeguards would not necessarily require changes to the statute itself, but closer attention to how statutory powers are exercised through regulatory guidance and practice, with a view to reducing avoidable vulnerability and inequality in access to egg freezing.

 

6. Lived experience of egg freezing (illustrative context)

6.1. Alongside the academic analysis, I briefly include my personal experience of egg freezing to illustrate aspects of current practice. This is not presented as representative, but solely as illustrative of my own experience.

6.2. As a woman in my thirties with extensive academic knowledge of fertility and reproductive governance, I nonetheless found it difficult to navigate the process of obtaining clear and reliable information about egg freezing. While the HFEA website provides high-quality and accessible information, it is not obvious to all patients where authoritative guidance can be found, and much information is instead encountered through clinic websites or informal online sources.

6.3. Choosing a clinic was itself challenging. In London, there is a very large and rapidly expanding number of private clinics offering egg freezing, reflecting the recent growth of so-called ‘social’ egg freezing. Comparing clinics in terms of quality of care, staff experience, pricing structures, and patient support was difficult, even with time, resources, and prior knowledge. This difficulty would likely be amplified for those living outside major cities or with fewer financial and other resources.

6.4. The quality of care was uneven across clinics. I initially received poor care, largely attributable to what appeared to be limited experience and support within the nursing team. This had a significant impact on my treatment and stress levels, and ultimately led me to change clinic, where the standard of nursing care and overall patient support was considerably higher.

6.5. Cost was a further significant factor. Egg freezing is expensive and largely paid for privately, with costs borne predominantly by women. In my experience, it was difficult to obtain a clear and comprehensive understanding of the total expected cost at the outset. This lack of cost transparency is frequently discussed in online patient forums and adds an additional layer of uncertainty and stress to decision-making.

6.6. My experience was shaped by relative privilege: living in London, having a stable income, and possessing specialist knowledge. Nonetheless, the difficulties I encountered suggest that navigating egg freezing may be considerably more challenging for those who are less financially secure, less geographically mobile, or less familiar with medical and regulatory systems.

6.7. The purpose of including this personal experience is not to generalise or to substitute for empirical evidence, but to illustrate how current arrangements around information provision, clinic choice, and cost can affect patients in practice, even under relatively favourable circumstances.

 

7. Policy implications and recommendations

7.1. The analysis in this submission suggests that safeguarding the interests of those considering egg freezing requires attention not only to clinic-level compliance, but also to the broader environment in which reproductive decisions are made.

7.2. From the perspective advanced here, policy responses need not involve changes to the Human Fertilisation and Embryology Act 1990 itself. Instead, they should focus on how existing statutory powers are exercised through regulatory guidance and practice.

7.3. In particular, the following areas warrant attention:

•          Improving the accessibility and coherence of authoritative information about egg freezing, so that patients can navigate options more easily. Ensuring that consent processes support clear understanding in context, while recognising women as capable decision-makers.

•          Strengthening oversight of advertising and public-facing information so that it is context-sensitive, reflects uncertainty, limits of effectiveness, and avoids reinforcing purely individual responsibility narratives.

•          Increasing transparency around the full financial structure of egg freezing, including cumulative and ongoing costs, in order to help reduce avoidable inequalities in access.

7.4. Addressing these issues would help ensure that decisions about egg freezing are made in conditions that better support autonomy, reduce avoidable sources of pressure, and mitigate inequalities in access and experience

January 2026

 

References

Cavaliere, G., & Cesarano, F. (2025). Assisted Reproductive Technologies and Women’s Choices: Autonomy, Harm and Gender Socialization. Hypatia, 1-20. Online first. DOI: https://doi.org/10.1017/hyp.2024.103.

Cavaliere, G., & Fletcher, J. R. (2022). Age-discriminated IVF access and evidence-based ageism: Is there a better way?. Science, Technology, & Human Values, 47(5), 986-1010. (Open access) ​https://doi.org/10.1177/01622439211021914

Cavaliere, G., Fletcher, J. R., (2027). Reproducing Anachronism: Ageing, fertility and inequality in reproductive governance. Forthcoming for The Journal of Medicine and Philosophy. Link to the accepted version of the paper.

 

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