Family Limits in Europe
A Position Paper from the Danish Egg and Sperm Donation Association June 2026
June 2026
Key Considerations Before Implementing a Family Limit
ESHRE presents the 15-family limit as a potential long-term ambition rather than an immediate policy recommendation and recognises that further evaluation is needed. Importantly, the proposed 15-family limit is not primarily driven by medical, genetic or
consanguinity concerns, but by psychological and social considerations relating to donor-conceived people’s experiences.
Before Europe commits to any long-term target, policymakers should demonstrate:
- That the expected benefits are supported by evidence.
- That sufficient donor recruitment capacity can realistically be achieved. • That patient access can be maintained throughout any transition. • That a realistic implementation strategy exists.
This assessment should take into account the practical implications for patient access, donor availability and cross-border fertility treatment.
Access to Care Is at Stake
According to the World Health Organization, around one in six people experience infertility during their lifetime. At the same time, increasing numbers of single women and same-sex couples rely on donor conception to build their families. For many patients, donor conception is not simply a treatment option – it is their only route to parenthood.
As fertility rates continue to decline across Europe, access to fertility treatment and donor conception is becoming increasingly important for individuals, families and society as a whole. Any policy that significantly reduces donor availability or increases waiting times therefore has direct consequences for access to care and for the ability of many people to build the families they aspire to have.
Before Europe moves towards any family limit, policymakers should demonstrate that the expected benefits for donor-conceived people outweigh any potential consequences for donor availability, patient access and treatment capacity.
A 15-Family Limit Requires Major Capacity Expansion
A reduction to 15 families is not simply a regulatory adjustment. It would require a fundamental expansion of donor recruitment capacity across Europe.
Europe is estimated to have approximately 3,000–3,500 donors available for patient treatment within the regulated system. Maintaining this donor pool requires the recruitment and qualification of around 700 – 800 new donors annually. However, donor recruitment cannot simply be increased on demand. Donors must meet extensive medical, genetic and regulatory requirements and undergo comprehensive screening before they can be approved. As a result, only around 2% of potential donors applying and 5% of applicants who donate first sample, ultimately become approved donors.
Our preliminary modelling, based on a significant part of the European banks in the market, indicates that implementing a family limit of 15 would lead to approximately 60% of donors currently available in the European market to be discontinued, creating a significant reduction in donor availability.
Combined with upcoming SoHO requirements for requalification of sperm inventory and the phase-out of No ID donors in additional EU countries, a further 10–15% of the current sperm inventory in Europe could be withdrawn from the market, primarily affecting smaller regional sperm banks with lower than required testing and documentation practices.
These changes could reduce short-term donor availability by as much as 70–75%, leaving Europe unable to meet donor demand for several years. Rebuilding donor availability from this reduced base is estimated to take between three and six years, require investments exceeding 100 million Euro and with significant implications for access to fertility treatment across Europe.
Yet capacity cannot be expanded overnight. Establishing a new donor recruitment site at the highest quality of today’s leading banks, and with scalable infrastructure, typically requires +€2 million in investment, 1–2 years for establishment, licensing and regulatory approvals, and a further 9–12 months before newly recruited donors become available for treatment. In practice, new recruitment capacity often takes 2–3 years before it contributes to patient access.
At the same time, donor recruitment is already challenging across many European markets. Recruitment programs—both private and publicly funded—have been discontinued in regions unable to sustain sufficient donor supply.
Additional SoHO restrictions affecting donor compensation and recruitment efforts are unlikely to support the substantial expansion of the donor pool that would be required. At the same time, expectations placed on donors have changed. What was historically understood as a donation is, in some countries, increasingly associated with expectations of future identification and potential contact with donor-conceived individuals. For some potential donors, these developments may make donation less attractive and reduce their willingness to participate.
These combined challenges risk reducing donor availability, increasing waiting times and limiting access to fertility treatment across Europe. The investments required to rebuild donor availability are likely to be reflected in higher treatment prices at a time where fertility treatment has already become significantly more expensive across Europe since 2017. These risks creating additional barriers to care for patients and further limiting access to treatment.
Reduced Access May Drive Patients Outside Regulated Systems
When access to regulated treatment becomes more difficult, patients naturally seek alternatives. Reduced donor availability may increase reliance on informal donor arrangements, online donor matching platforms and cross-border treatment outside established regulatory frameworks.
Such pathways often provide lower levels of screening, traceability, counselling and long-term oversight than regulated donor programmes. Future regulation should strengthen regulated pathways, not unintentionally create incentives to move outside them.
Recommendation
Before Europe commits to a long-term target of 15 families, policymakers should demonstrate:
- That the expected benefits are supported by evidence.
- That sufficient donor recruitment capacity can realistically be achieved. • That patient access can be maintained throughout any transition. • That a realistic implementation strategy exists.
A long-term ambition is not, in itself, an implementation plan. At present, we do not believe sufficient evidence, capacity planning or implementation considerations have been presented to support a transition to a 15-family limit across Europe.
Final Consideration
While well-intentioned, lower family limits would create substantial operational and financial challenges, ultimately, patients—not systems—will bear the burden through reduced donor availability, longer waiting times and higher treatment costs.
Policymakers and professional bodies such as ESHRE must ensure that proposed regulations are sustainable in practice. This requires balancing ethical considerations with realistic supply constraints and ensuring continued access to care. The objective should be a donor conception framework that supports the interests of donor-conceived people, donors and intended parents while preserving equitable access to fertility treatment across Europe.
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