We are writing this submission as a group of academic researchers, including legal scholars, bioethicists, and political scientists whose research focuses explicitly on the governance of assisted human reproduction in Canada and its implications for key stakeholders, namely donor-conceived people, gamete donors, women who act as surrogates, and intended parents. We are frequently called upon to provide our expertise to the Government of Canada and others in the development of laws and regulations related to assisted reproduction in Canada, and we have all published extensively on the challenges of governing in this field.

While we support the federal government’s development of these long-awaited regulations, there are a number of areas of concern raised by the proposed regulations and we have specific recommendations to address them. We have grouped these recommendations into three categories as related to: A) Safety of Sperm and Ova Regulations; B) Reimbursement under the Assisted Human Reproduction Act Regulations and C) Regulations Amending the Assisted Human Reproduction Act.