Georgia's surrogacy industry didn't grow organically. It metastasized after Russia banned foreign surrogacy contracts in 2022, inheriting Moscow's clinic infrastructure, its agency networks, and its client pipeline. The country registered over 3,000 surrogate mothers in 2023, up from roughly 300 births in 2021 to over 1,100 by 2023. Since 2012, more than 5,000 children have been born through surrogacy in Georgia. The country now functions as a low-cost hub in a global reproductive market shaped by regulatory arbitrage. The economics are revealing. A full surrogacy package in Tbilisi or Batumi runs €45,000–€55,000 — roughly one-third of comparable services elsewhere. Surrogate mothers report earning €18,000–€28,000 per pregnancy. The spread between what parents pay and what surrogates receive is where the agencies live, and it's a healthy margin. An estimated 19 clinics now operate across Georgia, competing for a client base drawn largely from Europe and Asia. The regulatory vacuum is the load-bearing structure of this industry. Georgian law governs the relationship between surrogates, intended parents, and clinics — but agencies, the actual intermediaries who broker deals, recruit women, and set terms, operate outside the legal framework entirely. The state sets no minimum standards for social guarantees, medical care, or contractual terms for surrogates. Human rights lawyer Nino Bogveradze identifies this as the critical weak spot: the entities with the most market power face the least oversight. Surrogate mothers occupy the weakest position in this arrangement. After embryo implantation, Georgian law prohibits them from keeping the child, leaving the program, or terminating the pregnancy. Multiple surrogates told DW that payment delays were common. Human Rights Watch and the International Women's Health Coalition have flagged these conditions as violations of reproductive self-determination. The women are overwhelmingly from precarious economic backgrounds — Russian, Ukrainian, Kazakh, and Georgian — using surrogacy fees for property down payments and apartment renovations. Intended parents face a different but parallel set of pressures. Olga and Daniel, a Hamburg couple, describe months of searching followed by aggressive sales tactics: urgency about other interested couples, emotional manipulation about childlessness, reluctance to answer medical questions thoroughly, and a 30-minute Zoom call presented as sufficient for selecting a surrogate. When they discovered their chosen surrogate would return to war-torn Ukraine mid-pregnancy — contradicting earlier assurances — the gap between agency promises and operational reality became concrete. Olga Doletskaya of the University of Leeds names the dynamic plainly: agencies frame their work as a humanitarian mission to help couples have children, but they are primarily driven by financial interests. That financial interest produces pressure in both directions — squeezing surrogates on pay and conditions while rushing intended parents past due diligence. The agency sits at the extraction point between two vulnerable parties, each of whom has limited alternatives and high emotional stakes. The deeper structural problem is that Georgia's surrogacy boom is built on regulatory arbitrage, not comparative advantage. The industry exists in Georgia because it was banned or restricted elsewhere. That means the incentive structure rewards the jurisdiction with the weakest protections, and any attempt to regulate will simply push agencies to the next permissive country. Without coordinated international standards — which do not exist and show no signs of emerging — the pattern will repeat.