Preventing and Addressing Statelessness 121 Additionally, the Permanent Bureau of Hague Conference on Private International Law (HCCH) has noted that: ‘While adoption may be a route for an intending mother to acquire legal parentage in some States, this can be far from straightforward since there may be rules which prohibit an adoption being granted where the prospective adoptive parents took part in a procurement which is unlawful or contrary to public policy’.21 On the other hand, in States that expressly permit and regulate surrogacy, the 2012 HCCH study highlights that some may allow for a ‘pre-approval’ process where the surrogacy arrangement must be presented and approved before any agreement or medical treatment may proceed. In other permissive State regimes, regulation takes the form of a set procedure for intending parents to obtain legal parentage ex post facto. Legislation governing legal parentage varies among States, as do procedures for transfer of parentage. In reviewing existing practice in States that favour regulation, the HCCH found that, while States may have varying requirements for the transfer of legal parentage, the paramount consideration is placed on the best interests of the child.22 3 Potential Measures to Address Statelessness in the Context of International Commercial Surrogacy in the Long and Short-Term Possibilities for Multilateral Regulation and Harmonisation of Private International Law As international surrogacy arrangements are a form of private international law, there have been calls for a new international convention to regulate such matters. It is argued that such a private international law instrument would provide more protection for surrogate mothers and also be in the best interests of the child as it would prevent cases of statelessness. The HCCH Secretariat has acknowledged that ‘this global phenomenon may ultimately demand a global solution’.23 The Hague Adoption Convention24 has been suggested as 3.1 21 22 23 24 HCCH, ‘A Preliminary Report on the Issues arising from International Surrogacy Arrangements’ (n 6) 10. Ibid. 14. Ibid. 30. Hague Conference on Private International Law, Hague Convention on the Protection of Children and Co-operation in Respect of Intercountry Adoption (29 May 1993) (Hague Adoption Convention). tilburg law review 19 (2014) 117-126