Legal Analysis of the European Commission’s Communication of 26 February 2026 Regarding the Pro-Abortion European Citizens’ Initiative “My Voice, My Choice”

Table of contents

1. General remarks on the European Citizens’ Initiative. 2

2. European Citizens’ Initiative “My Voice, My Choice” – scope and demands. 3

2.1 Legal basis for the proposed actions. 4

3. Competences of the European Union in the field of public health. 5

3.1 Case law of the Court of Justice of the European Union. 7

3.2 Use of European Union financial instruments. 8

4. References to international law.. 10

Conclusions. 12

1. General remarks on the European Citizens’ Initiative

The European Citizens’ Initiative (ECI) is a participatory democracy instrument provided for under European Union law, enabling citizens to request that the European Commission submit a proposal for a legal act in areas within the European Union’s legislative competences. Its legal basis is Article 11(4) of the Treaty on European Union and Regulation (EU) 2019/788 of the European Parliament and of the Council of 17 April 2019 on the European citizens’ initiative.[1] The initiative must relate to a matter in respect of which the Commission is empowered to submit a proposal for a legal act of the Union.[2] The Commission is not bound by the content of the initiative and is under no obligation to submit a proposal for a legal act. The ECI does not constitute an instrument of legislative initiative in the strict sense, but merely a mechanism for citizens to exert political influence on the agenda of EU institutions.

The procedure is as follows:

1) Submission of an application by at least 7 EU citizens from at least 7 different Member States for the European Commission to register the initiative.[3]

2) Preliminary formal review of the application to register the initiative. The Commission may refuse registration if: the initiative manifestly falls outside the scope of the Commission’s powers,[4] is manifestly unfounded, seriously abusive, or contrary to the Union’s values.[5]

3) Following the registration of the initiative, its organizers have 12 months to collect at least 1 million signatures from Union citizens, and these signatures must come from at least one quarter of the Member States.[6]

4) Once the formal requirements have been met, which include, in particular, collecting at least one million statements of support from Union citizens from the Member States, followed by their verification and certification by the competent national authorities, in accordance with the procedure laid down in Regulation (EU) 2019/788 of the European Parliament and of the Council of 17 April 2019, the citizens’ initiative is submitted to the European Commission, which decides on further action.[7]

5) The organizers have the right to present the initiative during a meeting with the Commission and to participate in a public hearing at the European Parliament.[8]

6) Commission decision: after a citizens’ initiative is submitted to the European Commission, the latter analyzes it in legal and political terms, including an assessment of its compliance with Union law and the extent of its own competences. At this stage, a meeting with the organizers of the initiative and a public hearing in the European Parliament are also held. Subsequently, within the time limit laid down in Regulation (EU) 2019/788 of the European Parliament and of the Council of 17 April 2019, the Commission adopts a communication setting out its position, indicating whether it intends to take action, in particular by submitting a legislative proposal, or refuses to take such action, giving reasons for its decision.[9]

In accordance with the applicable rules, the European Commission analyzes the initiative and presents its position in the form of a communication, indicating any measures it intends to take[10].

2. European Citizens’ Initiative “My Voice, My Choice” – scope and demands

European Citizens’ Initiative “My Voice, My Choice: “For Safe and Accessible Abortion” was registered by the European Commission in 2024, and subsequently—after collecting the required one million signatures, in this case over 1.1 million (exactly 1,124,513 verified statements of support)—submitted to the Commission for consideration.[11]

The organizers of the initiative called for: “(…) We are demanding that the EU passes legislation that would create a financial mechanism that helps Member States that voluntarily join this policy to provide safe abortion care for all those who don’t have access to it.[12]” As envisaged by the initiative, this mechanism would: fund the travel and lodging costs of people traveling to other Member States to undergo an abortion procedure, cover the costs of the abortion itself, and operate within the Union’s existing financial instruments or as a new dedicated fund.[13] The proposed solution would therefore be cross-border in nature and would effectively enable the use of abortion “services” outside the country of residence.

At the same time, the initiative did not definitively determine the legal form in which the proposed mechanism would be established. However, its premises indicated that its implementation would require the adoption of an act of European Union secondary legislation establishing a financial instrument, most likely within the framework of supporting measures in the field of public health, as referred to in Article 168 TFEU.

The initiative also does not specify the amount of funding allocated to achieving the intended objective. It indicates, however, that the mechanism could operate within the framework of the Union’s existing instruments, such as public health programs (e.g., EU4Health), or take the form of a new financial instrument.

Moreover, the assumptions presented indicated that Member States’ participation in the mechanism would be voluntary (“opt-in,” i.e., it would include only those Member States that chose to join), which is intended to ensure respect for their competence to organize health care systems. However, it cannot be ruled out that if financed from the Union’s general budget, the costs of this mechanism would be indirectly borne by all Member States[14].

2.1 Legal basis for the proposed actions

The organizers of the initiative indicate that such measures could be based on the Union’s competences in the field of public health (Article 9 TFEU, Article 168(1) and (5) TFEU, Article 3(1) and (3) TEU, Article 35 of the Charter of Fundamental Rights of the European Union) and social policy (Article 2 TEU, Article 3(3) TEU, Article 8 TFEU), taking into account the horizontal obligation to ensure a high level of human health protection in all Union policies and activities (Article 9 TFEU), as well as the principle of equality between women and men and the elimination of inequalities (Article 8 TFEU)[15]. They also point to the possibility of using existing financial instruments, such as the EU4Health program and the European Social Fund Plus.[16]

In its communication, the European Commission adopts a partially aligned position, recognizing that although the regulation of access to abortion as such remains outside the Union’s competence, it is possible to take supporting measures within existing EU funding programs and policy orientations, while at the same time emphasizing: (…) Against this background, it should be noted that a Member State’s decision on whether or not to legalise abortion, and under which conditions, falls fully within its freedom to organise its healthcare and therefore within the areas that remain the responsibility of Member States as set out in Article 168(7) TFEU. This is why EU action that would impact a Member State’s decision on whether and under which conditions to allow abortion is hence excluded. (…)[17].”

Consequently, due to a lack of competence, the Commission did not propose a new legal act or an instrument aimed at achieving the initiative’s objective, but instead limited itself to indicating the possibility of using existing financial programs in a neutral manner, i.e., theoretically without interfering in national bioethical choices and without creating a mechanism pursuing a uniform substantive objective at the EU level.

3. Competences of the European Union in the field of public health

The scope of the European Union’s authority in the field of public health is crucial for assessing the proposals contained in the European Commission’s Communication. This scope delineates the limits of permissible intervention by EU institutions in matters related to the organization of health care systems and the regulation of medical procedures in the Member States.

The organizers of the initiative refer in this respect to a number of provisions of primary law, pointing in particular to Article 9 TFEU, which establishes a horizontal obligation to take health protection into account in the definition and implementation of all Union policies and activities, and to Article 168 TFEU, which places an obligation on the Union to ensure a high level of human health protection and provides for supporting, coordinating and supplementary action, including the possibility of adopting so-called incentive measures in the area of public health protection and improvement. In the initiators’ argumentation, significant importance is also attached to Article 8 TFEU, which lays down the principle of eliminating inequalities and promoting equality between women and men in all the Union’s activities, as well as to the provisions of the Charter of Fundamental Rights of the European Union, in particular Article 1 (human dignity), Article 3 (right to physical and mental integrity) and Article 21 (prohibition of discrimination), which are intended to justify the claim that it is necessary to ensure genuine access to services in the area of so-called reproductive health, which, in the initiators’ view, would also include the possibility of obtaining an abortion, as part of the realization of fundamental rights.

This line of argumentation, however, is primarily functional and teleological in nature and does not establish the existence of the Union’s competence to finance or to organize access to specific medical procedures in the Member States. According to Article 168(7) TFEU, primary responsibility for defining health policy and for the organization and financing of health care systems remains within the competence of the Member States, which means that the Union’s competences in this area are of a complementary nature and cannot lead to the harmonization of national rules concerning health care services. Likewise, Article 9 TFEU and Article 8 TFEU are horizontal clauses that strengthen the requirement to take health and equality considerations into account in Union policies; however, they do not in themselves constitute an autonomous competence-conferring legal basis for creating new financial obligations in the field of health care services. Consequently, although the set of treaty norms and fundamental rights invoked by the organizers may support value-based argumentation in favor of increasing the accessibility of health care services, which they also consider to include abortion, it does not eliminate the constraints arising from the explicit division of competences between the Union and the Member States in the area of health care.

Moreover, legal scholarship emphasizes that Article 168 TFEU reflects a compromise between the Member States that opposed conferring broad competences on the Union in the field of health and those that advocated their extension. As a result, a model with limited competence was adopted, focused on public health in the collective sense, rather than on the provision of healthcare services at the individual level.[18] This means that the Union’s competences primarily concern areas such as disease prevention, health promotion, scientific research, information exchange, and addressing epidemiological threats, but do not include the organization of health care systems or determining the scope of health care services available to citizens.[19]

In this context, Article 168(7) TFEU is of key importance; it unequivocally states that responsibility for defining health policy and for the organization and provision of health services and medical care rests with the Member States. This also includes the management of healthcare systems and the allocation of financial resources earmarked for these purposes[20].

In the legal literature, it is noted that this provision serves a guarantee function, safeguarding the autonomy of Member States in areas that are particularly sensitive from axiological, social, and constitutional perspectives. This applies in particular to issues related to the beginning and end of human life, including regulations regarding the permissibility of abortion[21].

3.1 Case law of the Court of Justice of the European Union

The case law of the Court of Justice of the European Union is also crucial for assessing the scope of the Union’s competences, in particular the judgment in the Grogan case (C-159/90). In this case, the Court confirmed that “services involving the performance of abortions” may constitute a “service” within the meaning of EU law, yet at the same time it did not undermine the Member States’ right to restrict such “services” on the grounds of fundamental constitutional values.[22] This is clear confirmation that EU law is not an instrument for unifying moral decisions in such sensitive areas as the regulation of abortion.

Crucially, the legal literature on the subject emphasizes that the Court, in this case, refused to substitute its own moral assessment for that adopted by the Member State, thus holding that ethical issues remain within the purview of nation-states.[23] As noted by S. O’Leary and S. Iglesias Sánchez[24], in the case of Grogan the Court did not make its own assessment of the permissibility of abortion, but confined itself to recognizing that under certain conditions it may constitute a service within the meaning of Union law, while at the same time clearly separating that classification from any interference in the national ethical assessment of this procedure.

It is of crucial importance that the Court did not seek to harmonize or indirectly unify the moral standard concerning the permissibility of abortion, but instead accepted the existence of enduring axiological differences among the Member States.

As a result, this ruling is interpreted in the legal literature as confirmation that issues of an ethical nature (especially those belonging to the field of bioethics and the protection of life) essentially remain within the purview of the Member States, which retain the competence to regulate them in accordance with their own constitutional and social traditions.

This case law fits into the broader context of competence disputes between the Union and the Member States in the field of health, which—as legal doctrine indicates—often take the form of tension between the principles of the single market and national regulations based on constitutional values.[25]

3.2 Use of European Union financial instruments

In the communication under review, the European Commission acknowledges that the Union lacks competence to harmonize laws on abortion. At the same time, however, it points to the possibility of using the Union’s financial instruments—such as health programs or structural funds—to support access to “services” in the area of so-called reproductive health.[26] The Commission refers in particular to instruments such as the European Social Fund Plus (ESF+) and the EU4Health program, emphasizing that these funds can be used to improve access to health services and to support the health policies of the Member States.[27]

Such an interpretation raises serious doubts in light of the principle of conferral (Article 5(1)–(2) TEU). Under this principle, the European Union may act only within the limits of the competences expressly conferred upon it by the Member States in the Treaties, while any competences not conferred remain with the Member States. This means that both the existence of EU competences and their scope must derive directly from the provisions of the Treaties, and not from an expansive or teleological interpretation that would lead to the creation of new areas of Union action by implication.

Legal doctrine emphasizes that the principle of conferral serves as a “negative boundary” of integration, precluding any presumption of competences in areas not expressly conferred by the Treaties, even if such actions could pursue the EU’s general objectives.[28]

Consequently, this principle constitutes a significant limitation on attempts to derive the Union’s competence to finance certain medical services, including abortion, from general treaty provisions concerning, for example, the protection of public health, equality, or fundamental rights. Accordingly, it is not permissible to interpret primary law in a manner that would circumvent the limitations on competences by deeming the financing of procedures with a strong ethical dimension to fall within the Union’s general objectives.

At the same time, it should be emphasized that adopting a different position would create a significant systemic problem: the lack of clear boundaries between the competences of the Union and those of the Member States. In practice, this would entail the possibility of gradually expanding the scope of EU action through a functional interpretation, which would weaken the safeguard function of the principle of conferral. Importantly, this would lead to a situation in which the same treaty provisions could be interpreted as a basis both for action by the Union (e.g., the financing of certain medical procedures) and for that action to be challenged by the Member States, which retain competence for setting ethical standards and for the organization of health systems. Such ambiguity would pose a risk of jurisdictional tensions and of undermining legal certainty.

As the legal literature indicates, the development of EU law and policy in the area of health, carried out “with different degrees of visibility,” may have implications for fundamental rights and—accordingly— call into question the legitimacy or even the constitutionality of the Union’s role.[29]   

In particular, it should be noted that the financing of certain medical procedures by the Union may lead to de facto interference in national healthcare systems, and thus infringe upon competences reserved to the Member States. When the state decides to restrict access to certain benefits for constitutional or axiological reasons, funding them from EU funds may undermine the effectiveness of those regulations.

The Union’s competence in the area of public health is primarily of a supporting, coordinating, and supplementary nature, which means it has no authority to harmonize national regulations or to determine the substantive scope of healthcare services. However, financial mechanisms may generate a de facto regulatory effect, by incentivizing the performance of certain medical procedures regardless of national restrictions arising from constitutional, ethical, or axiological considerations.

This leads to a tension between the formal retention of the Member States’ competence to organize the health care system and the actual impact of EU instruments on the availability of health care services. In such an arrangement, one can speak of a form of regulatory compensation, whereby national restrictions lose part of their effectiveness through the provision of an alternative source of funding at the EU level.

Consequently, it should be recognized that although the European Union may adopt supporting measures in the field of public health, it is not empowered to shape—either directly or indirectly—the Member States’ policies on the permissibility of certain medical procedures, including abortion. Attempts to use financial instruments for this purpose should be regarded as falling outside the scope of the competences conferred upon the Union by the Treaties.

4. References to international law

In its communication, the European Commission refers to a number of international legal instruments concerning women’s rights and so-called reproductive health, identifying them as a point of reference for the Union’s actions in this area.[30]

In particular, the following are cited: The Beijing Declaration and Platform for Action of 1995 and the 1994 Programme of Action of the International Conference on Population and Development (ICPD), which emphasize the importance of access to health care and the improvement of so-called reproductive health.[31] However, the Commission overlooks the important fact that these documents do not establish an international right to abortion. On the contrary, the ICPD Programme of Action clearly states that “In no case should abortion be promoted as a method of family planning.”[32]

Furthermore, the same document emphasized that “any measures or changes relating to abortion within the health care system may be determined exclusively at the national or local level in accordance with the national legislative process,[33]” which clearly confirms that this matter remains within the competence of the states.

Likewise, the Beijing Declaration and Platform for Action in no way create a right to abortion, but indicate the need to reduce the number of abortions by improving access to education, health care, and social support[34].

The Commission also does not address the fact that binding international treaties—such as the Convention on the Elimination of All Forms of Discrimination against Women (CEDAW) or the Convention on the Rights of Persons with Disabilities (CRPD)—do not impose an obligation to legalize abortion. The provisions of these conventions focus on ensuring equal access to health care, without prejudging the permissibility of specific medical procedures.[35] Importantly, none of these documents even contains terms such as “abortion,” “reproductive rights,” “sexual rights,” or related terms.

Consequently, the Commission’s reliance on the indicated documents as the basis for actions aimed at increasing access to abortion should be regarded as an expansive interpretation of those documents, exceeding the scope of states’ obligations as agreed by the international community.

Conclusions

The European Citizens’ Initiative “My Voice, My Choice: For Safe and Accessible Abortion” constitutes an important test case probing the limits of the participatory democracy mechanism in the European Union and the actual scope of EU institutions’ competencies in the area of public health and bioethics. Despite having gathered over 1.1 million verified statements of support, the initiative’s proposals—aimed at establishing an EU financial mechanism supporting cross-border access to abortion (funding travel, accommodation, and the procedure itself)—encounter fundamental competence limitations arising from the EU Treaties. The European Commission, pursuant to Article 11(4) TEU and Regulation (EU) 2019/788, is not bound by the content of an ECI and is under no obligation to submit a proposal for a legal act. Therefore, it should refuse to take action due to a lack of competence.

Article 168(7) TFEU is of key importance; it expressis verbis reserves to the Member States the responsibility for the definition of health policy, the organization and financing of health care systems, and the provision of medical services. The Union’s competences in this area are exclusively of a supporting, coordinating, and complementary nature—they do not allow any actions (including financial ones) that would, de facto, affect the substantive scope of health care services or undermine national value choices. An attempt to use existing instruments (EU4Health, ESF+) to achieve the initiative’s objectives will have a regulatory effect contrary to the principle of conferral of competences (Article 5(1)–(2) TEU).

The case law of the Court of Justice of the European Union, in particular the judgment in the Grogan case (C-159/90), confirms that although abortion may be classified as a “service” within the meaning of EU law, the Member States retain the full right to restrict it on the grounds of fundamental constitutional and moral values. The Court deliberately refrained from unifying ethical standards, leaving moral judgment to the states.

The Commission’s references to international documents (the 1994 ICPD Programme of Action and the 1995 Beijing Declaration) are selective and expansive in scope. Both documents clearly state that abortion should not be promoted as a method of family planning, and that any decisions in this regard remain at the national level. No binding international treaty (including CEDAW or the CRPD) establishes a right to abortion or obligates states to legalize or fund it.

The European Commission, by allowing the funding of abortion services with EU funds, has acted in violation of treaty provisions.

Respect for the clear division of competences between the Union and the Member States is a prerequisite for maintaining the EU’s constitutional balance, legal certainty, and citizens’ trust in the Union’s institutions. It should be remembered that the mechanism of participatory democracy, though valuable, does not authorize bypassing the treaty-based limits of integration. Only strict adherence to the principle of conferral guarantees the coherence and legitimacy of the European Union’s legal order in the face of profound axiological differences among the Member States.

Julia Książek – analyst of the Ordo Iuris Center for International Law

---

[1] Regulation (EU) 2019/788 of the European Parliament and of the Council of 17 April 2019 on the European Citizens’ Initiative, OJ L 130 of 17.05.2019, p. 55; https://eur-lex.europa.eu/legal-content/en/ALL/?uri=CELEX:32019R0788, accessed: April 7, 2026; see also Article 11(4) of the Treaty on European Union, Official Journal of the European Union C 202 of June 7, 2016, https://eur-lex.europa.eu/EN/legal-content/summary/treaty-on-european-union.html.

[2] Ibid., Article 6(1)(b) of Regulation (EU) 2019/788.

[3] Ibid., Article 5(1)–(3) of Regulation (EU) 2019/788.

[4] Ibid., Article 6(3)(c) of Regulation (EU) 2019/788.

[5] Ibid., Article 6(3), points (d)–(e) of Regulation (EU) 2019/788.

[6] Ibid., Article 8(1) and Article 9(1) of Regulation (EU) 2019/788.

[7] Ibid., Article 12 of Regulation (EU) 2019/788.

[8] Ibid., Article 14 of Regulation (EU) 2019/788.

[9] Ibid., Article 15 of Regulation (EU) 2019/788.

[10] Ibid., Article 15(2)–(3) of Regulation (EU) 2019/788.

[11] European Commission, Communication from the Commission on the European Citizens’ Initiative (ECI) “My Voice, My Choice: for safe and accessible abortion”, (C/2026/1383), https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52026XC01383, accessed: April 7, 2026

[12] “My Voice, My Choice”, (n.d.). Our demands. https://www.myvoice-mychoice.org/our-demands, accessed: April 07, 2026)

[13] European Parliament, European Parliamentary Research Service (EPRS). (2025, December). European Citizens’ Initiative “My Voice, My Choice: For safe and accessible abortion” (PE 779.248). https://www.europarl.europa.eu/RegData/etudes/ATAG/2025/779248/EPRS_ATA(2025)779248_EN.pdf, accessed: April 07, 2026)

[14] European Citizens’ Initiative, “Details of initiative 2024/000004,” https://citizens-initiative.europa.eu/initiatives/details/2024/000004_en, (accessed: April 10, 2026).

[15] Ibidem, Legal Addendum.”Legal basis.”

[16] European Commission Commission Implementing Decision (EU) 2024/1158 of 10 April 2024 on the request for registration of a European citizens’ initiative entitled “My Voice, My Choice” (32024D1158). EUR-Lex. https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32024D1158, accessed: April 07, 2026)

[17] European Commission, Communication from the Commission on the European Citizens’ Initiative (ECI) “My Voice, My Choice: for safe and accessible abortion,” (C/2026/1383), point of the Communication : 2.2.  EU legal framework and policy context, Legal framework, https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52026XC01383, accessed: April 7, 2026

[18] T. Hervey, J. McHale, Health law and the European Union, Cambridge University Press 2004, pp. 74–75.

[19] R. Geiger, D.-E. Khan, M. Kotzur (eds.), TEU and TFEU. Commentary, Munich 2015, commentary on Article 168 TFEU, nb. III-IV, pp. 680-681.

[20] Ibidem, p. 677.

[21] For more, see: T. Herbey, J. McHale, Health law… , pp. 150 et seq.

[22] Judgment of the Court of Justice of 4 October 1991 in Case C-159/90 Society for the Protection of Unborn Children Ireland Ltd v Grogan [1991] ECR I-4685, https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex:61990CJ0159, accessed: April 7, 2026

[23] S. O’Leary, S. Iglesias Sánchez, in: P. Craig, G. de Búrca (eds.), The Evolution of EU Law, Oxford 2021, pp. 534–535.

[24] Ibid., p. 534.

[25] T. Hervey, J. McHale Health law…, p. 153.

[26] European Commission, Communication from the Commission on the European Citizens’ Initiative (ECI) ‘My Voice, My Choice: for safe and accessible abortion’, (C/2026/1383), point of the Communication : 2.2.  EU legal framework and political context, Legal framework, https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52026XC01383, accessed: April 7, 2026

[27] Regulation (EU) 2021/1057 of the European Parliament and of the Council of 24 June 2021 establishing the European Social Fund Plus (ESF+), OJ L 231 of 30.06.2021, https://eur-lex.europa.eu/legal-content/PL/ALL/?uri=CELEX%3A32021R1057; Regulation (EU) 2021/522 of the European Parliament and of the Council of 24 March 2021 establishing a program for the Union’s action in the field of health (EU4Health), OJ L 107 of 26.03.2021, https://eur-lex.europa.eu/legal-content/PL/ALL/?uri=CELEX:32021R0522.

[28] P. Craig “Competence and Member State Autonomy: Causality, Consequence and Legitimacy,” Yearbook of European Law 2011, Vol. 30 (1), p. 9-14.

[29] A. de Ruijter, EU Health Law & Policy: The Expansion of EU Power in Public Health and Health Care, Oxford University Press, 2016, pp. 9–10.

[30] European Commission, Communication from the Commission on the European Citizens’ Initiative (ECI) “My Voice, My Choice: for safe and accessible abortion,” (C/2026/1383), point of the Communication : 2.  CONTEXT, 2.1.  International context, https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A52026XC01383, accessed: April 7, 2026

[31] United Nations Programme of Action of the International Conference on Population and Development (ICPD), Cairo, 5–13 September 1994, A/CONF.171/13. https://www.unfpa.org/sites/default/files/event-pdf/PoA_en.pdf; United Nations Beijing Declaration and Platform for Action, Fourth World Conference on Women, Beijing, 4–15 September 1995, A/CONF.177/20. https://www.un.org/womenwatch/daw/beijing/pdf/BDPfA%20E.pdf.

[32] United Nations, Programme of Action of the International Conference on Population and Development, Cairo 1994, para. 8.25: “In no case should abortion be promoted as a method of family planning […]”;
“Any measures or changes related to abortion within the health system can only be determined at the national or local level according to the national legislative process”, https://www.unfpa.org/sites/default/files/event-pdf/PoA_en.pdf.

[33] United Nations, Beijing Declaration and Platform for Action, 1995, para. 106(k): highlighting the need to reduce the number of abortions through social and health policies and support for women, https://www.un.org/womenwatch/daw/beijing/pdf/BDPfA%20E.pdf.

[34] Ibid.

[35] United Nations Convention on the Elimination of All Forms of Discrimination against Women (CEDAW), adopted by the United Nations General Assembly by Resolution 34/180 of December 18, 1979, Article 12. Dz.U. z 1982 r. Nr 4, poz. 24 https://www.un.org/womenwatch/daw/cedaw/cedaw.htm; United Nations Convention on the Rights of Persons with Disabilities (CRPD), adopted by United Nations General Assembly resolution 61/106 of December 13, 2006, Article 25. Dz.U. z 2012 r. poz. 1169. https://www.un.org/disabilities/documents/convention/convoptprot-e.pdf.