Though it is widely accepted that United Kingdom (UK) surrogacy laws are in need of reform, how they should be reformed remains a matter of considerable disagreement. This article explores a new regulatory suggestion: labour law. Building on the extensive sociological and anthropological literature that has conceptualized contract pregnancy as a form of work, it considers whether and how this might translate into a new regulatory framework, drawing on the Sex Work Is Work movement for inspiration. Though recognizing that this would require substantial changes to some of the present features of UK surrogacy law, it shows that there may be significant potential in this pre-existing set of protections, improving the position of surrogates without dramatically changing the culture of the practice.