The European Union law only requires its members to implement anti-discrimination laws, but it doesn’t impose legal guarantees for same-sex couples.
Out of the 28 members, gay couples are not entitled to adoption in 14 states, most of which are located on the eastern side of the European map, except for Portugal, Ireland and Italy.
Only in two of these countries, Czech Republic and Ireland, proposals that would legalize step-child adoption are pending, meaning that one partner can adopt the biological child of the other. This partial adoption right already exists in Germany, Finland, Slovenia and Estonia.
Among the states which have removed inequality on this ground, fully equalizing gay and hetero couples, Netherlands judicial system was the first to implement the law in 2001, followed by Sweden and Spain, whereas UK and France have enforced it in the last two years.
Matching the adoption law with the marriage one – which may allow normal marriages, civil unions or none – can help identifying the most progressive jurisdictions on this ground within the European Union.
By granting both adoption and marriage, eight states have completely removed any difference in legal treatment linked to sexual orientation: United Kingdom, France, Spain, Sweden, Belgium, Netherlands, Denmark and Luxembourg.
On the other hand, regardless the pending reforms, strong discrimination is still effective in nine countries, where same sex-couples are not granted any sort of legal protection: Italy, Greece, Poland, Romania, Slovakia, Bulgaria, Latvia, Lithuania and Cyprus.