In a short time, various announcements have been made in relation with developments concerning international adoption. These developments are related to problems which have arisen regarding the recognition of adoptions constituted in foreign countries. The problem derives from the diversity of situations in which adoption takes place abroad and from the problems originated from the regulations, Art. 9 of the Civil Code.

The problem is that an objective and general revision to improve the legislative framework has not been carried out. Instead, specific solutions are pro?vided for specific subjects, which is a bad answer from the point of view of the legislative technique and also from a practical point of view.

The real difficulty is found in bad and insufficient regulation of the acknowledgement of the adoptions constituted abroad. Frequently modified in recent years, it has never been the object of enough attention and includes too many problems in the narrow framework of Art. 9, Paragraph 5 of the Civil Code. Regarding this aspect, we have to remember that in the process of elaborating the Organic Law of the Minor, there was a proposal of the Catalan Parliamentary Group which substituted the existing rule on acknowledgement for one that stated that «except for what has been provided for in the international agreements, the adoption constituted in a foreign country will produce the foreseen effects in Spain if it has been constituted by the state authorities of the citizenship or of the habitual residence of the adopting and of the adopted person and the required consents have been obtained. In addition, were the adopting person or one of the adopting persons be a Spaniard, the requirements of capacity and consent will have to be met, requirements equivalent to those foreseen in Spanish Law and if thisadoption is not openly against public order, taking into account the best interest of the child». In this way, a global regulation would be provided which would be more suitable in the majority of cases, instead of providing specific answers case by case. In juridical matters, unlike Impressionist painting, making little brush?strokes of various colours does not give good results.