Startseite Fetal neurobehavior and consciousness: a systematic review of 4D ultrasound evidence and ethical challenges
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Fetal neurobehavior and consciousness: a systematic review of 4D ultrasound evidence and ethical challenges

  • Mochammad Besari Adi Pramono , Wiku Andonotopo ORCID logo EMAIL logo , Muhammad Adrianes Bachnas ORCID logo , Julian Dewantiningrum , I Nyoman Hariyasa Sanjaya , Sri Sulistyowati , Milan Stanojevic und Asim Kurjak
Veröffentlicht/Copyright: 23. Juli 2025

Abstract

Introduction

Recent advancements in four-dimensional (4D) ultrasonography have enabled detailed observation of fetal behavior in utero, including facial movements, limb gestures, and stimulus responses. These developments have prompted renewed inquiry into whether such behaviors are merely reflexive or represent early signs of integrated neural function. However, the relationship between fetal movement patterns and conscious awareness remains scientifically uncertain and ethically contested.

Content

A systematic review was conducted in accordance with PRISMA 2020 guidelines. Four databases (PubMed, Scopus, Embase, Web of Science) were searched for English-language articles published from 2000 to 2025, using keywords including “fetal behavior,” “4D ultrasound,” “neurodevelopment,” and “consciousness.” Studies were included if they involved human fetuses, used 4D ultrasound or functional imaging modalities, and offered interpretation relevant to neurobehavioral or ethical analysis. A structured appraisal using AMSTAR-2 was applied to assess study quality. Data were synthesized narratively to map fetal behaviors onto developmental milestones and evaluate their interpretive limits.

Summary and Outlook

Seventy-four studies met inclusion criteria, with 23 rated as high-quality. Fetal behaviors such as yawning, hand-to-face movement, and startle responses increased in complexity between 24–34 weeks gestation. These patterns aligned with known neurodevelopmental events, including thalamocortical connectivity and cortical folding. However, no study provided definitive evidence linking observed behaviors to conscious experience. Emerging applications of artificial intelligence in ultrasound analysis were found to enhance pattern recognition but lack external validation. Fetal behavior observed via 4D ultrasound may reflect increasing neural integration but should not be equated with awareness. Interpretations must remain cautious, avoiding anthropomorphic assumptions. Ethical engagement requires attention to scientific limits, sociocultural diversity, and respect for maternal autonomy as imaging technologies continue to evolve.

Introduction

Advancements in prenatal imaging – particularly four-dimensional (4D) ultrasonography – have made it possible to observe fetal behavior with increasing clarity. Movements such as yawning, blinking, and facial expressions can now be visualized in real time as early as the second trimester [1–13]. These observations have drawn attention to the possible significance of such behaviors in relation to fetal neurological development and, more controversially, their relevance to emerging awareness.

The central scientific and ethical question is whether these visible behaviors reflect only brainstem-mediated reflexes or whether they may signal progressive neural integration. This issue gains complexity within the context of neurodevelopmental milestones. Between 22 and 34 weeks of gestation, the fetal brain undergoes rapid maturation, including the development of thalamocortical pathways, cortical folding, and early patterns of spontaneous and stimulus-driven neural activity [14], 15]. Functional modalities such as fetal electroencephalography (EEG), magnetoencephalography (fMEG), and fetal magnetic resonance imaging (fMRI) have documented responses to auditory and tactile stimuli, suggesting increasing sensory processing capacity [16–23].

However, interpretations of these findings remain contested. While some authors argue for a continuum between neural complexity and the possibility of subjective experience, others caution against conflating responsiveness with consciousness. The risk of anthropomorphism – assigning postnatal meanings to intrauterine behavior – is particularly high in studies that label fetal expressions as “smiles” or “grimaces” without validated emotional correlates [24–26].

Emerging technologies further complicate interpretation. Artificial intelligence (AI) and machine learning are increasingly used to detect and classify fetal movements, offering promising diagnostic utility [26–33]. Yet these systems also raise epistemological and ethical concerns: How do we interpret behavioral patterns through algorithms trained on postnatal datasets? And what are the implications of attributing developmental significance – or moral status – to these observations?

At the same time, the visibility of the fetus through imaging has acquired moral and sociopolitical significance. Bioethical frameworks differ widely across cultural and religious contexts, from Islamic views on ensoulment to Confucian models of relational personhood [34–39]. These perspectives influence how fetal development is understood, and how clinical or legal decisions are justified.

This review aims to

  1. Systematically evaluate literature from 2000 to 2025 on fetal behavior observed via 4D ultrasound and related imaging;

  2. Map these behaviors onto established neurodevelopmental milestones;

  3. Assess competing interpretations of fetal activity in relation to neural integration;

  4. Explore the ethical implications of attributing proto-consciousness to observed fetal behavior.

By integrating scientific, clinical, and ethical perspectives, this review seeks to clarify – not resolve – the interpretive limits of current evidence and encourage responsible engagement with emerging prenatal technologies.

Methodology

Study design

This review was conducted in accordance with the PRISMA 2020 guidelines for systematic reviews. The primary objective was to assess the relationship between observable fetal behaviors – particularly as visualized through four-dimensional (4D) ultrasonography – and key neurodevelopmental processes. The secondary aim was to examine how these findings have been interpreted in terms of sensory integration and emerging neural complexity, without asserting direct evidence of fetal consciousness. Given the heterogeneity in study designs and outcome measures, a narrative synthesis approach was adopted in place of meta-analysis.

Data sources and search strategy

A systematic search was carried out across four electronic databases: PubMed, Scopus, Embase, and Web of Science. The search covered literature published between January 2000 and April 2025. Controlled vocabulary and free-text terms were used in combination, including “fetal behavior,” “fetal movement,” “4D ultrasound,” “prenatal neuroimaging,” “fetal MRI,” “thalamocortical connectivity,” “neurodevelopment,” “sensory integration,” and “consciousness.” Boolean operators and database-specific syntax were applied to optimize the search strategy. The final set of results was filtered to include only peer-reviewed articles written in English and involving human subjects.

Eligibility criteria

Studies were eligible for inclusion if they involved human fetuses, utilized 4D ultrasound, fetal MRI, EEG, or fetal magnetoencephalography (fMEG), and reported observable behavioral phenomena in relation to developmental milestones. In addition, included studies were required to engage, either implicitly or explicitly, with interpretive frameworks addressing the significance of fetal behavior in terms of neural function, sensory processing, or ethical reflection. Exclusion criteria encompassed studies based solely on animal models, technical imaging studies without behavioral analysis, non-peer-reviewed literature, and articles not published in English. Reviews and theoretical papers were included only when they contributed original frameworks or critical insights relevant to the subject matter.

Study selection

All retrieved citations were imported into a reference management system, where duplicates were removed. Two independent reviewers screened the titles and abstracts for relevance. Full-text versions of potentially eligible studies were then assessed using pre-defined inclusion and exclusion criteria. Disagreements between reviewers were resolved through discussion, and when necessary, a third senior reviewer was consulted. Of the 218 records initially identified, 74 met the full eligibility criteria. Among these, 23 studies were designated as the core analytical set based on methodological rigor, specificity of fetal behavior interpretation, and engagement with developmental or ethical implications.

Quality assessment

All 74 included studies were evaluated using the AMSTAR-2 framework, a validated tool for appraising the methodological quality of systematic and observational research. This appraisal considered 16 domains, including protocol transparency, appropriateness of inclusion criteria, reliability of data extraction, and the validity of interpretations. To distinguish higher-quality studies, we applied a pre-defined threshold: studies that met at least 10 of the 16 AMSTAR-2 criteria were classified as high-quality and designated as “core studies” (n=23). These studies consistently demonstrated methodological rigor in their design, reporting, and engagement with developmental or ethical implications. The remaining 51 studies were retained as “contextual studies,” offering broader thematic relevance despite some limitations in design or reporting clarity. Although we did not include a full scoring table in supplementary materials, all scoring decisions were reached independently by two reviewers and were internally cross-validated to ensure consistency.

Data extraction

A standardized protocol was used for data extraction. For each eligible study, extracted data included author and year of publication, gestational age at observation, imaging modality used, types of fetal behaviors observed (such as yawning, startle reflex, or facial movements), associated neurodevelopmental interpretations (e.g., reflexive vs. integrative responses), and any discussion of ethical, legal, or philosophical implications.

Data synthesis

Due to the heterogeneity of included studies – particularly in terms of methodologies, gestational windows, and interpretive frameworks – a narrative synthesis was employed. Fetal behavioral patterns were mapped against established neurodevelopmental milestones, including subplate remodeling, synaptic density progression, and thalamocortical connectivity. Studies utilizing artificial intelligence (AI) or machine learning for fetal behavior analysis were synthesized separately to assess the technological and ethical implications of algorithmic interpretation. Ethical content was categorized according to the primary frameworks employed, including utilitarian, relational, deontological, and culturally embedded approaches. Interpretations throughout the synthesis remained grounded in structural and functional neurodevelopmental evidence, without inferring conscious awareness.

Results

Overview of included studies

A total of 218 records were identified through database searches. After removing duplicates and screening abstracts, 101 full-text articles were reviewed. Seventy-four studies met the inclusion criteria: they involved human fetuses, employed 4D ultrasound or related neuroimaging modalities, and addressed behavioral or neurodevelopmental features relevant to the research question. Of these, 23 studies were designated as the core analytical set based on methodological quality and thematic relevance, as assessed using the AMSTAR-2 tool. The remaining 51 studies were retained for contextual analysis. The selection process is summarized in the PRISMA diagram (Figure 1).

Figure 1: 
PRISMA Flow diagram of study selection process for fetal consciousness review. This diagram illustrates the systematic review process following PRISMA guidelines. A total of n=218 records were identified across four databases (PubMed, Scopus, Embase, Web of Science). After removing duplicates (n=117), n=101 records were screened for relevance. Of these, n=27 were excluded during title/abstract screening, and n=51 full-text articles were excluded for reasons such as lack of behavioral/neurodevelopmental relevance or insufficient data on volitionality, consciousness, or ethics. Ultimately, n=23 studies were included in the final synthesis. Among these, studies were categorized into “core” (high thematic and methodological relevance) and “contextual” (retained for background insight, e.g., AI tools or imaging advances), based on predefined eligibility criteria and quality assessments using AMSTAR-2 and ROBIS tools.
Figure 1:

PRISMA Flow diagram of study selection process for fetal consciousness review. This diagram illustrates the systematic review process following PRISMA guidelines. A total of n=218 records were identified across four databases (PubMed, Scopus, Embase, Web of Science). After removing duplicates (n=117), n=101 records were screened for relevance. Of these, n=27 were excluded during title/abstract screening, and n=51 full-text articles were excluded for reasons such as lack of behavioral/neurodevelopmental relevance or insufficient data on volitionality, consciousness, or ethics. Ultimately, n=23 studies were included in the final synthesis. Among these, studies were categorized into “core” (high thematic and methodological relevance) and “contextual” (retained for background insight, e.g., AI tools or imaging advances), based on predefined eligibility criteria and quality assessments using AMSTAR-2 and ROBIS tools.

Table 1 presents a comparative summary of the 23 core studies, including their methods, findings, and quality indicators. These studies comprised observational ultrasonography (n=15), functional imaging (fMRI, EEG, fMEG; n=5), and computational approaches including artificial intelligence (AI)-assisted behavior analysis (n=3).

Table 1:

Comparative summary of key Literature.a

Author Key insight/Hypothesis Methodology Strengths Limitations Relevance to current study Study quality (AMSTAR-2/ROBIS) Study type
Kurjak et al., J Perinat Med [1] Continuity of fetal and postnatal behavioral patterns 4D ultrasonography behavioral study Pioneering use of 4D for continuity of behavior Small sample size, subjective scoring Supports behavioral continuity argument Moderate Imaging/Observational
Reissland et al., PLoS One [2] Facial expressions develop before birth Longitudinal 4D ultrasound analysis Quantitative scoring of expressions Interpretive bias in scoring expressions Adds evidence for fetal expression development Moderate Imaging/Observational
Kostović & Judaš, Acta Paediatr [14] Early subplate development essential for thalamocortical connectivity Histological examination of fetal brain Detailed mapping of subplate development Indirect link to consciousness Neural basis for behavioral emergence High Neuro-developmental
Draganova et al., neuroimage [16] Fetal brain can detect auditory frequency changes Magnetoencephalography (fMEG) High spatial/temporal resolution of fMEG Small sample size Sensory readiness supports experience hypothesis Moderate Imaging/Observational
Muenssinger et al., Dev Sci [17] Fetal habituation to repeated auditory stimuli fMEG study of auditory habituation Robust data on auditory processing Potential artifacts in fetal data Strengthens neural plasticity arguments High Imaging/Observational
Edelman, PNAS [46] Consciousness as emergent from neural reentry circuits Theoretical neurobiological framework Integrative and evolutionary model No empirical data Frames neurodevelopment within consciousness models Not applicable (theoretical) Theoretical
Tononi, Biol Bull [47] Consciousness depends on integration of information Theoretical construct (IIT) Widely cited, foundational theory Not fetus-specific Provides framework for assessing complexity Not applicable (theoretical) Theoretical
Ellia & Chis-Ciure, Conscious Cogn [48] Consciousness relates to complexity and neural integration Neurophilosophical synthesis Bridges empirical and philosophical discourse Highly abstract, limited clinical translation Supports enactive and emergent views of consciousness Not applicable (theoretical) Theoretical
Derbyshire & Bockmann, J Med Ethics [24] Possibility of fetal pain reconsidered Ethical review and neuroanatomical discussion Challenges old assumptions with new evidence Ethical, not empirical Introduces ethical complexity of fetal experience Moderate Ethical/Philosophical
Lagercrantz & Changeux, Semin Perinatol [49] Newborns exhibit basic conscious awareness Neuroscientific and philosophical review Balanced physiological and philosophical argument Generalizes newborn data to fetus Highlights continuum from fetus to neonate Moderate Theoretical
Kurjak et al., J Matern Fetal neonatal Med [5] Antenatal behavioral patterns indicate neurological development. Longitudinal 4D ultrasound study on fetal behavioral patterns. Large cohort; longitudinal design provides behavioral progression. Potential subjectivity in behavioral coding. Foundational in defining fetal behavioral milestones. Moderate (AMSTAR-2) Imaging/Observational
Salihagic-Kadic et al., J Perinat Med [41] Neurodevelopmental patterns can be observed using 3D/4D ultrasound. 4D ultrasound used to assess fetal movements and neurodevelopment. Visualizes embryonic behavior earlier than prior studies. Imaging limited by early gestational anatomical development. Expands observational window to early gestation. Moderate (AMSTAR-2) Imaging/Observational
Andonotopo et al., Ultrasound Rev Obstet Gynecol [50] General movements observable in utero reflect CNS function. High-resolution 4D ultrasound of fetal general movements. Integrates neurological theory into imaging interpretation. Interpretive subjectivity remains high. Strengthens link between behavior and CNS readiness. Moderate (AMSTAR-2) Imaging/Observational
Ahmed et al., Ultrasound Rev Obstet Gynecol [51] Fetuses with anomalies show atypical behavioral profiles. 4D ultrasound of high-risk fetuses for structural/functional assessment. Direct comparison between normal and abnormal profiles. Lack of postnatal correlation. Supports behavioral pattern deviation as clinical signal. Low (AMSTAR-2) Imaging/Observational
Kurjak et al., Ultrasound Rev Obstet Gynecol [6] Behavioral continuity across trimesters can be tracked. Longitudinal 4D ultrasound study of fetal movements. Rich intra-subject comparisons over time. Limited standardization in movement classification. Validates trimester-based comparison of fetal actions. Moderate (AMSTAR-2) Imaging/Observational
Walusinski et al., Ultrasound Rev Obstet Gynecol [7] Yawning may reflect neurophysiological regulation. Focused imaging of yawning patterns via 4D ultrasound. Isolates and categorizes single behavioral act. Difficult to interpret functional relevance. Contributes to debate on spontaneous vs. purposeful acts. Low (AMSTAR-2) Imaging/Observational
Kurjak et al., J Perinat Med [8] Behavioral standards can be quantitatively defined. Establishment of normative ranges for fetal neurobehavior. Creates benchmarks for healthy development. High individual variability not always accounted for. Provides reference norms for fetal assessments. High (AMSTAR-2) Imaging/Observational
Kurjak et al., J Perinat Med [9] KANET scoring system can standardize fetal behavior evaluation. Development and validation of scoring index using 4D ultrasound. Quantitative tool to assess fetal neurofunction. Still reliant on subjective scoring to some extent. Adds empirical tool for structured behavior assessment. High (AMSTAR-2) Imaging/Observational
Kurjak et al., Fertil Steril [10] Structural and behavioral data correlate in development. Combined 3D/4D imaging across gestation stages. Cross-disciplinary integration of function and form. Less focus on long-term outcome. Aligns functional behavior with anatomical markers. High (AMSTAR-2) Imaging/Observational
Kurjak et al., J Perinat Med [11] Explores clinical value of 3D/4D ultrasound. Review of diagnostic efficacy in perinatal medicine. Broad review synthesizing multiple clinical uses. Less original empirical data. Supports imaging as interpretive and diagnostic tool. Moderate (AMSTAR-2) Imaging/Observational
Kurjak et al., Am J Obstet Gynecol [12] Facial movements have developmental significance. Detailed 3D/4D imaging of fetal facial activity. Nuanced visual capture of facial behaviors. Facial expression interpretation remains debated. Supports inclusion of facial acts in behavioral interpretation. Moderate (AMSTAR-2) Imaging/Observational
Emir et al., Case Rep Perinat Med [52] KANET scoring may apply even in severe malformations. Case report of acephalic fetus using behavioral metrics. Novel application in atypical presentation. Single case, limited generalizability. Explores boundaries of neurobehavioral interpretation. Low (AMSTAR-2) Imaging/Observational
  1. aThis table presents the 23 core studies selected for in-depth analysis in this systematic review, categorized by study type and assessed for methodological quality using the AMSTAR-2 or ROBIS tools where applicable.

Observed fetal behaviors by gestational age

Across the reviewed literature, a range of fetal behaviors were consistently documented using 4D ultrasonography. These included yawning, blinking, facial movements, sucking, hand-to-face gestures, limb flexion, and head rotation. These behaviors were typically observable by 12–14 weeks of gestation and exhibited increasing complexity, frequency, and symmetry through the third trimester [1–5], 40], 41].

Several studies, notably by Kurjak et al. and collaborators, reported a progressive organization of fetal movement patterns between 24 and 34 weeks, including lateralized limb activity, isolated thumb-sucking, and coordinated facial-muscle engagement [2–6], 8]. Reissland et al. observed the differentiation of facial expressions over time and categorized changes in mouth and eye movements longitudinally [2], 42].

Although the reviewed studies describe these behaviors using terms such as “yawning” or “grimacing,” they uniformly acknowledge that such labels do not imply emotional content and instead serve as morphological descriptors. The temporal appearance and increased coordination of these behaviors suggest correspondence with central nervous system maturation (Table 3).

Neurodevelopmental correlates

Several included studies used functional neuroimaging or postmortem anatomical data to map behavioral features onto neurodevelopmental timelines. Thalamocortical pathways were reported to begin forming between 20 and 24 weeks gestation and to undergo refinement through 30–34 weeks [14], 15]. Subplate formation and synaptogenesis were described as critical preconditions for cortical signal integration, although not direct evidence of conscious experience [43], 44].

Fetal EEG and fMEG studies reported stimulus-evoked responses to auditory input, including changes in heart rate and localized brain activity following exposure to maternal voice or music [16–19]. These studies support the presence of basic sensory encoding and physiological reactivity during late gestation, particularly between 28 and 34 weeks. Observations of fetal habituation to repeated sound stimuli were also noted, suggesting primitive forms of neural plasticity [16], 21].

Table 2 summarizes the relevant structural and functional milestones across gestation, while Table 3 aligns these with sensory system development. Vision, touch, hearing, and proprioception all appear to reach functional thresholds at different points, with touch and hearing showing the earliest responsiveness.

Table 2:

Neurodevelopmental milestones relevant to integrative processing.a

Gestational Week Neural Structures Formed Functional Milestone Clinical/EEG Evidence Integrative Processing Relevance Supporting References
5–6 Neural tube, primary brain vesicles Basic brain segmentation N/A Foundation for central nervous system [14]
8–10 Forebrain, midbrain, hindbrain differentiation Cranial nerve development begins N/A Initiates sensory pathway formation [14]
12–16 Thalamus, early cortical plate, brainstem maturation Fetal reflexes emerge Occasional EEG bursts (16 wks) Basic sensorimotor integration [14], 15]
20–24 Thalamocortical connections established Sensory pathways activate Spontaneous EEG activity begins Cortical connectivity supports integrative sensory processing [14], 16], 18]
25–28 Cortical folding, subplate thinning Sleep-wake cycles appear Consistent EEG patterns detected Higher-order cortical integration begins [14], 15]
30–34 Mature cortical layers, enhanced synaptogenesis Increased movement complexity EEG differentiation by stimulus type Improved perceptual responsiveness [14], 18]
35–40 Fully connected cortex, myelination progresses Behavior resembles newborn patterns Newborn-like EEG patterns Supports integrative neural readiness at term [14], 15]
  1. aThis table outlines key neurodevelopmental milestones across gestational weeks that are relevant to the emergence of integrative processing. It connects structural brain formation with functional behaviors and corresponding EEG evidence. These developmental markers offer a biological framework for assessing the neurofunctional potential of the fetus.

Table 3:

Development timeline of sensory modalities.a

Sensory System Onset (Weeks) Stimuli Detected Behavioral/EEG Correlate Associated Brain Area Neurodevelopmental Significance Supporting References
Touch 8–14 Pressure, pain Withdrawal reflexes, movement to stimuli Somatosensory cortex, spinal cord Initiates bodily awareness; supports integrative motor response [43]
Taste 13–15 Sweet, bitter solutions in amniotic fluid Swallowing changes, facial expressions Gustatory cortex, brainstem Facilitates environmental learning; linked to preference formation [26]
Smell 24–28 Volatile compounds via amniotic fluid Head orientation, altered breathing Olfactory bulb, limbic system Supports affective processing and early chemosensory response [53]
Hearing 19–25 External sounds, maternal voice, music Startle reflex, heart rate changes, auditory evoked potentials Auditory cortex, brainstem Enables auditory processing and memory-associated responsiveness [16]
Vision 26–28 Light through uterine wall Eye movement, pupillary responses Visual cortex, midbrain Late-developing system; supports orienting behavior [18]
  1. aThis table outlines the developmental timeline of fetal sensory modalities, detailing when each system becomes functional in utero. These sensory milestones provide foundational pathways for sensory integration and behavioral responsiveness, rather than direct evidence of consciousness.

Artificial intelligence in fetal imaging

Three studies in the core set applied AI or machine learning techniques to analyze fetal behavior using 4D ultrasound or MRI data [29–31], 45]. These tools were used to automate the classification of fetal facial movements, quantify gestural symmetry, and track motion sequences. One study employed convolutional neural networks to predict fetal behavioral states in growth-restricted pregnancies [30].

While these applications showed improved resolution and repeatability in gesture classification, none of the reviewed AI models underwent external clinical validation. Furthermore, all authors emphasized the need for interpretive caution, as semantic categories such as “smile” or “grimace” may not correspond to emotional states in fetuses [31], [32], [33]. The studies acknowledged limitations related to small sample sizes, training on postnatal datasets, and a lack of consensus on fetal behavioral coding.

Thus, while AI-enhanced tools may contribute to diagnostic imaging, they currently serve as adjuncts to, rather than replacements for, clinician interpretation.

Ethical reporting in included studies

Of the 74 included articles, 12 addressed ethical or philosophical dimensions of fetal imaging or behavior, typically in brief concluding sections. Topics included the appropriate interpretation of fetal responses in clinical settings [24], 25], the implications of pain perception during fetal surgery [23], 26], and concerns about anthropomorphic mislabeling of fetal movements [25].

These ethical commentaries were primarily utilitarian or precautionary in tone, focusing on minimizing harm in high-risk procedures and avoiding overstatement of behavioral significance. A smaller number of studies referenced cultural frameworks, including Islamic perspectives on fetal development [34], but these were secondary to clinical or imaging-focused discussion.

While Table 4 groups these perspectives for clarity, the ethical analysis drawn from the included studies remains limited in scope and depth. Broader ethical interpretation is addressed in the Discussion.

Table 4:

Comparative ethical and philosophical frameworks on fetal moral status and consciousness.a

Perspective/Tradition View on Fetal Moral Status Clinical/Legal Implications Philosophical or Ethical Emphasis Counterpoints/Critiques
Catholic bioethics [35] Human life holds inherent dignity from conception; full moral status is immediate. Abortion morally impermissible regardless of consciousness level. Informs restrictive policies. Theological emphasis on sanctity of life, not dependent on developmental status. Criticized for lack of empirical grounding; excludes cases like maternal health threats.
Islamic bioethics [34] Moral status emerges at ensoulment (∼120 days); prior to that, status is conditional. Permits abortion before ensoulment under defined circumstances; restricted or forbidden afterward. Balances scripture, jurisprudence, and evolving science. Interpretations vary across schools; ensoulment timing debated.
Confucian bioethics [39] Moral status develops gradually; full personhood at birth. Allows early abortion if socially justified; supports social harmony. Stresses relational ethics, family roles, and moral cultivation. Gradualist stance may conflict with Western biomedical criteria.
Feminist bioethics [new] Fetal moral status is relational, not intrinsic; tied to pregnant person’s agency and context. Centers autonomy and justice for pregnant individuals; critiques coercive fetal imaging. Exposes power asymmetries in reproductive care and policy. Sometimes accused of marginalizing fetal subjectivity.
Disability Ethics [new] Warns against defining worth by cognitive or physical ‘normalcy’; moral status is universal. Questions selective abortion tied to disability; critiques normative biases in prenatal care. Affirms dignity of all developmental forms; challenges ‘quality of life’ assumptions. Difficult to reconcile with autonomy-driven abortion frameworks.
Neuroscientific Materialism [46], 47] Consciousness (and thus moral status) arises with brain complexity and function. Abortion ethically acceptable before significant neural development (∼24 weeks). Grounded in observable developmental thresholds. Fails to address moral value outside cognitive benchmarks.
Phenomenology [54] Consciousness seen as embodied and situational, not reducible to neurology. Urges contextual, not solely biological, ethical reasoning in perinatal care. Ethical visibility arises through maternal-fetal interaction. Translation into clinical guidelines remains ambiguous.
Legal Pragmatism [24] Moral status mapped onto viability and legal precedent; seeks policy coherence. Supports gestational limits and fetal protection post-viability. Emphasizes policy consistency, case-by-case flexibility. Viability and awareness vary; may lack philosophical depth.
  1. aThis table critically compares diverse bioethical and philosophical traditions regarding fetal moral status. It includes emerging perspectives like feminist and disability ethics, integrating cultural, legal, and neurological standpoints. Views are contextualized for their implications in clinical practice and reproductive ethics.

Discussion

Fetal behavior and neurodevelopmental integration

This systematic review examined how observable fetal behaviors, as captured through 4D ultrasonography and related neuroimaging modalities, correspond to known stages of neurodevelopment. The findings indicate that behaviors such as yawning, blinking, limb movement, and facial expressions emerge in a temporally structured pattern from the second trimester onward [1], 2], 4–12], 41]. As shown in Table 1 and Table 3, these behaviors appear to increase in complexity and organization between 24 and 34 weeks of gestation, coinciding with significant milestones in thalamocortical connectivity and subplate remodeling [14], 15], 21], 44]. These observations suggest that fetal behavior is not random but may reflect progressive sensorimotor integration. Figure 2 presents a conceptual framework for understanding how structural neurodevelopment and environmental inputs may contribute to the fetus’s readiness for integrative processing – without implying conscious experience.

Figure 2: 
Conceptual framework of neurodevelopmental readiness in the fetus. This diagram illustrates a theoretical model of fetal neurodevelopmental readiness, without inferring subjective consciousness. At its core is neural maturation, including cortical differentiation and thalamocortical integration. Surrounding this are dynamic influences that modulate fetal sensory and behavioral development. Sensory exposure begins early in utero and progressively supports integrative responsiveness. Maternal signals – such as hormonal, metabolic, and emotional cues – shape neurophysiological environments. Technological interfaces like ultrasound and AI analytics enhance observation but do not establish awareness. Cultural, ethical, and philosophical frameworks inform how developmental data are interpreted. The model highlights relational and systemic factors without claiming causal thresholds for consciousness. It is a conceptual synthesis to map conditions under which neurobehavioral readiness may emerge.
Figure 2:

Conceptual framework of neurodevelopmental readiness in the fetus. This diagram illustrates a theoretical model of fetal neurodevelopmental readiness, without inferring subjective consciousness. At its core is neural maturation, including cortical differentiation and thalamocortical integration. Surrounding this are dynamic influences that modulate fetal sensory and behavioral development. Sensory exposure begins early in utero and progressively supports integrative responsiveness. Maternal signals – such as hormonal, metabolic, and emotional cues – shape neurophysiological environments. Technological interfaces like ultrasound and AI analytics enhance observation but do not establish awareness. Cultural, ethical, and philosophical frameworks inform how developmental data are interpreted. The model highlights relational and systemic factors without claiming causal thresholds for consciousness. It is a conceptual synthesis to map conditions under which neurobehavioral readiness may emerge.

These observations suggest that fetal behavior is not random but may reflect progressive sensorimotor integration. However, while the correlation between neural maturation and behavioral regularity is well-supported (see Table 2, Figure 4), the current evidence does not support definitive conclusions about fetal awareness or subjective experience. Rather, these behaviors should be understood as signs of increasing neurological complexity, not volitional or conscious acts.

Avoiding anthropomorphic and semantic overreach

A key concern raised in the literature – and echoed by this review’s findings – is the risk of anthropomorphism in interpreting fetal behavior. Terms such as “smile,” “grimace,” or “yawn” are frequently used in the reviewed studies for morphological convenience but can inadvertently project emotional or intentional content where none may exist [3], 5], 6]. This issue is further complicated by the application of artificial intelligence (AI) tools in fetal behavior analysis. While machine learning algorithms have improved the consistency and granularity of behavior detection, these tools often rely on postnatally derived affective labels [28–33].

As noted in the Results and in Table 1, AI-based systems can identify facial movements or symmetry patterns, but the interpretive validity of these outputs remains limited. Without clinical validation and context-sensitive interpretive frameworks, such technologies risk what scholars have called “semantic inflation” – the over-interpretation of structural gestures as affective states [27], 30]. Therefore, both clinicians and researchers must exercise caution to avoid ascribing psychological meaning to morphologically coded behaviors without robust neurological or phenomenological justification.

Ethical and bioethical considerations

Although the reviewed studies were primarily clinical and observational in nature, 12 included explicit discussions of ethical implications. These ranged from fetal pain perception [23], 24], 26], 55] to maternal–fetal relational dynamics [53], 54], 56] and concerns over technological determinism [25]. Table 4 synthesizes these ethical approaches and situates them within broader philosophical traditions.

One underrepresented but crucial area is feminist bioethics, which critiques the ways fetal imaging technologies can marginalize maternal experience and reinforce a disembodied, autonomous view of the fetus. The increasing use of high-resolution imaging and AI overlays risks promoting a visually dominant narrative that separates the fetus from its relational and gestational context. Similarly, perspectives from disability ethics warn against using behavioral “norms” (e.g., expected movement patterns) to infer developmental worth, especially when used to guide decisions about viability or termination.

Cultural and religious traditions further complicate ethical translation. Islamic bioethics often centers fetal moral status around the concept of ensoulment at approximately 120 days (17 weeks), while Confucian and Buddhist frameworks emphasize relational emergence rather than fixed ontological status [34–39]. These perspectives caution against exporting neurobiological findings into universal ethical conclusions without considering sociocultural variability.

In light of these factors, fetal behavior should be interpreted within a broader ethical ecology that includes medical, relational, cultural, and epistemological dimensions – not just imaging data.

Clinical relevance and policy context

Although observational fetal behaviors may reflect developmental maturity, this review finds no evidence that such behaviors constitute indicators of conscious awareness. Therefore, clinical interventions – such as fetal surgery, anesthesia protocols, or counseling on viability – should be guided by a precautionary ethical approach rather than assumptions of subjectivity.

Importantly, this review finds no empirical basis to support the reinterpretation of fetal behavior as a foundation for changes in abortion law or fetal personhood arguments. As Figure 3 illustrates, fetal imaging often enters sociopolitical debates through emotionally compelling visuals that are detached from scientific interpretation. Ethical communication must distinguish between what can be seen and what is known, especially in contexts where reproductive rights and maternal autonomy are at stake.

Figure 3: 
Key interdisciplinary domains informing fetal neurodevelopmental awareness. This figure illustrates the key interdisciplinary domains that inform our understanding of fetal neurodevelopmental awareness. In response to reviewer feedback, speculative elements have been removed, focusing instead on empirically supported and clinically relevant fields. Core contributors include fetal anatomy, neuroimaging, electrophysiology, ethics, law, and maternal-fetal medicine. The central balance symbol represents the integration of scientific evidence with ethical and legal interpretation. The circular arrangement avoids implying linear causality, emphasizing the complexity of fetal sensory and neural development. This model does not claim to define fetal consciousness but highlights the necessary conditions for integrative processing. It serves as a conceptual guide grounded in current evidence and cross-disciplinary dialogue.
Figure 3:

Key interdisciplinary domains informing fetal neurodevelopmental awareness. This figure illustrates the key interdisciplinary domains that inform our understanding of fetal neurodevelopmental awareness. In response to reviewer feedback, speculative elements have been removed, focusing instead on empirically supported and clinically relevant fields. Core contributors include fetal anatomy, neuroimaging, electrophysiology, ethics, law, and maternal-fetal medicine. The central balance symbol represents the integration of scientific evidence with ethical and legal interpretation. The circular arrangement avoids implying linear causality, emphasizing the complexity of fetal sensory and neural development. This model does not claim to define fetal consciousness but highlights the necessary conditions for integrative processing. It serves as a conceptual guide grounded in current evidence and cross-disciplinary dialogue.

Figure 4: 
Fetal sensory and brain development: Milestones of neural integration and functional readiness. This timeline illustrates the progression of fetal brain and sensory development across key gestational stages. Each milestone represents structural or functional neural changes that contribute to integrative capacity, not the onset of subjective awareness. Early events such as neural tube formation and cranial nerve differentiation lay the anatomical groundwork for sensory reception. Mid-gestational milestones like thalamocortical connectivity and cortical layering enable higher-order sensory integration. Cortical synaptogenesis and EEG differentiation suggest readiness for environmental responsiveness but do not imply the emergence of consciousness. The model emphasizes functional preparedness and neural maturity without inferring internal experiences. This framework supports cautious interpretation of fetal behavior in light of ongoing neurodevelopment.
Figure 4:

Fetal sensory and brain development: Milestones of neural integration and functional readiness. This timeline illustrates the progression of fetal brain and sensory development across key gestational stages. Each milestone represents structural or functional neural changes that contribute to integrative capacity, not the onset of subjective awareness. Early events such as neural tube formation and cranial nerve differentiation lay the anatomical groundwork for sensory reception. Mid-gestational milestones like thalamocortical connectivity and cortical layering enable higher-order sensory integration. Cortical synaptogenesis and EEG differentiation suggest readiness for environmental responsiveness but do not imply the emergence of consciousness. The model emphasizes functional preparedness and neural maturity without inferring internal experiences. This framework supports cautious interpretation of fetal behavior in light of ongoing neurodevelopment.

Limitations of the evidence and this review

Several limitations constrain both the current literature and this systematic review. First, many included studies relied on observational data with small sample sizes and lacked longitudinal follow-up. Second, there was a high degree of heterogeneity in behavioral coding systems, gestational age windows, and interpretive frameworks. Third, while AI-assisted analyses represent a novel advance, they remain under-validated and often use affective terms without cross-disciplinary consensus.

In addition, although this review attempted to integrate bioethical analysis, most included studies addressed ethical concerns only in passing. This limits the depth of ethical synthesis possible. Finally, the literature remains geographically skewed, with limited representation from low-resource settings or non-Western contexts.

Future research directions

Future studies should aim for longitudinal integration of behavioral and neuroimaging data from mid-gestation through early infancy. Standardized fetal behavior coding systems, combined with advanced imaging (e.g., fetal fMRI) and physiological metrics, may offer more precise correlations between structure and function. AI models must be co-developed with ethical oversight and undergo rigorous validation before clinical adoption.

Moreover, research is needed on the public communication of fetal imaging – especially how visual representations influence perceptions of moral status, parental decision-making, and legal interpretation. Interdisciplinary research that includes obstetrics, neuroscience, ethics, communication studies, and law will be critical in advancing responsible discourse. This review finds that fetal behavior becomes increasingly structured and neurodevelopmentally aligned during the second and third trimesters. These behaviors correlate with key neuroanatomical milestones but do not constitute evidence of conscious experience. Interpretive caution is necessary, especially in the context of advanced imaging and AI-enhanced diagnostics.

Ethically, the growing visibility of the fetus presents both opportunities and challenges. Clinicians, researchers, and policymakers must remain sensitive to the limits of current evidence, avoid premature conclusions, and engage in pluralistic, context-aware ethical reflection. Scientific clarity, clinical responsibility, and ethical humility must guide ongoing inquiry into the complex intersection of fetal development, behavior, and meaning.

Strengths, limitations, and Future directions

Strengths

This review offers a comprehensive and interdisciplinary synthesis of research on fetal behavior as observed through four-dimensional (4D) ultrasonography, functional neuroimaging, and emerging artificial intelligence (AI) tools. By systematically mapping behavioral patterns across gestation onto neurodevelopmental milestones (Table 2, Table 3), the study contributes to a growing understanding of fetal sensorimotor organization and neurological maturation.

Methodologically, the review adhered to PRISMA 2020 guidelines, applying a transparent and reproducible selection process (Figure 1) across four major databases and a 25-year span (2000–2025). Its scope included foundational observational studies as well as recent innovations in AI-assisted imaging, deep learning–based segmentation, and fetal fMRI [21], 22] 31–33]. A notable contribution lies in the integration of diverse disciplines – neuroscience, obstetrics, developmental psychology, and bioethics – into a cohesive framework for analyzing fetal behavior within a structured, developmental, and ethically cautious model.

This review also underscores the interpretive potential and limitations of AI-based movement classifiers in prenatal diagnostics. Rather than endorsing speculative claims, it critically examines how technological visibility must be balanced against epistemic humility. The findings reinforce the importance of contextual interpretation, particularly when visual data are used in ethically sensitive domains such as fetal pain, viability, or clinical counseling.

Limitations

Several limitations of the current evidence base and the present review warrant acknowledgment. First, all inferences regarding fetal awareness or perceptual capacity remain indirect. While behavioral regularity and thalamocortical maturation suggest increasing neurodevelopmental organization, they do not constitute proof of conscious experience [14], 15], 21], 43]. Observable behaviors – such as facial movements or hand gestures – should be interpreted cautiously, using morphologically descriptive terms rather than affective or intentional labels [3], 6].

Second, 4D ultrasonography is constrained by technical variability, including fetal positioning, maternal body composition, and operator expertise. AI-enhanced interpretation, while promising, remains subject to misclassification – particularly when algorithms are trained on postnatal or adult datasets not validated for fetal contexts [29], [30], [31], [32], [33, 57]. These challenges raise concerns about anthropomorphic misapplication and normative assumptions embedded in behavioral modeling.

Third, the ethical interpretation of fetal imaging is highly context-dependent. As shown in Figure 3 and discussed in the literature, fetal imagery may be used rhetorically in political or cultural debates that diverge from scientific consensus [25]. This underscores the need for restraint in public-facing communication and careful distinction between visual representation and empirical evidence.

Future directions

Future research should prioritize longitudinal designs that link prenatal behavior to postnatal neurocognitive and emotional outcomes. Establishing behavioral continuity across developmental stages will strengthen the clinical relevance of fetal observations and provide a firmer foundation for risk assessment and intervention.

There is also a need for improved validation of AI-driven analytic tools. Algorithm development should be interdisciplinary and explicitly designed for prenatal application, incorporating ethical review throughout the design pipeline. This includes safeguards against semantic overreach and normative bias in the labeling of fetal behavior [21], 31], 32].

From a clinical ethics perspective, a precautionary approach remains warranted – especially in high-risk pregnancies or surgical contexts. Continued use of fetal anesthesia based on nociceptive thresholds [23], 26] reflects such a stance and should remain guided by evidence, not public sentiment.

Bioethical analysis would benefit from deeper engagement with feminist, disability, and relational ethics, which interrogate how fetal behavior is framed within maternal, cultural, and systemic contexts. Legal and policy translation must also recognize ethical pluralism, especially given differing cultural understandings of personhood, agency, and gestational thresholds [34–39].

Finally, as fetal imaging technologies become more sophisticated and widely disseminated, the need for ethically responsible communication intensifies. Future scholarship should explore how fetal visibility shapes public attitudes, clinical practice, and reproductive policy. Transparent, interdisciplinary discourse – grounded in scientific caution and cultural respect – will be essential to navigating the increasingly complex terrain of fetal development and its ethical implications.

Conclusions

This systematic review synthesizes current evidence on fetal behavior as observed through 4D ultrasonography, functional neuroimaging, and AI-assisted analysis. The findings demonstrate that fetal behaviors – including facial movements, limb activity, and sensory responsiveness – emerge in a structured and developmentally consistent manner, particularly between 24 and 34 weeks of gestation. These patterns correspond with key neurodevelopmental processes, such as thalamocortical connectivity and subplate maturation, and may reflect increasing neural integration.

However, while these behaviors align with maturational milestones, they do not constitute evidence of conscious awareness. Terms often used to describe fetal actions – such as “yawn” or “smile” – must be interpreted morphologically, not affectively or intentionally. The application of artificial intelligence has expanded the resolution and scope of behavioral analysis, but interpretive caution is essential, particularly given the absence of validated frameworks for intrauterine cognition.

The ethical implications of these findings are complex. Fetal visibility – enhanced through imaging and computation – can influence clinical decisions, public discourse, and legal debate. Yet this visibility must not be mistaken for subjective knowability. Ethical frameworks must be pluralistic, context-aware, and grounded in empirical limits.

In clinical practice, a precautionary approach remains appropriate, especially in high-risk scenarios such as fetal surgery. Reproductive autonomy and informed maternal decision-making must remain central to any application of fetal behavioral interpretation. Future research should prioritize longitudinal studies, cross-disciplinary collaboration in AI model development, and transparent communication strategies to ensure responsible translation of imaging data into practice.

In summary, while fetal behavior becomes increasingly structured and neurologically coherent during gestation, no current evidence confirms the presence of consciousness. Interpretations must remain scientifically cautious, ethically reflective, and resistant to ideological projection. As imaging technologies evolve, so too must our commitment to clarity, humility, and responsibility in how fetal life is studied, understood, and represented.


Corresponding author: Wiku Andonotopo, MD, PhD, Department of Obstetrics and Gynecology, Fetomaternal Division, Women Health Center, Ekahospital BSD City, Serpong, Tangerang, Banten, Indonesia, E-mail:

Acknowledgments

The authors appreciate the Indonesian Society of Obstetrics & Gynecology (POGI) and Indonesian Society of Maternal & Fetal-Medicine (HKFM) for encouraging and supporting the work of this review article.

  1. Research ethics: Not applicable.

  2. Informed consent: Not applicable.

  3. Author contributions: The author has accepted responsibility for the entire content of this manuscript and approved its submission.

  4. Use of Large Language Models, AI and Machine Learning Tools: None declared.

  5. Conflict of interest: The author states no conflict of interest.

  6. Research funding: None declared.

  7. Data availability: Not applicable.

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Received: 2025-05-24
Accepted: 2025-07-10
Published Online: 2025-07-23

© 2025 the author(s), published by De Gruyter, Berlin/Boston

This work is licensed under the Creative Commons Attribution 4.0 International License.

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