Names used in all published decisions are pseudonyms. Any references appearing in square brackets indicate that information has been omitted from this decision and replaced with generic information pursuant to subsection 16(2AB) of the Child Support (Registration and Collection) Act 1988.

1. Mr Maddox and Ms Shephard are the parents of [Child 1], born [in] November 2018. According to the records of Services Australia - Child Support (Child Support), prior to 9 April 2024, the parents had a private arrangement for the collection of child support.
2. On 9 April 2024, the mother lodged an application with Child Support for it to collect child support payments on her behalf, including arrears of $839.57 for the period from 1 March 2024 to 8 April 2024 (the arrears period).
3. On 30 April 2024 Child Support decided to accept the mother's application, including the collection of arrears of $839.57 for the arrears period (the original decision).
4. On 9 June 2024, the father lodged an objection to the original decision.
5. On 22 July 2025, an objections officer from Child Support disallowed the objection (the objection decision). This meant that there was no change to the original decision.
6. On 18 August 2025, the father lodged an application for review with the Tribunal. The matter was heard on 10 December 2025. Both parents attended via MS Teams audio (equivalent to conference telephone) and gave affirmed evidence.
7. The Tribunal had before it a bundle of documents provided by Child Support, numbered 1 to 60, copies of which were provided to the parties before the hearing.

1. The statutory provisions relevant to this review are contained in the Child Support (Registration and Collection) Act 1988 (the Act).
2. The issue which arises in this case is whether the father is required to pay arrears of child support of $839.57 for the period 1 March 2024 to 8 April 2024.

1. Section 24A of the Act provides for a person to register a child support case at which time a registrable maintenance liability arises. It also provides for the payee to elect that Child Support does not have to collect child support; that is, the liability is not enforced.
2. Relevant to this review, section 28A provides for an application by a payee to change from a private collection arrangement to collection by Child Support, and for arrears of child support to be collected, up to a maximum of nine months. If the payee asks for arrears to be paid for a period that does not exceed three months, that application must be granted.[1]

1. On 9 April 2024 the mother applied to Child Support to collect child support on her behalf and to collect arrears of child support for the period 1 March 2024 to 8 April 2024. The arrears were calculated to be $839.57.
2. In a letter to Child Support dated 27 June 2025, the father wrote that the child support payable by him should have commenced from 8 April 2024 (it commenced from 9 April 2024) and not from 1 March 2024.[2]
3. The Tribunal confirmed with the father at the hearing that he did not have an issue with Child Support collecting child support from 9 April 2024. He was seeking review of the objection decision because of the collection of arrears of $839.57 for the period 1 March 2024 to 8 April 2024.
4. Given the father was agreeable to Child Support being responsible for collecting child support from 9 April 2024, the Tribunal will not consider that element of the objection decision any further.
5. Regarding the arrears, the father's position was that he and the mother had a private agreement from about January 2024 that he did not have to pay child support. He confirmed that there was no formal, written agreement between the parents about child support but was insistent that they had made an agreement. He referred to there being a private agreement in his letter of 27 June 2025.[3]
6. The mother said that the father had not paid child support for about six months before 9 April 2024, which contrasted with the father's position that he had not paid child support from about 1 January 2024.
7. The father directed the Tribunal to page 32 of the Child Support documents. This was the fourth page of what appears to be an email dated 3 January 2024 from the father to the mother, with commentary from both parents inserted into the text. It appears to include an email from the mother to the father dated 2 January 2024.
8. The mother had written "I'll inform child support you no longer want to pay".
9. The Tribunal does not consider this to be an agreement between the parents about the payment of child support. Rather, it reads as if the mother had undertaken to inform Child Support of what the father wanted.
10. The mother said that the father had been sending her abusive text messages about him being unwilling to pay child support and she wanted the messages to stop, so she agreed that he would not pay child support.
11. The mother said that the father then wanted her to call Child Support and tell them that he was no longer paying child support. She contacted Child Support accordingly but the verbal abuse did not stop and so she got a restraining order. There was then a period when they did not communicate with each other.
12. The father said that the premise of what the mother had said was correct. He confirmed that he had not paid child support since January 2024 which was when the mother called Child Support.
13. The father said that he wanted to have more care of their child and the mother refused. That was what was behind their disagreement.
14. The mother said that she thought it was unfair that she was not being paid child support but she was under duress and she wanted the name-calling to stop. She said that she understood that she could have claimed arrears for a longer period but claimed them from 1 March 2024 (and not an earlier date) as that seemed fair.
15. The Tribunal notes that the parents' evidence was largely consistent with what Child Support officers recorded when they spoke with each parent, which occurred a number of times between 9 April 2024 (when the mother lodged her application for collection by Child Support) and 22 July 2025 (when the objection decision was made).
16. The Tribunal has already recorded that the father was agreeable to Child Support collecting child support from 9 April 2024. He confirmed that he did not pay child support from 1 January 2024 to 8 April 2024. The Tribunal is satisfied that there is no written agreement between the parents that the father should not pay child support for the period in question.
17. Given the evidence just set out, the Tribunal is satisfied that arrears of $839.57 for the period 1 March 2024 to 8 April 2024 are payable by the father, pursuant to section 28A of the Act.
18. The Tribunal notes that the father did pay the arrears on 8 June 2024.[4]

[1] Section 28A applies in cases where a parent has applied for the first time for Child Support to collect the child support payments. This information was set out on page 7 of the Child Support documents. Under the heading "Application for Collection ...", there is a question and answer: "Is this the first application or a subsequent application? First". Otherwise, section 39A of the Act applies which also sets out that if the payee asks for arrears for up to three months to be paid, then that application must be granted.

[2] Page 48 of the Child Support documents

[4] Page 59 of the Child Support documents.