Who Pays for Extracurricular Activities in Manitoba? 2026 Guide to Section 7 Expenses

Both parents share extracurricular activity costs in Manitoba proportionally based on their incomes under Section 7 of the Federal Child Support Guidelines. If Parent A earns $100,000 annually and Parent B earns $50,000, Parent A pays 67% of qualifying activity expenses while Parent B pays 33%. These Section 7 expenses apply only to extraordinary extracurricular costs that exceed what the receiving parent can reasonably cover from their income plus base table child support, with the net cost calculated after deducting tax credits and subsidies.

Key Facts: Extracurricular Activities and Child Support in Manitoba

What Are Section 7 Expenses for Extracurricular Activities?

Section 7 expenses are extraordinary costs for extracurricular activities that parents share proportionally by income in addition to base table child support amounts. Under Section 7(1)(f) of the Federal Child Support Guidelines, these expenses cover activities that foster a child's talents, interests, or development, including competitive sports, music lessons, dance programs, and arts training. The expense must exceed what the receiving parent can reasonably cover from their income plus the table amount of child support they receive.

The Federal Child Support Guidelines define special or extraordinary expenses as costs that are necessary because they are in the child's best interests and reasonable given the means of both parents and the child, considering the family's spending patterns before separation. Manitoba courts apply these federal rules whether processing divorce matters under the Divorce Act or provincial family matters under The Family Maintenance Act.

Not every out-of-pocket expense qualifies as a proper Section 7 expense. Even when an expense falls within the category of extracurricular activities, the court retains significant discretion to determine whether that specific expense is necessary and reasonable in the circumstances. A casual recreational soccer league costing $200 per season typically does not qualify, while competitive hockey costing $8,000-$15,000 annually often does qualify as extraordinary.

The Five-Factor Test for Extraordinary Expenses

Manitoba courts apply a mandatory five-factor test from Section 7(1.1) of the Federal Child Support Guidelines to determine whether an extracurricular expense qualifies as extraordinary and therefore shareable between parents. Each factor receives weight in the court's analysis, and no single factor automatically determines the outcome.

The first factor examines the expense amount relative to the receiving parent's income, including the base table child support received. Courts assess whether a parent earning $45,000 annually while receiving $800 monthly in table support can reasonably absorb hockey registration fees of $3,500 from those combined resources. The second factor considers the nature and number of programs or activities in which the child participates, recognizing that costs compound when children engage in multiple activities simultaneously.

The third factor evaluates any special needs or talents the child possesses that make the activity particularly beneficial for their development. A child demonstrating exceptional musical aptitude may justify $4,000 annual piano lessons that would not qualify for an average recreational student. The fourth factor examines the overall cost of programs and activities, weighing whether total expenses across all children exceed reasonable limits. The fifth factor encompasses any other relevant circumstances the court deems appropriate.

How Parents Calculate Their Share of Activity Costs

The guiding principle for calculating each parent's share of extracurricular activity costs appears in Section 7(2) of the Federal Child Support Guidelines, which states that parents share expenses proportionally based on their respective incomes after deducting any contribution from the child. Parents earning $80,000 and $40,000 respectively would split qualifying expenses at a 67%-33% ratio, meaning on a $6,000 annual hockey expense, the higher-earning parent pays $4,000 while the lower-earning parent pays $2,000.

The Manitoba Child Support Guidelines Regulation, M.R. 52/2023 mirrors the federal calculation methodology and references the same provincial table amounts updated October 1, 2025. Both parents must calculate their annual income using the sources set out under the Total Income heading in the T1 General form issued by the Canada Revenue Agency, with adjustments specified in Schedule III of the Guidelines.

Before dividing expenses proportionally, parents must calculate the net cost by deducting any subsidies, benefits, income tax deductions, or credits relating to the expense. If total competitive dance costs $8,000 annually but the claiming parent receives a $1,200 tax credit through the Canada Child Benefit system, the shareable net cost becomes $6,800. Courts also deduct any contribution the child makes from part-time employment, particularly relevant for teenagers aged 16-18 with regular income.

Which Activities Qualify as Section 7 Expenses?

Competitive sports at elite levels consistently qualify as Section 7 extraordinary expenses when costs exceed $3,000-$5,000 annually and include travel, equipment, coaching, and tournament fees. In the Manitoba case of Correia v. Correia, the Court of King's Bench analyzed whether organized snowmobile racing qualified as a Section 7 expense, examining both whether the mother could reasonably cover the costs and whether the activity was necessary and reasonable given its expense and inherent dangers.

Activities that typically qualify as extraordinary extracurricular expenses include competitive hockey at AAA, AA, or elite levels costing $8,000-$20,000 annually, competitive figure skating with private coaching at $5,000-$12,000 yearly, elite gymnastics or dance at provincial or national competitive levels, specialized music instruction with a focus on performance or conservatory preparation, and travel sports teams requiring out-of-province competition.

Activities that generally do not qualify include recreational community sports leagues costing under $500 per season, school sports teams with minimal fees, community center swimming lessons under $300 annually, and basic music lessons at entry level costing under $1,500 per year. The determination depends heavily on the specific circumstances, with the same activity potentially qualifying for one family while not qualifying for another based on parental incomes and family spending history.

The Requirement for Parental Consultation and Agreement

Parents with joint decision-making responsibility regarding their children must discuss and agree upon Section 7 expenses before enrolling a child in costly activities. Under the Divorce Act, R.S.C. 1985, c. 3, as amended in 2021, decision-making responsibility includes authority over significant extracurricular activities, meaning neither parent should unilaterally commit to expenses exceeding $2,000-$3,000 annually without the other parent's input.

Courts have consistently held that a parent who enrolls a child in an expensive activity without informing or consulting the other parent risks having their claim for contribution denied. In Ginese v. Fadel (2024 ONSC 3011), when a father enrolled one child in a dance program where costs increased from $2,693 in 2021 to $14,444 in 2023 without consulting the mother, and similarly doubled soccer costs for other children, the court found these increased expenses were neither necessary nor reasonable.

Best practices for Section 7 expense consultation include providing written notice at least 30 days before activity registration deadlines, sharing full cost breakdowns including equipment, travel, and tournament fees, discussing how the activity fits the child's demonstrated interests and abilities, and documenting the other parent's response or non-response to the proposed expense. Parents who follow proper consultation procedures strengthen their position for court-ordered contribution if the other parent unreasonably refuses.

How Manitoba Courts Determine Necessity and Reasonableness

Manitoba courts apply a three-part test to determine whether a specific extracurricular expense is necessary and reasonable: the expense must benefit the child's best interests, the cost must be appropriate given parental and child financial means, and the expense must align with the family's pre-separation spending patterns. An activity the family funded at $6,000 annually before separation carries strong weight for continuation post-separation.

The best interests analysis considers how the activity contributes to the child's physical, emotional, social, or intellectual development. Courts examine whether discontinuing a long-standing activity would harm the child's development or emotional well-being, particularly where the child has demonstrated commitment and talent. A child who has trained in competitive swimming for 6 years and reached provincial qualifying times presents a stronger case than a child beginning a new expensive activity post-separation.

Financial means analysis requires courts to examine both parents' actual incomes, existing financial obligations including base child support and spousal support, housing costs, and other Section 7 expenses already being shared. Courts may reduce or eliminate contribution requirements where the total burden of Section 7 expenses would leave a parent unable to meet basic living expenses. Pre-separation spending patterns provide evidence of what the family historically prioritized and could afford.

Income Calculation for Section 7 Expense Sharing

Annual income for Section 7 expense calculations follows the same methodology as base child support under Sections 16-20 of the Federal Child Support Guidelines. Parents use Line 15000 (Total Income) from their T1 General tax return as the starting point, then apply adjustments from Schedule III including adding back certain deductions and accounting for self-employment income fluctuations.

The 2025 update to child support tables increased the income threshold below which no child support is payable from $13,000 to $16,000 annually. Parents earning below $16,000 may have zero base table support obligations, though they may still share Section 7 expenses proportionally based on their actual income above zero. The table amounts effective October 1, 2025 apply to both new and existing orders unless the court specifically orders otherwise.

For self-employed parents, courts may impute income based on historical earnings patterns, business assets, or lifestyle indicators where reported income appears artificially low. Courts also consider overtime income, bonuses, and second job earnings when calculating the proportional share each parent must contribute to extracurricular activity costs.

Child's Contribution from Part-Time Employment

The Federal Child Support Guidelines explicitly contemplate that children may contribute to their own Section 7 expenses from employment income, with that contribution deducted before parents split the remaining balance. For teenagers aged 15-17 earning $200-$400 monthly from part-time work, courts may attribute 25-50% of those earnings toward activities the child enjoys and benefits from, reducing each parent's absolute contribution accordingly.

Children under the age of majority rarely have contributions formally attributed for Section 7 purposes, though the Guidelines wording does not specifically prohibit it. Once a child turns 18 and child support continues for post-secondary education, courts more frequently consider the child's financial resources including employment income, savings, and RESP withdrawals when calculating how much parents must contribute to expenses.

Parents should use Worksheet 1 from the Federal Child Support Guidelines to estimate child income contributions where applicable. A 17-year-old earning $6,000 annually from part-time work might reasonably contribute $1,500-$2,000 toward their own competitive hockey expenses before parents split the remaining $10,000-$12,000 proportionally by income.

Tax Deductions and Subsidy Considerations

Section 7(3) of the Guidelines requires courts to reduce shareable expenses by any tax benefits, subsidies, or income tax deductions available to either parent. The Canada Child Benefit provides tax-free monthly payments that may offset childcare and activity costs for lower-income families, while provincial recreation tax credits in some jurisdictions further reduce net expenses.

Parents claiming childcare expenses on their tax returns receive deductions that reduce their net cost of daycare, which qualifies as a Section 7 expense under Section 7(1)(a). If daycare costs $12,000 annually but the claiming parent receives a $2,400 tax benefit, the shareable expense becomes $9,600 divided proportionally. Similar calculations apply where employers provide childcare subsidies or flexible spending accounts for dependent care.

Manitoba does not currently offer a provincial children's fitness or arts tax credit, though the federal government previously provided such credits before 2017. Parents should track all potential deductions and subsidies to accurately calculate net Section 7 expenses, as overstating costs may result in court orders requiring reimbursement of overpaid amounts.

Enforcement and Modification of Section 7 Expense Orders

Manitoba's Maintenance Enforcement Program (MEP) can enforce court orders for Section 7 expense contributions alongside base child support obligations. When one parent fails to pay their proportional share of $3,000 in annual hockey expenses, the receiving parent can register the arrears with MEP for collection through wage garnishment, driver's license suspension, or passport denial for amounts exceeding $3,000.

Either parent may apply to vary a Section 7 expense order when material circumstances change, including significant income changes of 10% or more, a child's changing interests or abilities, or one parent's relocation affecting activity availability. The court applies the same necessity and reasonableness test to proposed modifications, considering whether continued contribution remains appropriate given current circumstances.

Parents should keep detailed records of all Section 7 expense receipts, communications regarding activity enrollment, and evidence of payments made. Documentation proves essential when seeking enforcement of unpaid contributions or when defending against claims of non-payment. Courts view parents who maintain organized financial records more favorably than those who cannot substantiate their claims.

How to Request Section 7 Expense Contributions

Parents seeking court-ordered Section 7 expense contributions must file a Statement of Claim or Motion with the Manitoba Court of King's Bench (Family Division), paying the $200 filing fee unless eligible for a fee waiver through Legal Aid Manitoba. The application should include detailed evidence of the expense amounts, the child's participation history, pre-separation spending patterns, and both parents' current incomes.

Required documentation includes activity registration receipts and invoices, equipment purchase records, travel and accommodation expenses for out-of-town competitions, the child's achievement records demonstrating commitment and talent, both parents' Notice of Assessment from the Canada Revenue Agency for the most recent 3 years, and any written communications regarding the activities between parents.

Courts prefer parents who negotiate Section 7 expenses directly through mediation or collaborative family law processes before seeking judicial intervention. The Community Legal Education Association of Manitoba provides resources for self-represented litigants navigating family court procedures, though complex Section 7 disputes often benefit from legal representation given the discretionary nature of court decisions.

Frequently Asked Questions

Does base table child support cover extracurricular activities in Manitoba?

Base table child support covers ordinary extracurricular costs that parents can reasonably absorb from their income plus support received. Section 7 extraordinary expenses apply only when activity costs exceed approximately $2,000-$3,000 annually and represent costs the receiving parent cannot reasonably cover. Courts assess each family's specific financial circumstances when determining the threshold between ordinary and extraordinary expenses.

What percentage does each parent pay for Section 7 expenses?

Parents share Section 7 expenses proportionally based on their respective annual incomes. A parent earning $90,000 paired with a parent earning $60,000 would split costs 60%-40% respectively. The calculation uses income above the $16,000 threshold where no table support applies, and deducts any child contribution before dividing the remainder proportionally between parents.

Can one parent enroll a child in activities without the other parent's consent?

Parents with shared decision-making responsibility must consult before enrolling children in significant extracurricular activities costing more than $2,000-$3,000 annually. Courts have denied contribution claims where one parent enrolled children in expensive programs without informing or consulting the other parent. Unilateral enrollment decisions risk having the enrolling parent bear 100% of costs.

What activities typically qualify as Section 7 extraordinary expenses?

Competitive sports at elite levels (AAA hockey, provincial gymnastics, competitive figure skating) costing $5,000-$20,000 annually typically qualify when the receiving parent cannot reasonably cover costs from income plus support. Advanced music training with conservatory-track instruction, specialized dance programs at competitive levels, and travel sports teams with significant out-of-province competition costs also commonly qualify.

How do courts handle disputes about activity costs?

Manitoba courts apply a five-factor test examining expense amounts relative to parental income, the nature and number of activities, the child's special needs or talents, overall program costs, and other relevant factors. Either parent may file a motion with the Court of King's Bench seeking a determination of whether specific expenses qualify and how costs should be divided.

Do teenagers have to contribute from their part-time job earnings?

Courts may attribute a portion of teenage earnings (typically 25-50% for ages 16-17) toward Section 7 expenses before dividing the remainder between parents. A 17-year-old earning $6,000 annually might contribute $1,500-$2,000 toward their own hockey expenses. Contributions from children under 16 are rarely required unless the child has substantial independent income.

What happens if one parent refuses to pay their share?

Unpaid Section 7 expense contributions can be enforced through Manitoba's Maintenance Enforcement Program, which may garnish wages, suspend driver's licenses, or deny passport renewals for arrears exceeding $3,000. The receiving parent must document all expenses and payments to support enforcement applications.

Can Section 7 expense orders be changed if circumstances change?

Either parent may apply to vary a Section 7 expense order when material circumstances change, including income changes of 10% or more, a child's changing interests, or relocation affecting activity availability. The court applies the same necessity and reasonableness test to proposed modifications, requiring evidence of changed circumstances.

Are tax credits deducted from Section 7 expenses before sharing?

Yes. Under Section 7(3) of the Guidelines, courts must deduct any tax benefits, subsidies, or credits relating to the expense before calculating each parent's proportional share. If an $8,000 expense generates a $1,200 tax benefit, parents share the $6,800 net cost rather than the full $8,000.

What evidence do I need to claim Section 7 expenses?

Parents must provide registration receipts, equipment invoices, travel expenses, the child's achievement records, both parents' tax returns for 3 years, and communications about the activities. Courts favor organized documentation over verbal claims, and may deny contributions where the claiming parent cannot substantiate expense amounts.