What Is a Schedule 1 Application?
Last updated: April 2026
by Jess Knauf, Director of Client Strategy at Mediate UK
Information reflects current family law and mediation requirements as of 23 April 2026.
Key Takeaways
- A Schedule 1 application allows unmarried parents to apply to court for financial provision for their children under the Children Act 1989.
- It can include orders for housing, lump sums, periodical payments, and contributions to childcare costs.
- Schedule 1 is not the same as a divorce financial settlement, and the financial provision is for the child’s benefit, not the parent’s.
- The Child Maintenance Service (CMS) handles most maintenance cases, but courts can “top up” where the paying parent earns over £156,000 gross per year.
- Mediation can be a quicker, less costly way to reach an agreement, and attending a MIAM is required before making most court applications.
Schedule 1 Application
A Schedule 1 application is a legal process under Schedule 1 of the Children Act 1989 that allows an unmarried parent to apply to court for financial provision on behalf of their child. It can cover housing, lump sum payments, periodical payments, and childcare costs, and is particularly relevant where parents were never married or in a civil partnership. The purpose is to meet the financial needs of the child, not to replicate the financial settlement available on divorce.
If you have a child with a partner you were never married to, and your relationship has broken down, you may be wondering what financial options are available to you. Many parents are surprised to find that, without a marriage or civil partnership, the usual divorce financial settlement rules simply do not apply. A Schedule 1 application is the legal tool designed to fill that gap, allowing a parent to ask the court to provide financial support for a child, even where the parents were never a couple in the legal sense. In this guide, we explain what a Schedule 1 claim involves, how the process works, and what the recent high-profile case of Goodman v Walker tells us about how courts approach these applications.
We also look at how mediation and other routes can help families reach an agreement without the cost and stress of court proceedings. For a broader view of financial arrangements on separation, our Ultimate Guide to Financial Settlement on Divorce covers the full picture for both married and unmarried couples.
What does a Schedule 1 Application include?
Schedule 1 of the Children Act 1989 sets out the powers the family court has to make financial orders in relation to children where the parents are not, and have never been, married or in a civil partnership. It is a separate legal route from divorce financial proceedings, and it is important to understand the distinction.
A Schedule 1 application can be made by a parent, guardian, special guardian, or anyone named in a Child Arrangements Order as the person with whom the child lives. In most cases, it is the parent with whom the child primarily lives who makes the application, seeking financial provision from the other parent.
The court can make a wide range of orders under Schedule 1, including:
Housing orders: The court can require the non-resident parent to purchase or provide a property for the child and their primary carer to live in. Importantly, this property typically reverts to the paying parent when the child finishes full-time education.- Lump sum payments: These might cover furniture, a vehicle, legal costs, or other capital needs directly connected to the child’s welfare.
- Periodical payments: Regular financial support, similar to child maintenance, payable to the parent with care on behalf of the child.
- Childcare contributions: Where applicable, the court can order a contribution to nursery fees, nanny costs, or school fees.
- Settlement of property: In some cases, a property can be settled on trust for the child’s benefit.
Housing orders: The court can require the non-resident parent to purchase or provide a property for the child and their primary carer to live in. Importantly, this property typically reverts to the paying parent when the child finishes full-time education.Schedule 1 and Child Maintenance: What Is the Difference?
Many parents start with the Child Maintenance Service (CMS), which handles the calculation and enforcement of regular child maintenance payments. This is the right first step for most families.
However, the CMS has a cap on the income it can assess. Where the paying parent earns more than £156,000 gross per year, the CMS cannot make an assessment beyond that figure. In those higher-income cases, the receiving parent can make a Schedule 1 claim to court to “top up” the maintenance beyond what the CMS can award.
The court will look at the paying parent’s income, assets, and standard of living alongside the specific financial needs of the child. It is not a formula, and each case is assessed on its own facts.
What Schedule 1 Is Not
One of the most common misconceptions about a Schedule 1 application is that it allows the parent with care to claim a financial settlement for themselves, comparable to what they might receive on divorce. That is not the case.
All orders made under Schedule 1 are for the benefit of the child. A housing order, for example, provides a home for the child to live in during childhood, but the property remains the paying parent’s asset and is returned to them once the child has finished education or the primary carer remarries or begins living with a new partner.
The court is alert to applications that appear to be seeking provision for the parent under the guise of meeting the child’s needs. As the Goodman v Walker case makes very clear, claims must be reasonable and directly connected to the child’s welfare, not a back-door route to a lifestyle-based award for the parent.
Considering Your Options as an Unmarried Parent?
Mediation can be a far less costly and more private way to reach agreement on child arrangements and financial support. Book a MIAM to find out if mediation is right for your situation.
Case Study: Goodman v Walker [2024] EWFC 212 (B)
In the News: Goodman v Walker and What It Tells Us About Schedule 1
Few cases have put Schedule 1 applications under a brighter public spotlight than the proceedings involving Premier League footballer Kyle Walker and influencer Lauryn Goodman, heard before His Honour Judge Hess at the Central Family Court in July 2024.
Walker and Goodman were never married. They have two children together, Kairo and Kinara. In an earlier set of proceedings concluding in 2022, the court ordered Walker to purchase a property for Goodman and Kairo to live in, up to a value of £1.85 million, within a certain radius of Sussex. Walker was also ordered to pay child maintenance of £8,000 per month, plus contributions toward childcare costs, a furniture fund, a replacement vehicle every four years, and lump sums covering Goodman’s debts.
In June 2023, shortly after the birth of Kinara, Goodman made a further Schedule 1 claim. The 2024 hearing addressed a number of additional items she sought, including a £33,000 air conditioning unit, an astroturf football pitch costing £31,000, hot tub maintenance at £500 per month, a new Mercedes GLE every three years, and childcare costs of up to £350,000 per year. The Judge’s findings were pointed: he described Goodman as treating Walker like “an open-ended cheque book” and found that her claims were often exaggerated and not reliably evidenced.
One particularly striking example involved Goodman’s request for an astroturf pitch for Kinara, who was one year old at the time of the hearing. The justification offered was that the infant had shown footballing potential by kicking a ball with her left foot from a crawling position. HHJ Hess described this as “an unjustified evidential leap.”
The final outcome saw Goodman receive some of what she sought, but at far more modest levels. Monthly maintenance payments were increased to £12,500 to account for both children, and the housing cap was raised to £2.4 million, but the more extravagant claims were dismissed. The Judge was clear that Walker’s stance throughout the proceedings had been fair and reasonable, and that Goodman should have accepted his offer far earlier.
HHJ Hess also took the unusual step of waiving anonymity and publishing the judgment in full, as part of the family court’s transparency pilot. The case is now publicly available at Goodman v Walker [2024] EWFC 212 (B). It remains one of the clearest illustrations of how a court will scrutinise Schedule 1 applications and reject claims that do not genuinely reflect a child’s needs.
What Lessons Does This Case Teach?
The Goodman v Walker case is a useful reference point for anyone considering a Schedule 1 claim, for several reasons.
- Claims must be proportionate: The court will assess what is genuinely needed for the child, based on the paying parent’s income and lifestyle. Inflated or poorly evidenced claims are likely to be rejected, and may attract adverse cost consequences.
- Schedule 1 is not a lifestyle award for the primary carer: Provision is for the child’s benefit. Parents should resist the temptation to frame their own wishes as the child’s needs.
- Transparency in the family court is increasing: As this case showed, there is a growing movement toward publishing family court judgments. If you go to court, there is a real possibility that the details could become part of the public record.
- Early settlement is generally better: Judge Hess made clear that Goodman should have accepted Walker’s offer well before the final hearing. Prolonging proceedings through unreasonable positions adds costs, delays, and stress for everyone involved, including the children.
“We see cases where one party holds back from mediation, expecting the court to deliver a more favourable outcome. The reality is that courts look carefully at proportionality and reasonableness. A negotiated agreement through mediation, reached at an early stage, almost always produces a better result for the whole family than a drawn-out court process.”
Jess Knauf, Director of Client Strategy, Mediate UK
How Does a Schedule 1 Application Work in Practice?
If you are considering a Schedule 1 application, understanding the process can help you plan ahead and consider whether there are less formal routes that might work first.
Step 1: Consider Mediation First
Before making any court application, you are generally required to attend a Mediation Information and Assessment Meeting (MIAM). This is a short, confidential meeting with an accredited mediator to explore whether your dispute might be resolved through mediation rather than court. There are limited exemptions to this requirement, for instance in cases involving domestic abuse.
Mediation can be particularly effective for financial discussions involving children. A mediator will help both parents explore what the child genuinely needs and reach an agreement that works practically for both households, without the adversarial nature of court proceedings. You can find out more about our financial mediation process here.
Step 2: Make the Court Application
If mediation is not suitable or has not produced a resolution, you can apply to the family court under Schedule 1. You will typically need to complete a Form A for financial remedy proceedings, along with a MIAM certificate confirming that you have attended, or are exempt from, a MIAM.
You will also be required to provide full financial disclosure through a Form E, setting out your income, assets, outgoings, and the financial needs of the child. Read our guide to financial disclosure for a full explanation of what this involves.
Step 3: Attend Court Hearings
A Schedule 1 case will typically involve a First Directions Appointment (FDA), a Financial Dispute Resolution hearing (FDR), and, if agreement is not reached, a Final Hearing. At each stage, the court will encourage the parties to settle.
Family Law Service
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What Factors Does the Court Consider in a Schedule 1 Claim?
Unlike in divorce financial proceedings, the court does not have a specific statutory checklist to follow under Schedule 1. However, case law has established that the court will generally look at a broad range of factors, including:
- The income and financial resources of both parents: Including earning capacity and future financial prospects.
- The financial needs of the child: Based on their age, any disabilities, and the standard of living they would have enjoyed had the family remained together.
- The paying parent’s lifestyle and standard of living: The child is generally entitled to benefit from the paying parent’s financial position.
- The financial needs of the primary carer: Insofar as they relate to providing a home and care for the child.
- Any physical or mental disability of the child.
- The way the child has been, or is expected to be, educated.
The welfare of the child is an important consideration, though it is not the court’s “paramount” consideration as it is in children’s living arrangements cases. The court’s task is to strike a fair balance between the child’s needs and what it is reasonable to ask the paying parent to provide.
Can a Schedule 1 Agreement Be Reached Without Going to Court?
Yes, and in most cases this is preferable. Parents can negotiate and agree financial arrangements for their children without ever setting foot in a courtroom. The options include:
Direct negotiation: If the relationship is amicable enough, parents can agree arrangements directly, ideally with legal advice to make sure the terms are fair.- Family mediation: A mediator helps both parents discuss financial provision and reach an agreed outcome. Any agreement reached in mediation can be written up and, if appropriate, made into a consent order by the court.
- Solicitor negotiation: Each parent instructs their own solicitor to negotiate on their behalf.
- Collaborative law: Both parents and their solicitors meet together to reach an agreed solution.
Direct negotiation: If the relationship is amicable enough, parents can agree arrangements directly, ideally with legal advice to make sure the terms are fair.Mediation has a strong track record in financial cases involving children. It tends to be quicker, less expensive, and more private than court proceedings. For families where privacy matters, the growing transparency in the family courts, illustrated by the publication of the Goodman v Walker judgment, is an additional reason to consider resolving things without litigation. You can learn more about how financial remedies in mediation can help, or explore our guide to making mediated agreements legally binding.
Do You Need a MIAM Before a Schedule 1 Application?
In most cases, yes. Before making a court application under Schedule 1, you are generally required to show that you have considered mediation by attending a MIAM. This is a brief, confidential meeting with a qualified family mediator who will explain how mediation works and help you both assess whether it is a suitable route for your situation.
There are some exemptions to this requirement, such as where domestic abuse has been involved. You can check whether you may be exempt using our MIAM calculator, or read our full overview of MIAM exemptions.
At Mediate UK, we offer MIAMs for £115 plus VAT per person, with appointments available quickly across the UK. Many clients find that after their MIAM, they choose to proceed with mediation rather than court, saving significant time and money.
Summary
A Schedule 1 application is the legal route available to unmarried parents seeking financial provision for their child. It can cover housing, lump sums, maintenance top-ups, and childcare contributions, but it is not a substitute for divorce financial proceedings and all provision must be genuinely for the child’s benefit.
The Goodman v Walker case is a useful reminder that courts will scrutinise claims carefully and expect them to be proportionate. Whether you are considering a Schedule 1 claim or responding to one, exploring mediation and other non-court options first is almost always worthwhile. A MIAM is usually the required first step before any court application, and can also be the start of a more constructive resolution.
Frequently Asked Questions
Who can make a Schedule 1 application?
A Schedule 1 application can be made by a parent, guardian, special guardian, or a person named in a Child Arrangements Order as someone with whom the child lives. It is most commonly made by the parent with primary care of the child, directed at the other parent. In certain circumstances, a child aged 18 or over who is in full-time education can also make an application themselves.
What is the difference between a Schedule 1 claim and a divorce financial settlement?
A divorce financial settlement divides the assets and financial resources of two married or formerly civil-partnered people. A Schedule 1 claim is available to unmarried parents and is solely for the financial benefit of the child, not the parent. Any housing provided under Schedule 1 returns to the paying parent when the child finishes education or the primary carer begins a new relationship. Parents cannot use Schedule 1 as a backdoor route to a personal financial settlement.
What can a court order under Schedule 1?
The family court can make a range of orders under Schedule 1, including a settlement or transfer of property for the child’s benefit, lump sum payments for furniture, a vehicle, or other capital needs, periodical payments (regular child maintenance), top-up maintenance beyond the CMS cap, and contributions to childcare, nursery, or school fees. Orders for housing typically include a condition that the property is returned to the paying parent when the child finishes education.
Do I need a MIAM before making a Schedule 1 application?
In most cases, yes. You are generally required to attend a Mediation Information and Assessment Meeting (MIAM) before making a court application under Schedule 1, unless an exemption applies. Exemptions can apply in cases involving domestic abuse, urgency, or other specific circumstances. A MIAM is a short confidential meeting with a qualified mediator to explore whether mediation might be a suitable alternative to court.
What did the Goodman v Walker case decide?
Goodman v Walker [2024] EWFC 212 (B) was a high-profile Schedule 1 case involving footballer Kyle Walker and Lauryn Goodman, heard before HHJ Hess in July 2024. Goodman made a number of financial claims for their daughter Kinara, many of which were rejected by the court as disproportionate. The judge increased monthly maintenance to £12,500 for both children and raised the housing cap to £2.4 million, but dismissed the more extravagant requests. The judgment was published in full as part of the family court’s transparency pilot.
Can I reach a Schedule 1 agreement without going to court?
Yes. Parents can agree financial provision for their children without court involvement, through direct negotiation, mediation, collaborative law, or solicitor correspondence. Any agreement reached outside court can be recorded in a written document and, if appropriate, converted into a court order for enforceability. Mediation is often the most cost-effective and private option, and is generally required as a first step before any court application can be made.
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