Does the three-year retroactivity limit still apply if the payor deliberately hid their income?

The commonly cited "roughly three years" figure is a general starting point courts use when assessing how far back a retroactive child support award should reach, not a hard statutory cap, and it is specifically one of the things that can be extended where the payor engaged in blameworthy conduct, including deliberately concealing or misrepresenting their true income. Courts have recognized that a payor should not benefit from their own concealment, so where hidden income is proven, the look-back period can extend well beyond the usual starting point, potentially covering the entire time the concealment occurred.

What counts as concealment can include underreporting self-employment income, failing to disclose a raise or bonus that should have triggered a support review, or actively misleading the recipient about their financial situation. The recipient still generally needs to show when they could reasonably have discovered the true income and how quickly they acted once they did, since courts also consider the recipient's own diligence. Because this turns heavily on specific evidence of concealment and discovery, a recipient in this situation should gather documentation, such as any communications or financial records, as soon as the hidden income comes to light.