Can undue hardship be claimed by the recipient parent, not just the payor?

Yes. The undue hardship provisions in the Federal Child Support Guidelines are available to either parent, not just the person paying support, so a recipient parent facing one of the recognized qualifying circumstances, such as unusually high debts reasonably incurred to support the family, can also apply for an adjustment to the standard table amount. This comes up less often in practice simply because recipients are usually the ones seeking an increase rather than a further adjustment, but the legal mechanism itself does not favour one side over the other.

The same two-stage analysis applies regardless of who brings the claim: the parent must first establish that the qualifying circumstance actually causes hardship, and then the case moves to a comparison of the standard of living between both households, since undue hardship is not found where the claiming household's standard of living is not actually lower than the other's. Because the framework treats both parents symmetrically, a recipient parent considering this kind of claim should expect to meet the same evidentiary bar around financial disclosure and the standard-of-living comparison that a payor would face.