legal.aguilar-pelaez.co.uk built 2026-05-26 19:42 UTC · logout

reg 1.09A - definition of "de facto relationship"

The four-factor test for whether two people are in a de facto relationship. Crucially, factor (d) explicitly contemplates partners who do not live together permanently, which is why a long-distance relationship with periods apart can still meet the legal test.

Primary source

"For the purposes of subsection 5CB(2) of the Act, the Minister is to consider all of the circumstances of the relationship, including, in particular, the matters set out in subregulation (3).

The matters for subregulation (2) are:

(a) the financial aspects of the relationship, including:
    (i) any joint ownership of real estate or other major assets;
    (ii) any joint liabilities;
    (iii) the extent of any pooling of financial resources, especially in relation to major financial commitments;
    (iv) whether one person in the relationship owes any legal obligation in respect of the other;
    (v) the basis of any sharing of day-to-day household expenses;

(b) the nature of the household, including:
    (i) any joint responsibility for the care and support of children;
    (ii) the living arrangements of the persons;
    (iii) any sharing of the responsibility for housework;

(c) the social aspects of the relationship, including:
    (i) whether the persons represent themselves to other people as being in a de facto relationship with each other;
    (ii) the opinion of the persons' friends and acquaintances about the nature of the relationship;
    (iii) any basis on which the persons plan and undertake joint social activities;

(d) the nature of the persons' commitment to each other, including:
    (i) the duration of the relationship;
    (ii) the length of time during which the persons have lived together;
    (iii) the degree of companionship and emotional support that the persons draw from each other;
    (iv) whether the persons see the relationship as a long-term one." Migration Regulations 1994 (Cth) reg 1.09A(2) and (3)

The four factors mapped to the four pillars of evidence

The four reg 1.09A subregulations map directly to the four-pillar evidence framework the Department uses when assessing partner visas. This is not a coincidence: the four pillars are the operational expression of the legal test.

reg 1.09A factorPillarWhat it asks
(a) financialFinancialJoint assets, joint liabilities, pooled resources, shared day-to-day expenses
(b) householdHouseholdLiving arrangements, shared housework, joint care of children
(c) socialSocialHolding out to others, friends' opinions, joint social life
(d) commitmentCommitmentDuration, time lived together, emotional support, long-term view

Critical reading: factor (d)(ii) does not require continuous cohabitation

Factor (d)(ii) refers to "the length of time during which the persons have lived together" - in the past tense, accumulated. It does not say "the relationship requires continuous cohabitation". This phrasing, combined with the Migration Act s 5CB(2) standard "not living separately and apart on a permanent basis", is what permits long-distance relationships to qualify.

My case Eduardo and Natalie have ~278 days of documented cohabitation across 14 distinct periods on 10 continents between Aug 2024 and May 2026. They have never been "separately and apart on a permanent basis" - the periods apart were for work demands (Natalie's E-3 role in San Francisco, Eduardo's UK company) with active planning to be co-located whenever possible. The relationship satisfies reg 1.09A on all four factors. The cohabitation chronology supports factor (d) in particular.

My case verdict

De facto relationship under reg 1.09A: satisfied

All four factors evidentially supported. Modlean verdict: relationshipSatisfied eduardoNatalieRelationship = true (kernel-checked in ModleanSatAuPartnerVisa).

Related