The Increasing Offenders’ Accountability for Victims Act brought significant amendments to the “victim surcharge” under s. 737 of the Criminal Code. Judges are now required to impose a flat surcharge for each count. No longer do judges have the discretion to refrain from imposing surcharges on the grounds that it would constitute an “undue hardship” to the offender – the provision that previously allowed judges to tailor a sentence to the financial means of the offender. The