Arizona Expands Scope of Unclaimed Property Law by Eliminating Key Statutory Exemptions

Arizona has enacted legislation that could significantly expand the scope of the state’s unclaimed property law by eliminating several longstanding statutory exclusions from the definition of “property.” As enacted, the changes will require many holders to reevaluate their Arizona unclaimed property compliance programs. The legislation eliminates Arizona’s longstanding business-to-business (B2B) and de minimis exemptions, while also removing exclusions for gift certificates, gift cards, and other forms of stored value, potentially broadening the range of property subject to Arizona’s unclaimed property law.

Background

On June 22, 2026, Arizona Governor Katie Hobbs signed SB 1336 into law, which amends the definitions section of Arizona’s Unclaimed Property Act. Effective September 12, 2026, the legislation expands the statute’s potential reach by removing several longstanding exclusions from the definition of “property.”

Exemptions Eliminated

The amendment eliminates Arizona’s statutory exclusions for the following:

• B2B property arising from a current business relationship

• De minimis property (defined by Arizona as $50 or less)

• Gift certificates

• Electronic gift cards

• Stored value cards

• Nonrefundable tickets

• Prepaid phone cards

• Frequent flyer miles

• Merchandise points and similar loyalty or rewards programs

As a result, these property types are no longer expressly excluded from Arizona’s unclaimed property law.

Potential Compliance Impact

The repeal of Arizona’s B2B and de minimis exemptions may have a broad impact on many businesses. Companies that have historically excluded commercial credit balances or small-dollar liabilities from Arizona reporting may need to reassess their compliance practices. Likewise, retailers, hospitality companies, airlines, telecommunications providers, and other businesses that maintain gift card, stored value, or loyalty programs should evaluate whether these programs may now fall within the scope of Arizona’s unclaimed property requirements. Because Arizona’s unclaimed property statute does not establish specific dormancy periods for many of these newly covered property types, they may be subject to the statute’s general catchall provision, which presumes abandonment three years after the owner’s right to demand the property or the holder’s obligation to pay or distribute the property first arises. Additional guidance from the Arizona Department of Revenue would help clarify how these provisions will be administered.

Timing

The legislation becomes effective on September 12, 2026. While the precise reporting implications will depend on the applicable dormancy analysis and any future administrative guidance, the amendments are generally expected to first affect Arizona’s 2027 reporting cycle.

Recommended Next Steps

Organizations should consider:

• Identifying programs or liabilities previously excluded under Arizona’s B2B or de minimis exemptions

• Reviewing gift card, stored value, loyalty, and rewards programs for potential reporting implications

• Evaluating recordkeeping and reporting processes in anticipation of future compliance obligations

• Monitoring guidance issued by the Arizona Department of Revenue and any future legislative developments affecting the amended statute

Ryan’s Abandoned and Unclaimed Property professionals are monitoring these developments and are available to assist organizations in assessing the impact of these changes and preparing for future compliance requirements.

The material presented in this communication is intended to provide general information only and should solely be seen as broad guidance and not directed to the particular facts or circumstances of any individual who may read this publication. No liability is accepted for acts or omissions taken in reliance upon the content of this piece. Before taking (or not taking) any action, readers should seek professional advice specific to their situation from Ryan, LLC or other tax professionals.