Arizona requests preliminary unclaimed property reporting

Background

The APU has implemented an early review process for the annual reporting cycle ending Nov. 1, 2026. Beginning in mid-June 2026, the APU distributed notices to organizations that previously reported unclaimed property to Arizona, requesting submission of a preliminary NAUPA II report.

According to the APU, the purpose of this early review process is “to ensure a smoother final filing process and faster reunification of assets with their rightful owners.”

Primary considerations

Key considerations include the following:

• Participation is voluntary: There is no legal requirement under Arizona unclaimed property statutes or regulations to submit a preliminary report. The APU’s request is voluntary, and limited to data reporting. No funds, checks or other transfers are required.
• Cooperation is ‘highly encouraged’: Although voluntary, the APU has indicated that participation is highly encouraged. Holders should weigh this context when deciding whether to participate.
• No impact on annual requirements: Submission of a preliminary report does not relieve holders of their obligation to perform statutory due diligence under Arizona law and does not satisfy the annual reporting requirement. The APU notes that preliminary reports submitted in July may differ from the final report due Nov.

Data security considerations

The requested submission process raises data security considerations. The APU has requested that holders transmit NAUPA II report files—which contain personally identifiable information (PII) of property owners—via email. Although the APU refers to the submission address as its ‘secure Holder Reporting email,’ holders that elect to participate should consider using secure, encrypted email methods and consult with their information security teams to determine the appropriate transmission protocols before sending files containing PII.

Next steps

Given the voluntary nature of this request and the limited timeframe, holders should consider the following:

1. Assess readiness. Evaluate whether a preliminary NAUPA II file can be prepared accurately within the July 4, 2026, deadline (effectively Monday, July 6 due to the weekend and holiday), without affecting the quality of the final filing.
2. Maintain compliance and statutory reporting. Regardless of whether a holder submits a preliminary report, all statutory due diligence must be completed before Nov. 1, 2026. Holders must also complete and remit their full annual report by that date.
3. Exclude funds. The preliminary report is a data-only submission. Payment remains due only with the final annual report on or before Nov. 1, 2026.
4. Prioritize data security. If participating, consider a secure, encrypted email method when transmitting PII in the NAUPA II files.
5. Monitor developments. Holders should continue to monitor any further guidance from the APU regarding this process. Holders that receive a notice directly from the APU should retain a copy for their records.

Holders with questions about Arizona’s new preliminary report request or state unclaimed property obligations generally should speak to an unclaimed property adviser.