Fall 2025 Delaware unclaimed property update

On Aug. 15, 2025, Delaware mailed the second wave of unclaimed property voluntary disclosure agreement (VDA) notices for the 2025 calendar year. Holders not in compliance or holders who have not previously received an invitation should be aware of the state’s outreach as well as the potential to receive a Delaware verified report and compliance review request.

Delaware VDAs

Delaware’s biannual invitation to participate in the state’s unclaimed property VDA program has found its way to mailboxes once more, with Aug. 15 marking the second invitation circulation of 2025. Companies should be on alert for a letter from the Delaware Secretary of State’s office requesting their participation in the VDA program.

Typically, these invitations are addressed to someone in the C-suite or registered as a contact for a company with the Delaware Secretary of State. Each mailing cycle normally includes letters sent to hundreds of businesses, providing the recipient company with a 90-day window to respond and accept the invitation to enter the program. Companies that do not respond within 90 days will likely receive an audit notice at the end of the period. We advise companies to regularly check their physical mailboxes for receipt of such letters and be ready to respond promptly within this limited timeframe.

Historically, the invitations were sent to larger companies, but recent trends indicate that more middle-market companies are receiving the invitations as the state broadens its enforcement efforts. Any company legally domiciled in Delaware should be asking itself ‘when’ rather than ‘if’ it might receive a VDA invitation and proactively address any compliance gaps.

Responses to the Aug. 15 invitations are due by Nov. 13, 2025.

Delaware Verified Reports and Compliance Reviews

In addition to the VDA program, Delaware continues its unclaimed property enforcement efforts through the mailing of its Verified Report and Compliance Review notices. The notices often require less effort in comparison to the VDA, but failure to respond can also lead to a Delaware unclaimed property audit. For more information on these notices, please read our article Delaware ramping up unclaimed property enforcement actions.

Some companies that previously filed unclaimed property reports with Delaware are receiving verified report notices issued for their most recently filed report year. However, companies have also received these notices despite having never filed unclaimed property reports. In those circumstances, Delaware aims to verify that non-reporting companies genuinely have no unclaimed property to report to the state.

Holders receiving a Delaware VDA program invitation or a Verified Report and Compliance Review notice should reach out to their unclaimed property advisers immediately. For more information about RSM US’ unclaimed property services or further insights, visit the RSM abandoned and unclaimed property page.