Recently, the first wave of Delaware unclaimed property voluntary disclosure agreement (VDA) notices were mailed this year. Unclaimed property holders that receive an invitation should be prepared to respond, especially with an increase in invitations sent to mid-market and lower mid-market companies. Holders should also be aware of Delaware verified report and compliance review requests.
On April 11, 2025, Delaware mailed Delaware unclaimed property holders an initial circulation of invitations to the Delaware Unclaimed Property Voluntary Disclosure Agreement (VDA) program. Companies should be vigilant 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. Delaware usually mails hundreds of letters in each mailing cycle and provides the recipient company a 90-day window to respond and accept the invitation to enter the program. Companies that do not respond within the 90 days will likely receive an audit notice at the end of the period, and therefore a prompt response is encouraged.
Traditionally, these invitations were mailed to larger companies. However, in recent cycles, we have observed an increase in invitations received by mid-market and lower mid-market companies – an indication that the state’s unclaimed property enforcement efforts are expanding.
Responses to the April 11, 2025 invitations are due by July 10, 2025. Looking ahead, Delaware’s next round of unclaimed property VDA invitations are scheduled for Aug. 15, 2025.
Delaware is expected to continue its unclaimed property enforcement efforts through the mailing of its Verified Report and Compliance Review notices throughout 2025. These notices initially require a lesser effort in comparison to the VDA program, but failure to respond can also lead to a Delaware unclaimed property audit. Please read our article, Delaware ramping up unclaimed property enforcement actions, for more information and background on these notices.
Many companies that filed unclaimed property reports with Delaware are receiving notices for their most recently-filed report year. However, we have also observed companies receiving verified report notices despite not having filed any Delaware unclaimed property reports. In these 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’s unclaimed property services or further insights, visit the RSM US unclaimed property page.
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