On June 13, 2026, Arizona’s unclaimed property program sent notices to holders requesting that a preliminary report be filed by July 4, 2026 — 120 days ahead of the state’s annual filing deadline.
The request raised questions across the holder and service provider community, largely because of its timing and the fact that it does not reflect any change in Arizona law.
What Changed, and What Didn’t
Arizona has not amended its statute to require a preliminary report. The state’s own website confirms the report is voluntary, not a legal requirement. Dunbar contacted Arizona directly and was told the same: filing is optional, and the goal is to let the state begin owner location work in parallel with a holder’s own due diligence process — not to add a new compliance obligation.
Holders who cannot meet the July 4 deadline were explicitly told by the state not to file the preliminary report. There is no penalty or follow-up requirement for sitting this one out.
Why the Timing Is a Problem
The notice landed two days before the California filing deadline and roughly two weeks ahead of the Michigan and Texas deadlines. For holders managing multi-state compliance calendars, a new voluntary request with a three-week turnaround — arriving in the middle of an already demanding filing season — is difficult to absorb regardless of whether it is mandatory.
Due Diligence Still Applies
Arizona was clear that filing a preliminary report does not relieve a holder of its statutory due diligence obligations. Whether or not a holder chooses to participate, the standard due diligence requirements ahead of the annual report remain unchanged and still need to be completed.
Bottom Line
This is a voluntary, one-time request from Arizona, not a new statutory requirement. Holders who have the bandwidth to file early can do so. Holders who don’t have time before July 4 are not at risk for skipping it, but should continue with normal due diligence and prepare for their annual filing on the standard timeline.
Holders with questions about their Arizona reporting obligations, or compliance generally, can contact Dunbar.
