Unclaimed property voluntary disclosure programs for businesses

What a voluntary disclosure program does

When a business holds property for an owner and there has been no activity or contact for a set period, called the dormancy period, the law requires it to turn the property over to the state.¹⁷ Late reports cost money. California charges 12% interest a year from the date the property should have been reported, unless the failure had reasonable cause;¹⁸ Kansas adds a civil penalty of 25% of the value for willful failure to pay or deliver.¹⁹

A voluntary program is the state’s offer to settle that past liability on easier terms. The names vary (voluntary disclosure agreement, voluntary compliance program, compliance assistance program), but the deal is similar: the business reviews its own records for a set number of past years, reports and pays what it finds, and the state waives some or all interest and penalties. Virginia, for example, says penalties and interest “will be waived for property reported and remitted to Virginia through the program”.⁴ North Dakota describes its program as “an opportunity for businesses to come into compliance without a formal examination”.²

Programs by state

The table lists the states whose own pages describe how they handle voluntary filings. For any other state, its unclaimed property office can say whether it accepts voluntary filings; the contacts page lists each office.

Who can use a program

Most programs listed here are closed once an audit is underway or announced:

• Utah and Virginia exclude holders under audit or notified of an upcoming audit by the office or its contracted auditors.³⁴
• North Dakota excludes any business sent an official notice of examination,² and Delaware any business to which the State Escheator has mailed one.¹
• West Virginia excludes holders under audit by any state, not only its own.¹²
• Florida’s program is only for holders that have not filed an annual report or agreed to a self-audit.¹¹

Several states also limit repeat use. California excludes holders that had interest waived under its program in the past five years, unless the property comes from an acquisition or merger.¹⁵ Pennsylvania excludes holders granted voluntary compliance in the past 10 years,⁶ and Utah accepts first-time participants only, unless the property type is new or comes from a merger or acquisition.³

How far back the review goes

The look-back is the number of past years the business must review. Ten years is the most common:

Where records are missing, programs may expect an estimate: Delaware expects enrollees with Delaware entities “to reasonably estimate liabilities” for periods and entities without records.¹³

Delaware’s voluntary disclosure program

Delaware’s program matters to far more businesses than operate there. Under the Supreme Court’s rules, when an owner’s address is unknown, or the state of that address has no law to take the property, it goes to the business’s state of incorporation.³² The Secretary of State concludes that “most if not all Delaware legal entities” are likely to owe Delaware some unclaimed property, even with no operations, vendors or customers in the state.¹³

How it works, from the statute and the Secretary of State’s program pages:

• Who runs it. Under section 1173 of Title 12 of the Delaware Code, the program is “solely administered by the Delaware Secretary of State”; the Office of Unclaimed Property no longer accepts new submissions.⁸
• Invitations. The Secretary of State may invite a business to enter; if the enrollment form is not received within 90 days, the business is referred for examination.¹ As a general rule, Delaware does not start a new examination unless the business was first told in writing that it may enter the program.¹
• Enrolling. A business can also enroll on its own by signing Form VDA-1.¹³
• The work. The business scopes its entities and property types, quantifies what it owes, presents its findings for validation, and then signs the closing agreement; payment is due within 10 days of the demand letter.³³
• Time limit. At most 2 years from enrollment.¹³¹
• What it gives. Interest and penalties are waived for holders that complete the disclosure in good faith.¹ The Secretary of State lists protection from audit and indemnification against other states and claimants for the entities, property types and years included.⁹ The audit waiver holds as long as the business files its annual reports for the next three reporting cycles.¹³
• Who cannot enter. A business that has already been mailed a notice of examination (apart from an option to convert that examination into a program review), or that withdrew from or was removed from the program.¹

Outside the program, Delaware’s Office of Unclaimed Property says its current policy is “to waive, or not impose, interest and penalties on voluntarily filed property, even if filed late”, but it gives no written waivers; the VDA is the only way to get a statutory or guaranteed waiver.³⁴

What a program does not do

A completed program settles the past years it covers; it does not end the duty to report. Virginia expects continued annual reporting when there is something to report,⁴ and Delaware’s audit protection depends on the next three annual reports.¹³

The Secretary of State describes this audit waiver as unlike most other state programs.¹³ Kansas says its program “does not protect your business from an audit”;⁵ Alaska says its process does not exempt holders from compliance or verification audits.¹⁶ South Dakota keeps the right to audit, and counts the payment under the agreement toward any audit findings.¹⁰

A program can also be limited to one state’s property: Florida’s takes only property due to Florida and accepts none on behalf of another state.¹¹ The business reporting guide explains which state gets each item, and the reporting deadlines table lists each state’s annual dates.

The usual steps

1. Check eligibility with the state’s own page: no audit underway or announced, and any limits on past participation.³⁶
2. Apply or sign the agreement. Utah, for example, reviews the signed form and countersigns it once the holder is found eligible;³ Pennsylvania asks that no report be filed until it has given formal written approval.⁶
3. Review the records for the look-back period and every property type, including those with short dormancy periods such as wages.⁷
4. Report and pay by the program’s deadline: within 90 days in Pennsylvania,⁶ six months in Virginia,⁴ one year in Oklahoma.²⁹
5. Keep filing every year after the program ends.⁴

Next step

Check the state’s row in the table above, then contact its unclaimed property office before you file. Virginia’s program also calls for due diligence,⁴ so see due diligence letters for the state rules. Years with nothing to report are covered in negative reports.

Questions people ask

What is an unclaimed property voluntary disclosure agreement?

An agreement with a state under which a business reviews its past records, reports and pays the unclaimed property it finds, and in return the state waives some or all interest and penalties; Pennsylvania's agreement, for example, waives "all applicable penalties and interest" for property reported within its terms.⁶

Can a business use a voluntary disclosure program during an audit?

Generally not. Utah and Virginia exclude holders under audit or notified of one,³⁴ North Dakota excludes businesses sent a notice of examination,² and West Virginia excludes holders under audit by any state.¹²

How far back does an unclaimed property VDA go?

In most of the programs listed here, 10 years: 10 report years in Delaware and Kansas,¹³⁵ 10 years in Pennsylvania.⁶ Utah uses 5 reportable years⁷ and Arkansas 6 years.¹⁴

Does the Delaware VDA protect against an audit?

Yes, for the entities, property types and years included,⁹ as long as the business keeps filing its annual reports for the next three reporting cycles.¹³ A business already mailed a notice of examination generally cannot enter.¹

Are interest and penalties always waived?

Not in every program. California waives interest for enrolled holders that meet all program requirements;¹⁵ Kansas says the Treasurer has discretion to waive them;⁵ Alaska says it "will often" waive them.¹⁶

Sources

Footnote numbers point here. Open "Quoted text" for the exact words relied on ("[…]" marks words left out).

1. Delaware Code Title 12, Chapter 11, Subchapter II. Unclaimed Property (§§ 1130-1191) Delaware General Assembly / Delaware Code Online · delcode.delaware.gov · current Delaware Code Online text (latest session law cited: 84 Del. Laws c. 368, 2024) · checked Nov. 3, 2026
   Quoted text (7)

   (1) The Secretary of State shall waive interest and penalty under §§ 1183 and 1184 of this title for holders that complete the voluntary disclosure in good faith.

   If the form indicating the person’s intent to enter into a voluntary disclosure agreement is not received by the Secretary of State by certified mail or by other means deemed acceptable by the Secretary of State within 90 days after the request to enter the voluntary disclosure agreement program was delivered, the Secretary of State shall refer the person to the State Escheator for examination under § 1171 of this title.

   (a) Effective July 1, 2015, and subject to subsection (d) of this section, the State Escheator shall not initiate any new examination of records or an investigation of any person under this section unless the person has first been notified in writing by the Secretary of State that the person may enter into an unclaimed property voluntary disclosure agreement

   the person shall enter an unclaimed property voluntary disclosure agreement and make payment in full or enter into a payment plan within 2 years from the date the person’s intent to enter into an unclaimed property voluntary disclosure agreement was accepted by the Secretary of State.

   the person under such an examination may notify the State Escheator and the Secretary of State of the person’s intent to convert the pending examination into a review under the Secretary of State’s voluntary disclosure program

   (3) A person to which a notice of examination has been mailed by the State Escheator, except those persons that elect to enroll in the Secretary of State’s unclaimed property voluntary disclosure program under § 1172(b) of this title.

   a. The person formally withdrew from the voluntary disclosure agreement program. b. The Secretary of State removed the person from the voluntary disclosure agreement program for failure to work in good faith to complete the voluntary disclosure agreement program as soon as practicable.

2. Voluntary Disclosure (VDA) ND Dept. of Trust Lands, Unclaimed Property Division · unclaimedproperty.nd.gov · checked Nov. 3, 2026
   Quoted text (3)

   Any business that has been sent an official notice of examination is NOT eligible to participate in the VDA.

   Those eligible include first-time reporters of unclaimed or abandoned property and businesses who believe they may not be in compliance with N.D.C.C. ch. 47-30.2.

   It is an opportunity for businesses to come into compliance without a formal examination.

3. Voluntary Disclosure Agreement Utah Office of State Treasurer · mycash.utah.gov · checked Nov. 3, 2026
   Quoted text (4)

   The Holder is not currently under audit by our office or one of our contracted auditors.

   The Holder has not been notified of an upcoming audit by our office or one of our contracted auditors.

   The Holder is a first-time participant in the program. This provision is waived if the property type is new or associated with the merger or acquisition of a new company.

   Once received, the State will review the application to make sure the Holder is eligible. Once approved, the State will sign and date the VDA form

4. Voluntary Compliance Program Virginia Department of the Treasury · vamoneysearch.gov · checked Nov. 3, 2026
   Quoted text (5)

   The holder is not currently under audit by our office or one of our contracted auditors.

   The holder has not been notified of an upcoming audit by our office or one of our contracted auditors.

   Conduct a self-review, perform due diligence, and remit the findings within six months of the execution of the participation request form.

   The self-review will cover the ten preceding report years. Continued annual reporting is expected when there is something to report.

   Applicable penalties and interest will be waived for property reported and remitted to Virginia through the program.

5. Kansas Voluntary Compliance Program Agreement Kansas State Treasurer · missingmoney.ks.gov · checked Nov. 3, 2026
   Quoted text (3)

   *Look-back period is 10 reporting years.

   Participation in this program does not protect your business from an audit.

   The administrator shall have discretion to waive the payment of penalties & interest as described in KSA 58-3967 for businesses agreeing to participate in Kansas' Voluntary Compliance Program.

6. Voluntary Disclosure Agreement for Reporting Unclaimed Property Pennsylvania Treasury Department · searchandclaimpa.gov · checked Nov. 3, 2026
   Quoted text (6)

   To report all past due unclaimed property identified through a complete examination of its books and records for the last ten years.

   To file a report within ninety (90) days of the execution of this agreement directly with the Treasury Department.

   To waive all applicable penalties and interest, as permitted under § 1301.24 and 1301.25 of the PA Unclaimed Property Law, for the reported property, if the property is reported within the terms of this agreement.

   Holder has not been granted voluntary compliance or participated in Treasury’s Compliance Review Program in the past 10 years.

   Holder is currently not under audit or self-audit by Pennsylvania Treasury for past due unclaimed property reporting, and

   **Please note that a holder report and remittance must not be submitted until after Treasury has provided a formal, signed approval as recognition for admittance into the Voluntary Compliance Program.

7. Holder Reporting Guide, 2026 Reporting Instructions Utah Office of State Treasurer · mycash.utah.gov · 2026 · checked Nov. 3, 2026
   Quoted text (2)

   To report all unclaimed property identified through a complete audit of its books and records for the last five (5) reportable years. This includes property with last activity dates that fall within the applicable dormancy periods for each property type, including shorter periods for items such as wages and commissions.

   To file a report within ninety (90) days of the execution of this agreement directly with the Unclaimed Property Division.

8. Voluntary Disclosure Program Delaware Department of Finance, Office of Unclaimed Property · unclaimedproperty.delaware.gov · checked Nov. 3, 2026
   Quoted text (2)

   Per 12 Del. C. sec. 1173, the Delaware Unclaimed Property Voluntary Disclosure Agreement Program is now solely administered by the Delaware Secretary of State (SOS VDA Program).

   The Office of Unclaimed Property, Department of Finance (formerly Division of Revenue and/or Bureau of Abandoned or Unclaimed Property), no longer accepts new Voluntary Disclosure Agreement Program submissions.

9. Abandoned or Unclaimed Property VDA Program (home page, archived copy) Delaware Department of State (Secretary of State) · vda.delaware.gov · archived copy, captured Oct. 1, 2026 (view capture) · checked Nov. 3, 2026
   Quoted text (1)

   Upon completion of the program, Holders obtain a settlement agreement that allows for: a waiver of interest and penalties protection from audit indemnification against other states and claimants for all entities, property types, and years included in their SOS VDA.

10. Voluntary Disclosure Program South Dakota State Treasurer – Unclaimed Property Division · southdakota.findyourunclaimedproperty.com · checked Nov. 3, 2026
    Quoted text (2)

    The holder must not be under audit by South Dakota, either directly or by third party audit firms. Under terms of the voluntary disclosure program all penalties and interest associated with amount remitted will be waived. South Dakota retains all rights and authority to request an audit or examination of the holder records.

    If South Dakota requests an audit or examination of years reported for the property types included in this report, the payment received under the voluntary disclosure agreement will apply to the findings of the examination.

11. Chapter 69G-20, Florida Administrative Code (Unclaimed Property) - compiled rules PDF Florida Department of Financial Services · myfloridacfo.com · checked Nov. 3, 2026
    Quoted text (4)

    (b) Penalties and fines are not assessed by the Department.

    (2) To participate in this program, the Holder must not: (a) Be currently under examination or audit; (b) Have filed an annual report of unclaimed property with the Department; (c) Have agreed to a Department-assisted or Contractor-assisted self-audit;

    (e) Have been notified by the Department or by one of the Department’s contract auditors of the intention or desire to conduct an examination or audit of the Holder.

    (3) The property to be disclosed must be unreported and unremitted unclaimed property due to the State of Florida. No property will be accepted on behalf of another state.

12. Guidelines for Preparing Unclaimed Property Reports West Virginia State Treasurer's Office, Unclaimed Property Division · wvunclaimedproperty.gov · Revised August 2023 · checked Nov. 3, 2026
    Quoted text (1)

    Please note, in order to be considered for a voluntary compliance program, the holder must not be under audit by West Virginia or any other state.

13. Frequently Asked Questions, Abandoned or Unclaimed Property VDA Program (archived copy) Delaware Department of State (Secretary of State) · vda.delaware.gov · archived copy, captured May 18, 2026 (view capture) · checked Nov. 3, 2026
    Quoted text (7)

    The look-back period is 10 report years (or 15 transaction years as Delaware has a 5 year dormancy period for most property types) from the date the Holder enrolls in the VDA.

    The Secretary of State expects every VDA enrollee with Delaware domicile entities to reasonably estimate liabilities for periods and entities where records are not available to determine a Holder’s unclaimed or abandoned property.

    Therefore, it is likely that most if not all Delaware legal entities would have some unclaimed property due and payable to the State of Delaware, even if that legal entity has no operations, vendors or customers in Delaware.

    A Holder enrolls in the SOS VDA Program by executing Form VDA-1 – Notice of Intent to Voluntarily Comply with Abandoned or Unclaimed Property Law

    Pursuant to Delaware law, the maximum time allotted to complete the SOS VDA Program is 2 years from the date of enrollment.

    Unlike most other state VDA programs, for Holder’s that complete the SOS VDA program, the State waives its right to examine the Holder related to the entities, years, and property types included in the SOS VDA.

    This waiver is effective as long as the Holder fulfills its future annual reporting requirements for the three subsequent reporting cycles after the completion of the SOS VDA.

14. Arkansas Unclaimed Property Administrative Rules, 18 CAR § 21-101 et seq. (final) Arkansas Auditor of State · auditor.ar.gov · 11/03/2025 (effective Nov. 3, 2025) · checked Nov. 3, 2026
    Quoted text (2)

    Conduct a complete examination of the holder’s, the holder’s subsidiaries’, or other related entities’, books and records for the six (6) years immediately prior to participation;

    within one hundred eighty (180) days after the holder enters the voluntary disclosure program.

15. Voluntary Compliance Program (VCP) California State Controller's Office, Unclaimed Property Division · claimit.ca.gov · checked Nov. 3, 2026
    Quoted text (2)

    Approved and enrolled holders that fulfill all program requirements, including completing a training program and meeting reporting deadlines, will be eligible for waived interest on past-due unclaimed property reported under the program.

    The holder has not had interest waived under the Voluntary Compliance Program within the past five years or is applying to resolve unclaimed property related to an acquisition or merger.

16. Holder Reporting Handbook Alaska Department of Revenue, Treasury Division · unclaimedproperty.alaska.gov · Eff. 8.15.2025 · checked Nov. 3, 2026
    Quoted text (2)

    The State of Alaska will often waive penalty and interest during this process.

    The voluntary compliance process does not exempt holders from compliance or verification audits.

17. What is unclaimed property? National Association of Unclaimed Property Administrators (NAUPA) · unclaimed.org · checked Nov. 3, 2026
    Quoted text (1)

    After a designated period of time (called the dormancy period) with no activity or contact, the property becomes “unclaimed” and—by law—must be turned over to the state.

18. Unclaimed Property Law and Regulations (official SCO compilation of Code of Civil Procedure section 1500-1582 and 2 CCR 1150 et seq.) (PDF) California State Controller's Office · sco.ca.gov · February 2026 · checked Nov. 3, 2026
    Quoted text (2)

    any person who fails to report, pay, or deliver unclaimed property within the time prescribed by this chapter, unless that failure is due to reasonable cause,

    shall pay to the Controller interest at the rate of 12 percent per annum on that property or value thereof from the date the property should have been reported, paid, or delivered.

19. K.S.A. 58-3967. Interest and penalties Kansas Office of Revisor of Statutes · ksrevisor.gov · K.S.A. current as published Nov. 3, 2026; last amended L. 2014 · checked Nov. 3, 2026
    Quoted text (1)

    (c) A person who willfully fails to pay or deliver to the administrator any unclaimed property as required by this act shall pay a civil penalty equal to 25% of the value of the property that should have been paid or delivered.

20. Voluntary Disclosure Agreement Alabama Unclaimed Property · unclaimed.alabama.gov · checked Nov. 3, 2026
    Quoted text (1)

    In an ongoing effort to assist businesses with compliance, the State of Alabama does offer an amnesty program (Voluntary Disclosure) for businesses reporting past due unclaimed property. Once executed, this agreement establishes a mutual consent which allows the business to report and remit past due unclaimed property and comply with state statues without concern of interest and penalties for the property associated with the agreement.

21. Voluntary Disclosure Agreement (PDF) Alabama State Treasury, Unclaimed Property Division · unclaimed.alabama.gov · checked Nov. 3, 2026
    Quoted text (2)

    the Holder will be expected to examine records, prepare and file unclaimed property which would have been due and payable during the course of the most recent 10 reporting years, at the minimum.

    The preferred time period for filing this report is within 90 days of the effective date of this VDA. However, the Holder may request a filing deadline not to exceed 6 months from the effective date.

22. Report Unclaimed Property (holder FAQ) Arkansas Auditor of State · auditor.ar.gov · checked Nov. 3, 2026
    Quoted text (1)

    As an ongoing effort to promote compliance with Unclaimed Property law, the Office of the Auditor of State offers three voluntary filing programs to any holder not currently under audit or in receipt of an audit commencement letter from this office.

23. FAQs: Holder Reporting Connecticut Office of the Treasurer, Unclaimed Property Division · ctbiglist.gov · Revised: June 2025 · checked Nov. 3, 2026
    Quoted text (1)

    Connecticut does not have a formal Voluntary Compliance process.

24. First Time Filers: Reporting Instructions Connecticut Office of the Treasurer, Unclaimed Property Division · ctbiglist.gov · Revised: January 2026 · checked Nov. 3, 2026
    Quoted text (2)

    please include a letter, on company letterhead and signed by an officer, stating your company would like to become compliant with unclaimed property reporting in Connecticut and formally request any interest or penalties be waived for voluntary compliance.

    An unclaimed property report should be submitted for all past due property – a look back period of 10 years, same as our audit process, is recommended.

25. Voluntary Disclosure Agreement Treasurer of State of Iowa · greatiowatreasurehunt.gov · checked Nov. 3, 2026
    Quoted text (1)

    The State of Iowa is currently not accepting VDA applications.

26. Iowa Administrative Code 781—Chapter 9, Unclaimed Property Iowa Legislature · legis.iowa.gov · IAC chapter 9 as published 04-15-2026 (rule 9.43 eff. 2/26/25) · checked Nov. 3, 2026
    Quoted text (1)

    9.43(3) The division will not impose any interest or penalties for property reported under an approved VCSA submission.

27. Voluntary Disclosure Program Office of the Maine State Treasurer · maineunclaimedproperty.gov · checked Nov. 3, 2026
    Quoted text (2)

    Maine does not have a formal voluntary compliance program at this time but we do review requests on an individual basis.

    Permission for voluntary disclosure reporting is generally granted based on the disclosure request and the holder not currently or about to be under audit.

28. Voluntary Disclosure Agreement (VDA) Comptroller of Maryland · claimitmd.gov · checked Nov. 3, 2026
    Quoted text (1)

    This VDA program only applies if we have not previously contacted you in reference to the unclaimed property.

29. Unclaimed Property Compliance Assistance Program Oklahoma State Treasurer · oklahoma.gov · Last modified Oct 06, 2026 · checked Nov. 3, 2026
    Quoted text (1)

    we offer a Compliance Assistance Program to give companies up to one year to meet the legal requirements for unclaimed property reporting. By participating in the program, businesses can avoid paying penalties and interest.

30. Compliance Assistance Program Commitment Form Oklahoma State Treasurer · oklahoma.gov · checked Nov. 3, 2026
    Quoted text (2)

    The look back period (the time for which the holder is expected to review and report unclaimed property) for this program is a maximum of ten (10) years.

    If compliance is achieved by the commitment date, no penalties and interest will be assessed by the Treasurer.

31. Voluntary Compliance Disclosure Wyoming State Treasurer's Office, Unclaimed Property Division · statetreasurer.wyo.gov · Last Updated: 09/19/2019 · checked Nov. 3, 2026
    Quoted text (1)

    Holders that have been granted an “informal voluntary disclosure” will not be subject to penalty.

32. Delaware v. Pennsylvania, 598 U.S. 115 (2023), opinion Supreme Court of the United States · supremecourt.gov · Feb. 28, 2023 · checked Nov. 3, 2026
    Quoted text (2)

    either because the creditors' addresses were unknown or because the State that is entitled to escheatment under the primary rule did not have a law empowering it to take custody of the proceeds.

    adopted a secondary rule to apply in those circumstances; namely, that the proceeds should escheat to the debtor's State of incorporation.

33. Steps to VDA (archived copy) Delaware Department of State (Secretary of State) · vda.delaware.gov · archived copy, captured April 10, 2026 (view capture) · checked Nov. 3, 2026
    Quoted text (2)

    The Holder will have 10 days to make payment of the amount due.

    During Phase 2, the Holder will review its books and records to identify/quantify past-due abandoned or unclaimed property reportable to Delaware for the in-scope entities and property types.

34. FAQs: Reporting Property Delaware Department of Finance, Office of Unclaimed Property · unclaimedproperty.delaware.gov · checked Nov. 3, 2026
    Quoted text (3)

    The current administrative policy of the State Escheator is to waive, or not impose, interest and penalties on voluntarily filed property, even if filed late. The State Escheator / Office of Unclaimed Property do not provide written waivers; please do not request them.

    If a holder wishes to obtain a statutory waiver or guarantee of a waiver of interest and penalties, the holder may enter the Voluntary Disclosure Agreement Program

    as this is the only vehicle currently available for a statutory or guaranteed waiver.