This blog was last updated on May 27, 2026
Delaware recently sent out another round of Verified Report requests, addressed to Tax/Escheat Departments, with the subject line Notice Requesting Verified Reports for Report Year 2025*. Even if you’ve been through a Delaware audit before—or completed the Voluntary Disclosure program—this notice can still land on your desk. As in prior rounds, Delaware is using four third-party firms (Kelmar, Specialty Audit Services, Discovery Audit Services, and Escheatment Experts Consulting Services) to handle the review work tied to the Verified Report process.
The biggest takeaway: respond quickly. The notice gives companies 30 days from the date of the letter to reply. If you need more time, it’s worth reaching out to the firm managing your request as soon as possible to confirm receipt and ask for an extension. Delaware’s FAQ notes that requested information should be provided no later than 180 days from the date of the notice to allow time for review and completion. Missing the deadline can trigger referral to the Secretary of State’s Voluntary Disclosure Agreement Program under 12 Del. C. § 1173, or additional enforcement action under 12 Del. C. § 1172(d)(4).
What are the details of Delaware’s Verified Report Requests?
So what, exactly, does Delaware expect you to submit as part of the Verified Report process? Here’s the checklist:
- Complete the “Verified Report for Report Year 2025” form. For most holders and business associations (other than banking organizations and insurance companies), Delaware reports were due March 1, 2026 for property meeting dormancy as of December 31, 2025 (see industry notes below). A company officer must attest under oath—via notarized signature—that the Verified Report and any enclosures are true, correct, and complete.
- Insurance industry: Delaware may request a Verified Report for Report Year 2024, since insurance companies typically report by December 20, 2025 for property meeting dormancy as of December 31, 2024.
- Banking organizations: Delaware reports are generally due November 10 for property meeting dormancy as of June 30 of the applicable period.
- Include Attachment A (Legal Entities list). Attachment A should list all legal entities included in the 2025 report (or 2024, if insurance). If you file a consolidated report, be sure to include every subsidiary and related entity covered under the filing entity. =
- Confirm whether you have written policies and procedures. If they exist, Delaware asks that you include a copy so the reviewer can evaluate them and offer recommendations.
Once you’ve gathered the items above, the Verified Report also requires you to certify one of the following statements applies to your company:
a. The company did not have any property to report to Delaware.
Note: Delaware modified the 2025* form to include a line that allows companies to document whether a negative** or $0 report was filed—and the date it was filed.
b. You submitted a report that included property—provide the submission date, a copy of the “Holder Summary Demonstrating Report Successfully Submitted for Processing”***, and proof of payment.
c. You reported property for the period but later identified additional property to report—include the original submission date.
d. You did not report property for the period, but you have property to report—state when you will file the report.
One detail that’s easy to miss: the cover letter now states, “Please note that this includes any property, including equity related property, reported on behalf of the holder by a transfer agent or third party.” Because the Verified Report package is limited, this can be tricky—especially for publicly traded companies where transfer agents often file equity-related items on a consolidated Delaware report.
Given the confidential nature of what you may be sharing, you may also want to consider putting a Non-Disclosure Agreement in place with the third-party firm assigned to your request. While personally identifiable information typically does not need to be provided, Attachment A and your policies/procedures can contain sensitive, non-public details.
Looking ahead, Delaware has indicated the Verified Report process will be annual, with notices typically going out each summer. If you receive a notice, you can generally expect another request about 4–5 years later. The best way to make the next one easier is to stay compliant every year, and to document your policies and procedures for identifying, tracking, and reporting unclaimed property (especially helpful when teams and responsibilities change). If you’d like support building or refreshing those procedures, Sovos’ unclaimed property consulting team can help.
*Depending on the company’s industry, the form may reference 2024 or 2025.
**While negative reports are not required, Sovos recommends submitting a negative report if the company reviewed its records and determined nothing is due for the period under review to demonstrate ongoing compliance with Delaware’s requirements.
***Sovos recommends including the Holder Summary and Proof of Payment rather than the detail report to protect property owner information.