On July 31, 2026, the Arizona Department of Revenue (Department) issued Unclaimed Property Ruling UPR 26-001 (Ruling), providing critical guidance on the effect of Arizona Senate Bill 1336 (SB 1336), which repealed three longstanding unclaimed property exemptions: the de minimis exemption, the business-to-business (B2B) exemption, and the gift card/stored value exemption. Because SB 1336 takes effect on September 12, 2026, but for this ruling, the legislative changes would not go into effect until Fall 2027 reporting.
What the Ruling Says
The Ruling is favorable to holders. Even though SB 1336 eliminated the B2B, de minimis, and gift card exemptions going forward, the Department has committed not to assert those categories as reportable in current or pending examinations, and not to accept remittances of such property. The Ruling makes clear that:
● Property that was not subject to Arizona’s unclaimed property law before September 12, 2026 does not become subject to it solely by reason of SB 1336’s repeal of the exemptions.
● The Department will not accept reports or remittances of the formerly exempt property. De minimis, B2B, and gift card/stored value property remain outside the reportable universe under the current framework.
● The Department will not audit for these categories. The Department will direct its contract auditors, including contingent-fee auditors, not to include the formerly exempt categories within the scope of any examination.
The Basis for the Department’s Ruling
Under Arizona’s constitution, a law can only address what its title describes and the title of SB 1336 says nothing about unclaimed property. The bill’s title is “state land department; continuation; oversight,” a routine sunset review of the State Land Department. It contains no reference to gift cards, B2B exemptions, or the definition of “property” under Arizona’s unclaimed property statute.
Because the repeal of the B2B, de minimis, and gift card exemptions has no natural connection to the State Land Department’s continuation and oversight, the only subject expressed in the title, the Department concludes that those unclaimed property amendments are constitutionally suspect and declines to give them operative effect.
It’s worth noting that the Ruling reflects the Department’s own administrative interpretation and does not carry the force of law. A court could ultimately reach a different conclusion. For now, however, the Department has made its position clear.
