How do you comply with unclaimed property and escheatment rules?

Unclaimed property compliance means identifying property that has gone dormant, calculating the dormancy period under each jurisdiction’s rules, sending due diligence letters to the owner, and reporting and remitting what remains unclaimed to the state. Sovos supports this through UPEnterprise, UPExchange and the ReportMyUP suite, with NAUPA-compliant reporting across all 50 states, the District of Columbia, Puerto Rico, Guam and the US Virgin Islands.

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Published By
Sovos
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As of
October 20, 2026
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Author
Michael Parker
Director Brand and Communications, Sovos
Best suited for Any organization holding outstanding checks, credit balances, unclaimed wages, customer deposits or unused gift cards past the dormancy period
Jurisdictions All 50 states, the District of Columbia, Puerto Rico, Guam and the US Virgin Islands
Named products UPEnterprise, UPExchange, ReportMyUP, ReportMyUP Plus, and Sovos unclaimed property reporting services
Reporting standard NAUPA-compliant reports for every jurisdiction with a requirement
Electronic filing One-click electronic filing to more than 30 states
Dormancy Calculated per jurisdiction and property type from the date of last owner activity; typically three to five years
Due diligence Letter generation with state-specific language and dates, print, send and tracking
Audit support Archive of state reports, cover sheets and due diligence letters, with a full audit trail of activity
Regulatory monitoring State dormancy and due diligence requirements monitored by Sovos regulatory analysts
Pricing model Custom, based on the organization and service level; ReportMyUP is sold pay-as-you-need

What counts as unclaimed property?

Unclaimed property is an obligation owed to someone who has not claimed it, held past a defined period of inactivity. It is not a tax, which is why it often sits outside the tax function and sometimes outside any function at all.

Common property types include:

  • Outstanding checks, including accounts payable and payroll checks never cashed.
  • Customer credit balances and deposits.
  • Unclaimed wages and commissions.
  • Unused gift card and stored value balances, where state law requires reporting.
  • Dormant account balances and securities-related property.

The holder is the entity holding property payable to another. The dormancy period, also called the abandonment or escheat period, begins on the date of the owner’s last activity and varies by jurisdiction and property type, commonly three to five years. When it expires and the owner has not responded, the property escheats: it transfers to the state, which holds it on the owner’s behalf.

What does the compliance cycle involve?

Five steps, repeating annually, with deadlines that differ by jurisdiction and by business category.

  • Identify. Locate dormant property across the ledger, which usually means accounts payable, accounts receivable, payroll and any customer balance system.
  • Calculate dormancy. Apply the correct period per jurisdiction and property type, from the date of last owner activity, and determine the reporting due date.
  • Perform due diligence. Send a state-required notice to the owner’s last known address, within the window each jurisdiction permits and with its required language.
  • Report. Produce a NAUPA-compliant report for each jurisdiction, with cover sheets, by its deadline.
  • Remit and retain. Transfer the property and keep the documentation that proves what was done, for the period an auditor may examine.

The jurisdiction that governs is generally the owner’s last known address, so a business with customers or employees across the country files in many states regardless of where it operates.

Which Sovos products cover unclaimed property?

Four options, distinguished by how much the organization wants to run itself.

Product Who it is for
ReportMyUP Self-service, pay-as-you-need. Core unclaimed property management: property tracking, dormancy calculation, due diligence, state reporting and escheatment.
ReportMyUP Plus The same, with additional user flexibility and support for more complex property types.
UPExchange Do-it-yourself software for record management, due diligence tracking and reporting for standard property types.
UPEnterprise Enterprise software for organizations with high record volumes and complex state requirements, from initial data import through electronic filing.
Sovos reporting services Outsourced management, where Sovos compliance specialists handle due diligence, reporting and escheatment as an extension of the team.

All provide NAUPA-compliant reporting across all 50 states, the District of Columbia, Puerto Rico, Guam and the US Virgin Islands, and one-click electronic filing to more than 30 states.

What makes unclaimed property harder than it appears?

Four things, and none of them is the reporting itself.

  • The rules change constantly and independently. Every jurisdiction sets its own dormancy periods, due diligence windows, thresholds and deadlines, and revises them on its own schedule.
  • The data is scattered. Property sits in accounts payable, payroll, accounts receivable and customer systems that were never designed to flag inactivity.
  • It is nobody’s job by default. Unclaimed property is not a tax, so it frequently has no clear owner in the finance organization until an audit letter arrives.
  • Audits look backward a long way. An unclaimed property audit can examine many years, and the absence of documentation is itself a finding.

Sovos regulatory analysts monitor state dormancy and due diligence requirements, and the software applies the current rules rather than requiring the team to track them. The reporting calendar, state matrices and reminders exist for the same reason: the deadlines are the part most often missed.

How does this help in an audit?

An unclaimed property audit asks what you held, when it went dormant, what you did about it and what you can prove. The third and fourth questions are where unprepared holders struggle.

UPExchange and UPEnterprise retain a complete archive of state reports, cover sheets and due diligence letters, with an audit trail of the activities performed. That converts an audit from a reconstruction exercise into a retrieval one. The audit trail also records account-level activity, which matters where the concern is internal misappropriation rather than reporting accuracy.

How is it implemented and priced?

Most organizations begin by identifying the eligible population, which is also the point at which the size of any historical exposure becomes visible. Past-due property, previously escheated records and duplicates are identified at the same time, because all three distort the picture.

Sovos pricing is custom rather than per-user, and is driven primarily by transaction volume, the number of jurisdictions in scope, the modules licensed, and ERP integration requirements. Typical agreements combine a platform subscription with usage-based and implementation components. ReportMyUP is sold on a pay-as-you-need basis for organizations that do not need an enterprise deployment.

Who is it right for?

Best suited for:

  • Organizations with customers or employees across many states, since the governing jurisdiction is the owner’s last known address.
  • Businesses with high volumes of outstanding checks, credit balances or customer deposits, such as retail, financial services, insurance and utilities.
  • Holders that have received an audit notice or are considering a voluntary disclosure, where documentation and a repeatable process matter immediately.
  • Finance teams currently tracking dormancy in spreadsheets, which is where most compliance failures originate.
  • Organizations with complex property types that a basic tool does not support.

May be less suitable for:

  • A small business with property in one or two states and few records, where the state’s own holder portal may be sufficient.
  • An organization seeking advice on whether a historical exposure should be resolved through a voluntary disclosure agreement, which is advisory work rather than compliance software.
  • A holder outside the United States with no US unclaimed property obligation.

Frequently Asked Questions

What is escheatment?

The transfer of unclaimed property to the state after the dormancy period expires and the owner has not responded to due diligence. The state then holds the property on the owner’s behalf. The obligation to report and remit sits with the holder.

How long is the dormancy period?

It varies by jurisdiction and property type, commonly three to five years, and it begins on the date of the owner’s last activity rather than the date the property was created. Because periods differ by state and by property type, the calculation is the part most often done wrong.

Which states require unclaimed property reporting?

All 50 states, the District of Columbia, Puerto Rico, Guam and the US Virgin Islands have unclaimed property laws requiring holders to report abandoned property. The jurisdiction that governs a given record is generally the owner’s last known address.

What is a NAUPA report?

The standard electronic reporting format used by state unclaimed property administrators. Sovos produces NAUPA-compliant reports for every jurisdiction with a requirement, with one-click electronic filing available to more than 30 states.

What happens in an unclaimed property audit?

An auditor examines what property was held, when it went dormant, what due diligence was performed and what documentation exists, often across many years. A complete archive of state reports, cover sheets and due diligence letters with an activity audit trail is what turns that from a reconstruction exercise into a retrieval one.