Arizona Department of Revenue Clarifies Administration of SB 1336 Following Unclaimed Property Amendments.

On July 29, 2026, Ryan published the tax development, “Arizona Expands Scope of Unclaimed Property Law by Eliminating Key Statutory Exemptions,” analyzing the potential impact of Arizona’s enactment of SB 1336. On July 31, 2026, the Arizona Department of Revenue (ADOR) issued Unclaimed Property Ruling UPR 26-1, providing important administrative guidance regarding the Department’s interpretation and administration of the legislation.

In UPR 26-1, ADOR concluded that the statutory amendment resulted from a drafting anomaly and does not expand the categories of property subject to Arizona’s Unclaimed Property Act. The Department relied on Arizona’s constitutional single-subject rule, explaining that SB 1336 was enacted as legislation relating to the Arizona State Land Department and was not intended to substantively amend Arizona’s unclaimed property law. As a result, organizations are not required to modify their current Arizona unclaimed property reporting practices based on SB 1336 at this time.

ADOR’s Position

According to the ruling, ADOR will continue administering Arizona’s unclaimed property law in accordance with its historical practice. The Department concluded that the following categories remain outside the scope of Arizona’s Unclaimed Property Act:

• Business-to-business (B2B) property arising from a current business relationship

• De minimis property

• Gift certificates

• Electronic gift cards

• Stored value cards

• Nonrefundable tickets

• Prepaid phone cards

• Frequent flyer miles

• Merchandise points and similar loyalty or rewards programs

Practical Effect for Holders

The ruling states that ADOR will not:

• Require holders to report or remit property in these categories;

• Accept reports or remittances for property in these categories; or

• Include these categories in unclaimed property examinations, including examinations conducted by contingent-fee auditors.

Accordingly, organizations should continue administering their Arizona unclaimed property compliance programs consistent with ADOR’s published guidance.

Looking Ahead

UPR 26-1 provides important administrative guidance regarding ADOR’s current interpretation of SB 1336. Organizations should continue monitoring future legislative and administrative developments affecting Arizona’s unclaimed property law. There is an expectation among interested parties that legislation will be introduced during the next session of the Arizona Legislature to correct this drafting anomaly.

Ryan’s Abandoned and Unclaimed Property professionals will continue to monitor this issue and provide updates as additional guidance becomes available.

The material presented in this communication is intended to provide general information only and should solely be seen as broad guidance and not directed to the particular facts or circumstances of any individual who may read this publication. No liability is accepted for acts or omissions taken in reliance upon the content of this piece. Before taking (or not taking) any action, readers should seek professional advice specific to their situation from Ryan, LLC or other tax professionals.