Leawood, Kan. – August 3, 2026: Recall our previous Card Alert that the Arizona Governor’s Office had issued a statement that striking the property exemptions in Senate Bill 1336 was an error. To view that Card Alert click here, July 24, 2026 Arizona Card Alert. In that Card Alert we anticipated that the Department of Revenue would be issuing formal guidance to confirm that no reporting would be required in November of 2026. That guidance has just been released. The Arizona Department of Revenue has issued advisory ruling UPR 26-001 (“Advisory Ruling”) to (1) provide guidance on the effects of SB 1336 on the definition of “property” in A.R.S. § 44-301(17)(b), and (2) provide clarity on the reporting and delivery obligations of holders of that property. The Advisory Ruling confirms that SB 1336 did not expand Arizona’s unclaimed property law and does not create new reporting obligations for Gift Cards or similar products.
The following is a summary of some key determinations in the Advisory Ruling:
1. No New Reporting Requirements: SB 1336 does not expand the scope of reportable property under Arizona’s unclaimed property law.
2. Gift Cards Remain Excluded: Gift certificates, electronic gift cards, non-refundable tickets, certificates evidencing property denominated in value other than currency, including stored value cards and similar products (collectively referred to herein as “Gift Cards”) remain excluded from the definition of reportable property.
3. No Reporting Required: Gift Cards should not be included in Arizona unclaimed property reports.
4. No Remittance Required: Gift Cards should not be remitted to Arizona, and the Arizona Department of Revenue will not accept remittances for them.
The Advisory Ruling also suggests there is potential penalty relief in the form of abatement of interest and penalties under A.R.S. § 44-333 for reasonable reliance on the Advisory Ruling.
We encourage any interested parties to read the Advisory Ruling in its entirety: July 31, 2026 Arizona Unclaimed Property Ruling.
NOTE: The Advisory Ruling and this Card Alert are provided for informational purposes only and do not constitute legal advice. Please review the disclaimers in the Advisory Ruling and consult counsel regarding the application of Arizona’s unclaimed property laws to your specific facts.
Card Compliant will continue to monitor for any additional updates on the rectification to SB 1336, as it pertains to the exemptions of the Arizona Unclaimed Property Law.
To read Arizona Bill 1336 that currently has the erroneous strikethrough, click here: Arizona Senate Bill 1336.
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