DE Unclaimed Property Notices Expected Before Year-End

As 2025 draws to a close, Delaware continues to accelerate its unclaimed property enforcement efforts. Additional rounds of verified report and audit notices are anticipated before year-end. Businesses incorporated or operating in Delaware should remain vigilant – timely response is essential to avoid escalation.

Delaware notices to expect

Delaware’s enforcement initiative remains active, and affected organizations either received a voluntary disclosure invitation letter in mid-August or might receive a verified report notice or audit notice by year-end. Each type of notice carries distinct requirements and deadlines but all demand immediate attention.

Crowe observation

Regardless of which type of notice a company receives, responding promptly allows the company to maintain control and mitigate potential exposure.

Voluntary disclosure invitation letters

Companies that received voluntary disclosure invitation letters that were issued around Aug. 15, 2025, have 90 days to respond. Failure to respond within the timeframe – by around Nov. 15 – guarantees referral to audit.

Verified report notices

Following the campaign earlier this year, another wave of verified report notices is expected in the fourth quarter of 2025. Under Section 1170 of Delaware’s unclaimed property law, the verified report notice requires an officer of the company to attest to the accuracy of the company’s prior-year report.

• Response deadline: 30 days from the notice date (extensions may be requested).
• Next steps: Failure to respond can result in mandatory participation in the voluntary disclosure program or referral to audit.
• Policy documentation: Delaware will request a copy of your written unclaimed property policy and procedures.

Audit notices

Additional rounds of audit notices are anticipated throughout November and December 2025, particularly for companies that did not respond to the August voluntary disclosure invites. Delaware audits carry a 10-year lookback period and are conducted by third-party audit firms on behalf of the state. With a dormancy period of five years for most property types, that’s generally a review of 15 years of a company’s records. Additionally, Delaware unclaimed property reports are based on a year-end calendar, so the state is incentivized to commence examinations by Dec. 31.

Organizations currently under audit may wish to consider Delaware’s expedited audit program, which:

• Caps interest at 1% (versus a 20% minimum for standard audits)
• Requires completion within two years

These features can significantly reduce audit duration and cost.

Year-end action steps

To prepare for potential notices and minimize exposure, companies should:

• Monitor mail closely: Notices are issued via postal mail.
• Review historical filings: Confirm accuracy for 2024 and prior reporting years.
• Organize documentation: Make sure unclaimed property records are readily accessible.
• Respond promptly: Missed deadlines could trigger audits or forfeiture of more favorable options.
• Engage advisers early: Professional guidance can help assess risk and determine the most effective response strategy.

Looking ahead

Delaware’s anticipated pre-year-end enforcement surge reinforces its ongoing focus on identifying noncompliance. Companies that proactively review their reporting history, update documentation, and prepare for possible contact will be best positioned to manage risk, maintain compliance, and reduce exposure entering 2026.