Important 2024 Compliance Reminder: Illinois Unclaimed Property

Apr 24, 2024

By Quinn Harris, CPA, Partner

The Illinois Treasurer requires all businesses and not-for-profits to file annual unclaimed property reports. These reports are due May 1st. Even if an entity is not holding any unclaimed property, it must still file a negative (no unclaimed property) report. The unclaimed property report and any related payment are due May 1st of each year. The report due May 1, 2024 covers activity for the period January 1, 2020 through December 31, 2020.

Unclaimed property must be reported and remitted to the state. Examples of unclaimed property include uncashed payroll checks, customer overpayments, uncashed/voided checks to vendors, and gift cards/certificates with an expiration date. Uncashed payroll, commission, bonus, and reimbursement checks, or other compensation for personal services must also be reported.

Submission Details:  All submissions must be made online via the Illinois State Treasurer’s Office (ISTO) reporting portal. It’s important to use the NAUPA II format for these submissions. For detailed guidance on how to submit a report and file online at

About Audits and Record-Keeping:  The ISTO can conduct compliance audits going back as far as 13 years for entities that have not filed or might have underreported. Such audits may involve ISTO staff or third-party agencies, emphasizing why it’s crucial to keep detailed and accurate financial records.

Voluntary Disclosure Agreement (VDA) Program:  If you uncover any past compliance oversights, the ISTO’s VDA program is available. This program allows you to report unclaimed property voluntarily without penalties or interest, assuming your business isn’t currently under examination. It’s a fantastic opportunity to rectify past oversights and avoid potential fines.

Subject to Other State Unclaimed Property Filing Requirements:  If you conduct business in multiple states, you may also have unclaimed property filing requirements in those states. All 50 states and the District of Columbia have unclaimed property laws.

How Can We Help?  The MichaelSilver professionals have extensive experience assisting clients in properly reporting unclaimed property. If you believe you are holding unclaimed property or are unsure if you have such exposure, please call us at 847.982.0333. We are happy to assist you.

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