On June 22, 2026, Arizona enacted SB1336 (the “Act”), a bill "relating to the state land department" with amendments extending far beyond the state land department. The Act amends the definitions section of Arizona's unclaimed property statute by striking former A.R.S. § 44-301(17)(b) in its entirety, eliminating Arizona's longstanding exclusions from the definition of "property" for gift certificates, electronic gift cards, stored value cards, nonrefundable tickets, prepaid phone cards, frequent flyer miles, and merchandise points, as well as the B2B/current business relationship and de minimis property exemptions. Absent an emergency clause, the amendment takes effect on Arizona's general effective date: September 12, 2026.

The practical effect is that these previously exempt property types now have the potential to become reportable Arizona unclaimed property for the first time in several years. Because Arizona’s dormancy provisions do not specifically address these property types, they would appear to default to Arizona's catchall provision, § 44-302(A)(16), under which "all other property" is presumed abandoned three years after the owner's right to demand the property, or the holder's obligation to pay or distribute it, first arises.

Notably, this change may be vulnerable to challenge under the Arizona Constitution, which, among other safeguards, prohibits the legislature from passing bills that do not adequately describe their subject. Unless a court invalidates the amendment, or the legislature corrects it, however, holders issuing gift cards, stored value products, or loyalty points to Arizona customers, or relying on the B2B exemptions, should examine the provisions of the Act to determine the impact on their reporting.

Please contact us or the Reed Smith attorney with whom you regularly work if you would like to discuss.

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