765 ILCS 1026/ (IL-RUUPA) · Illinois State Treasurer — Unclaimed Property Division

Illinois RUUPA B2B Exemption Repeal, Mandatory Negative Filings & May 1 Compliance

Illinois represents one of the steepest mid-market compliance traps in the United States due to its 2018 retroactive B2B repeal and statutory mandatory negative reporting thresholds.

Deadline: May 1 Cutoff: December 31 B2B Repealed (Retroactive) Zero Report: Mandatory

Illinois Statutory Dormancy & Compliance Schedule

NAUPA Property Stream	Statutory Dormancy	Compliance Rule
Uncashed AP Vendor Checks (CK13)	3 yrs	Illinois repealed its historical B2B exemption effective January 1, 2018 under IL-RUUPA with retroactive reach-back—making previously exempt vendor checks and AR credits reportable.
Payroll, Wages & Commissions (MS01)	1 yr	Never B2B exempt; applies to employee final & bonus checks.
AR Credit Balances & Overpayments (MS09)	3 yrs	Write-offs to income do not extinguish reporting obligation.
Customer Refunds (MS05)	3 yrs	Due diligence window: 60–365 days prior to May 1 (Electronic if >= $50).
Gift Cards & Stored Value (GC / MS12)	5 yrs (exempt if no fees/exp)	Unaddressed cards route to corporate domicile under 2nd Priority.
Securities & Dividends (SC01 / SC08)	3 yrs	First-class mail; Certified Mail >= $1,000 if securities
Virtual Currency / Digital Assets (VC)	5 yrs (USD liquidation)	Verify liquidation vs. native custodial transfer mandate.

Key Illinois Compliance Traps & Enforcement Risks

2018 Retroactive B2B Exemption Repeal Manufacturers, distributors, and service companies that relied on Illinois's pre-2018 B2B exemption were swept back into multi-year liability when IL-RUUPA repealed the exemption retroactively.

Mandatory Negative Report Thresholds Under 765 ILCS 1026/15-401, businesses exceeding $1M in annual sales, $10M net worth, or 100 employees must file an annual negative report even with $0 due.

Illinois State Treasurer VDA Program

10-year + dormancy lookback agreement waiving penalties and interest for holders catching up post-2018 B2B repeal prior to audit notice.

Statutory Interest & Penalties: Interest + up to $200/day civil penalties ($5,000 cap) + audit extrapolation. Negative Report Policy: Mandatory annual Negative (Zero) Report if annual sales > $1M, net worth > $10M, > 100 employees, or publicly traded.

Statutory Questions & Answers

Do we have to file a $0 report in Illinois if all our vendors are businesses?

Yes, if your company meets any statutory size threshold (sales > $1M, net worth > $10M, or > 100 employees). Moreover, B2B obligations are no longer exempt in Illinois.

How does Illinois handle virtual currency?

Illinois requires liquidation of abandoned virtual currency into U.S. dollars prior to remittance to the State Treasurer.