Voluntary Compliance Program: What It Waives, Who Qualifies

The short answer

California's Voluntary Compliance Program lets a holder who has not yet reported unclaimed property fix that on its own terms. Completing the program waives the 12 per cent annual interest the State Controller can otherwise charge under CCP §1577(a). Enrollment runs year-round, and waiting to be found through an audit is the costlier alternative.

The Voluntary Compliance Program waives the 12 per cent annual interest a holder would otherwise owe under CCP §1577(a), not the underlying property itself.
Enrollment is open year-round; a holder does not need to wait for a specific filing window to apply.
Interest accrues from the date the property should have been reported, so the longer a holder waits, the more an audit can cost.
Life insurers file their notice report before 1 May and remit 1 to 15 December; all other businesses file before 1 November and remit 1 to 15 June.
Extension requests must reach the Controller at least 30 days before the report due date.

Is your business already out of compliance without knowing it?

Every company that has operated in California for more than a few years almost certainly holds some unclaimed property already. The State Controller’s own files show how common this is: checking accounts alone account for 399,537 records and $1,078,405,026 statewide, cashier’s checks for 682,998 records and $785,935,117, and savings accounts for 351,678 records and $700,965,410. Behind each line is a company that at some point stopped looking for the rightful owner and, in many cases, never filed the report the law requires.

If your finance team has never run an unclaimed property review, or has not run one in several years, there is a reasonable chance some of your dormant accounts, uncashed vendor checks, or unclaimed refunds should already have been reported to the Controller.

What does the Voluntary Compliance Program actually waive?

Under Code of Civil Procedure §1577(a), a holder that fails to report, pay, or deliver unclaimed property on time owes the Controller interest at 12 per cent per annum, calculated from the date the property should have been reported. That interest has no stated cap and keeps accruing for as long as the property goes unreported.

Section 1577(d) requires the Controller to waive that interest for a holder that participates in and completes all requirements of the California Voluntary Compliance Program. The waiver covers the interest only. It does not reduce the value of property owed; the holder still must identify, report, and remit everything that belongs in the Controller’s custody. What the program removes is the penalty for having been late.

Who can use the program, and when?

The program runs year-round. A holder may apply at any time, rather than waiting for an annual window or a specific trigger. This matters because the two statutory filing cycles are fixed: life insurance companies file their notice report before 1 May and remit between 1 and 15 December; all other businesses file before 1 November and remit between 1 and 15 June. Extension requests are due no later than 30 days before the report is due. A holder that has missed one or more of these cycles does not need to wait for the next one to come around before putting things right.

Why does self-reporting cost less than being found?

The arithmetic is straightforward. Interest under §1577(a) runs from the date the property should have been reported, not from the date the Controller discovers it. A holder that has been out of compliance for several years and is later identified through an examination can face interest charges stretching back across all of those years, calculated at 12 per cent annually on top of the property itself. A holder that enrolls in the Voluntary Compliance Program and completes it owes the property, and nothing more.

There is no penalty for coming forward late to join the program itself. The real comparison is between two paths to the same destination: report now and keep the interest off the ledger, or wait, and have the interest calculated for you once the gap is found.

Is there any other way to avoid the interest?

The statute also allows the Controller to waive interest where the failure to report was due to reasonable cause, separate from the compliance program. That determination is made case by case, and nothing in the statute guarantees a particular outcome for a particular set of facts. The Voluntary Compliance Program is the route with a defined, statutory waiver attached to it: complete the requirements, and the interest is waived. We do not offer tax, legal, or compliance advice on whether a specific delay qualifies as reasonable cause; that question is for your attorney or your own compliance counsel.

What should a holder do next?

Before applying, most businesses need an internal review: which accounts are dormant, how long they have been dormant, and what the statutory holding period is for each property type. That review is the work our business escheatment audit was built for, and it is the step that determines whether the Voluntary Compliance Program is worth pursuing and what it will involve. See our business escheatment audit for the mechanics of a review, our pricing for how we charge for it, and our official State links page for where the Controller’s current program materials are published.

Questions People Ask

What is the California Voluntary Compliance Program?

It is a State Controller program that waives the 12 per cent annual interest a holder would otherwise owe under CCP §1577(a) for reporting unclaimed property late. A holder must participate in and complete all of the program's requirements to receive the waiver. It does not reduce the property owed, only the interest for having reported it late.

How much can unpaid interest actually add up to?

Interest accrues at 12 per cent per annum from the date the property should have been reported, with no stated cap on how long it can run. A holder several years behind on reporting can see that interest compound across every one of those years if the shortfall is found through an audit rather than self-reported.

When are unclaimed property reports due in California?

Life insurance companies file their notice report before 1 May and remit between 1 and 15 December. All other businesses file before 1 November and remit between 1 and 15 June. Extension requests must be submitted at least 30 days before the report due date.

Does joining the program reduce how much property we have to turn over?

No. The Voluntary Compliance Program waives interest only. A holder that completes the program still must identify, report, and remit the full value of the unclaimed property it holds; the program simply removes the 12 per cent annual interest charge for having reported it late.

Is there a deadline to apply for the Voluntary Compliance Program?

No. The program runs year-round, and a holder may apply at any time rather than waiting for the next annual filing cycle. Acting sooner limits how much interest would otherwise accrue if the Controller later finds the same gap through an examination.

Can a small business use the program, or is it only for large holders?

The statute does not limit the program by company size. Any holder with unreported property can apply, from a small business with a handful of uncashed checks to a large company with thousands of dormant accounts.

Sources

Figures on this page are from our copy of the State Controller’s published file as it stood on 25 October 2026. The State republishes the file weekly, so current totals will differ. Search is always against the latest copy.

How You Are Protected

Our fee is capped at ten per cent of what is recovered by Code of Civil Procedure §1582, and nothing is owed until the State Controller has paid you. If we recover nothing, you owe nothing. Our recovery fee is never asked for up front — it comes out of money the Controller has already paid you. A booking deposit on an in-person appointment is a separate thing, and is credited back against anything you are charged.

California Unclaimed Property Services is a private asset recovery firm. We are not the California State Controller’s Office.