NEWS & INSIGHTS
Understanding Florida SB 1452 and Its Impact on Tax and Finance
Florida’s 2026 Department of Financial Services omnibus bill touches everything from hurricane mitigation grants and workers’ compensation disputes to a sweeping Chapter 717 abandoned property overhaul and the permanent ratification of gold and silver as legal tender. Here is what tax attorneys, CPAs, and compliance professionals need to know.Â
Florida SB 1452: What the 2026 Bill Means
Florida’s 2026 legislative session produced one of the more wide-ranging Department of Financial Services bills in recent memory. CS/CS/CS/SB 1452 passed both chambers without a single dissenting vote, clearing the Senate 39 to 0 and the House 109 to 0. The bill amends or expands nine separate subject areas under DFS jurisdiction, and while not every provision is equally relevant to the tax bar, several carry meaningful implications for practitioners advising businesses, lenders, fiduciaries, and property holders operating in Florida.Â
My Safe Florida Home ProgramÂ
The bill revises eligibility for hurricane mitigation inspections and grants under the My Safe Florida Home Program. Going forward, grants are limited to applicants who qualify as low-income or moderate-income. Priority within that pool goes first to low-income applicants who are 60 years of age or older, followed by moderate-income applicants in the same age bracket.Â
The bill also streamlines program administration. A 24-month deadline now applies from the date of initial inspection to submit a grant application, and applicants whose improvements are approved have 18 months to complete the work without requesting an extension. DFS must provide at least five business days notice before treating an application as abandoned, giving applicants an opportunity to respond with good cause.Â
These changes reflect a deliberate effort to focus remaining program resources on the most vulnerable homeowners while reducing the backlog of inactive applications that had accumulated under the prior rules.Â
Workers’ Compensation Dispute ProceduresÂ
Two procedural changes affect the Division of Workers’ Compensation. First, the Three-Member Panel Report to the Legislature shifts from a two-year to a five-year reporting cycle. Second, providers now have 60 days, rather than 45, to file a petition with DFS to resolve utilization and reimbursement disputes after receiving notice of disallowance or payment adjustment. The bill also expands acceptable delivery methods for those petitions to include common carriers with verifiable tracking in addition to certified mail.Â
Insurance Licensing and Public Adjuster ObligationsÂ
The bill eliminates a prior friction point in out-of-state license transfers by removing the requirement that an applicant cancel their home state license before Florida issues a resident license. Under the revised process, the prior state license must be cancelled within 30 days after the Florida license issues. The application fee exemption for insurance licensure is also expanded to cover all honorably discharged veterans of the United States Armed Forces and their spouses.Â
Public adjusters face a new statutory obligation to respond to written or electronic consumer requests within 14 days, consistent with the existing timeline for responding to DFS.Â
The Abandoned Property Overhaul Under Chapter 717Â
The most substantive change in the bill for business and compliance practitioners is the comprehensive revision to Chapter 717, Florida Statutes, governing what the bill now calls abandoned property. The legislation replaces the term unclaimed property throughout the chapter with abandoned property, a terminological shift the bill backs with substantive changes to dormancy triggers, notice requirements, and claim procedures.Â
Under the revised framework, property becomes subject to DFS custody only when the applicable dormancy period has expired and required due diligence has been completed. This ties custody to a defined sequence of events rather than to the presumption of abandonment alone.Â
The bill reinstates undeliverable first-class mail or electronic communications as a dormancy trigger for equity interests in business associations and securities accounts, and extends the dormancy period tied to owner-initiated activity from three to ten years. Holders of property presumed abandoned and valued above $1,000 must now send a second notice by certified mail. For property valued at $50 or more, holders must use due diligence to locate the apparent owner and send written notice by first class mail or email at least 90 days, but not more than 180 days, before filing a report with DFS.Â
The public database is also expanded to include property valued at $10 or more, down from the prior threshold. Securities identified as non-freely transferable or worthless are excluded from reporting requirements. Holders must now certify that all reports are complete and that due diligence requirements have been satisfied.Â
For practitioners advising clients who hold property on behalf of others, manage dormant accounts, or work with fiduciaries in an estate or trust context, these changes require a review of existing compliance calendars and notice procedures.Â
Gold and Silver as Permanent Legal Tender in FloridaÂ
Perhaps the most distinctive provision in SB 1452 for SALT practitioners is the ratification of rules implementing Chapter 2025-100, Laws of Florida, which made gold and silver coins legal tender in Florida. The bill also repeals the automatic repeal clause that would have unwound Chapter 2025-100, making the legal tender designation permanent and effective July 1, 2026.Â
The rules being ratified were adopted by DFS and the Financial Services Commission for the Office of Financial Regulation. While the practical transactional footprint of gold and silver as legal tender remains to be seen, the Florida sales and use tax implications of these transactions have drawn attention from SALT practitioners since Chapter 2025-100 was originally enacted. The permanent ratification of that framework means those questions are no longer theoretical.Â
For businesses, lenders, or investment advisors operating in markets where precious metals are exchanged, the intersection of Florida’s legal tender framework with existing sales tax exemptions and the state’s broader treatment of investment assets warrants continued attention.Â
The SALT TakeawayÂ
For Florida tax practitioners, two provisions in this bill do the most work. The Chapter 717 overhaul changes how and when abandoned property obligations attach, which affects any client holding property on behalf of others, managing dormant accounts, or working through a fiduciary structure. The gold and silver legal tender ratification is the more novel question. Chapter 2025-100 is now permanent, the implementing rules are ratified, and the sales and use tax treatment of legal tender precious metal transactions under Chapter 212 remains unsettled. Those questions are worth getting ahead of before the Department does it for you. The legal tender provisions are effective July 1, 2026.Â
CS/CS/CS/SB 1452 is a 2026 Florida omnibus bill that amends statutory provisions governing the Department of Financial Services, including the My Safe Florida Home Program, Chapter 717 abandoned property, workers' compensation disputes, insurance licensing, and the permanent ratification of gold and silver as legal tender.Â
The 2026 session renamed unclaimed property to abandoned property throughout Chapter 717, extended dormancy periods for equity and securities accounts, added certified mail requirements for higher-value property, expanded due diligence obligations, and strengthened claim verification procedures.
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Yes. Chapter 2025-100, Laws of Florida, made gold and silver coins legal tender in Florida. CS/CS/CS/SB 1452 ratified the implementing rules and repealed the automatic repeal clause, making the legal tender framework permanent effective July 1, 2026.Â
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The bill extends the dormancy period tied to owner-initiated activity from three to ten years for equity interests and securities accounts and reinstates undeliverable first-class mail or electronic communications as a dormancy trigger.
Holders of property valued at $1,000 or more must send a second notice by certified mail. For property valued at $50 or more, holders must send notice by first class mail or email between 90 and 180 days before filing a report with DFS.Â
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The bill limits grants to low-income and moderate-income applicants, prioritizes applicants 60 and older within those categories, sets a 24-month post-inspection application deadline, and gives approved applicants 18 months to complete improvements.
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Applicants no longer need to cancel their home state license before Florida issues a resident license. Instead, the prior license must be cancelled within 30 days after the Florida license is issued.Â
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Public adjusters must now respond to written or electronic consumer requests within 14 days, consistent with the timeline already required for responses to the Department of Financial Services.
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The intersection of Florida's legal tender framework with the state's sales tax exemptions for investment metals and the broader treatment of precious metal transactions under Chapter 212 is an active area of SALT analysis. Practitioners advising clients in precious metals transactions should review applicable exemptions and the rules implementing Chapter 2025-100.
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No. The bill expressly provides that securities identified as non-freely transferable or worthless are excluded from the reporting requirements under Chapter 717.
Florida State and Local Tax Litigation
Explore our Florida State and Local Tax Litigation. Businesses facing Florida tax disputes should be prepared for the possibility that litigation may continue beyond the trial level. Understanding how tax cases move through Florida’s appellate courts can be critical to protecting favorable rulings and challenging adverse decisions.
© 2025 Jeanette Moffa. All rights reserved.
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Jeanette Moffa, Esq.
(954) 800-4138
JeanetteMoffa@MoffaTaxLaw.com
Jeanette Moffa is a Partner in the Fort Lauderdale office of Moffa, Sutton, & Donnini. She focuses her practice in Florida state and local tax. Jeanette provides SALT planning and consulting as part of her practice, addressing issues such as nexus and taxability, including exemptions, inclusions, and exclusions of transactions from the tax base. In addition, she handles tax controversy, working with state and local agencies in resolution of assessment and refund cases. She also litigates state and local tax and administrative law issues.