Older CAC guidance describes a penalty that grows every single day a return is late. Filing agents now say that part is switched off. Here is what that actually means.
What the daily penalty used to add up to
The Companies Regulations 2021 set out a default penalty that could accrue daily for as long as a return stayed unfiled. On top of the flat, one-off company fine for each late return, this was the part that made an old backlog genuinely expensive to calculate by hand.
We are not stating the exact daily figures here, because we could not confirm them on a CAC-published page. Where a number is not solid enough to quote, this article leaves it out rather than guessing.
Why filing guides now describe it as suspended
Filing-agent sources report the daily penalty as suspended until further notice. That phrase, not "cancelled" or "removed", is doing a lot of work: it suggests CAC could switch it back on without amending any law, since the regulation behind it has not changed.
No CAC notice announcing this suspension turned up in our research. That does not mean the suspension is not real. It means the source for it is filing-agent practice and reporting, not a CAC document we could point to directly.
What still applies even though the daily charge does not
The one-off, per-return company-level penalty is unaffected. For a small company, that is ₦1,000 for each late return, and the company and each of its directors and officers can be billed at the same rate on top of it.
Nothing about the daily penalty's suspension changes who owes this charge, or how many late returns it covers if a company has been behind for a long time.
Why "suspended" is not the same as "cancelled"
A suspended rule can restart. A cancelled or repealed one generally cannot, without new law being passed. Since the daily penalty sits in the same regulations as the charges CAC is actively enforcing, there is no legal reason it could not return.
Businesses that have relied on the suspension for a long backlog should treat it as a temporary reprieve, not a permanent feature of the system.
What to check before you assume you are safe
Before assuming your bill is smaller because of the suspension, confirm your actual invoice through the CAC portal rather than calculating it from an old article, including this one. Figures and practice have moved before.
If you are working out a multi-year bill, our worked example for a small company shows how the per-return and per-officer charges combine. The CAC annual return penalty calculator is a faster way to run your own numbers, and the CAC annual returns hub links the rest of this series. You can start your CAC annual return once you know what is outstanding.