Churches, mosques, professional associations and NGOs mostly register with CAC as incorporated trustees, not as companies. The annual return that follows has its own window, fee and paperwork.
What an incorporated trustee is, briefly
An incorporated trustee is the legal shell many non-profits use. A board of trustees holds property and signs contracts for the group. There are no shareholders, unlike a company. The structure is common for churches, old students' associations, foundations and professional bodies.
Because it is not a company, its annual-return rules sit in a different part of CAMA from the rules for companies limited by shares, or for companies limited by guarantee. Do not assume the company rules, including the AGM link, apply here.
The filing window: 30 June to 31 December
Section 848 of CAMA 2020 sets the filing window between 30 June and 31 December each year. That is a stretch of exactly six months, not a single date.
This is unlike a company's return, which is tied to a specific AGM date. A trustee board can choose any point inside that window, as long as it files before 31 December. There is no meeting requirement standing between the association and its filing.
The fee and the penalty
Filing costs ₦5,000. Miss the window, and the penalty is ₦10,000, charged against the organisation itself rather than against individual trustees.
That last point matters for boards used to hearing about director-level penalties elsewhere in CAC's rules. A trustee is not billed personally. The organisation's own funds carry the cost instead.
What comes with the return
The return is not just a form. It comes with an audited statement of accounts for the year. It also lists the trustees, the council members, any land the association holds, and any change to its rules.
Boards that treat the audit as an afterthought tend to miss the window waiting for the accountant, rather than struggling with the CAC form itself. Building the audit into the financial year's calendar, not just the filing month, avoids that.
Incorporated trustees also have a second, separate filing many boards do not expect: a bi-annual statement of affairs. It is not the same document as the annual return, and it carries its own two deadlines. See the incorporated trustees statement of affairs for that one.
How this differs from a company's annual return, and where Docufy fits
A company's annual return follows its AGM. It reports directors and shareholders, and it can bring a penalty on each officer.
An incorporated trustee's return runs on a fixed half-year window instead. It reports trustees and council members, and its penalty falls on the organisation alone. Our comparison of the annual return, audited accounts and tax returns covers the accounts side in more depth.
Docufy's vetted partner firm today files company annual returns, not incorporated-trustees returns. If your organisation is incorporated trustees, not a company, ask a company secretary or a lawyer who works with associations to handle this filing. For fees across both structures side by side, see the CAC annual return cost guide. Browse the CAC annual returns hub for the rest of this series.