Incorporated trustees' duties after CAC registration

Incorporated trustees duties after registration: what changes once CAC issues the certificate, and the filings that follow it.

2 min readBy the Docufy editorial team

Quick answer

Once CAC registers incorporated trustees, the organisation must keep CAC's record current, file an annual return between 30 June and 31 December each year, and file a separate statement of affairs twice a year. Miss either filing, and a penalty follows.

Annual return window
between 30 June and 31 December each year
Statement of affairs deadlines
15 July (for January to June) and 15 January (for July to December)
Annual return law
section 848 of CAMA 2020
Late annual return penalty
₦10,000
On this page

Registration is the start of incorporated trustees status, not the end of the paperwork. Here is what CAC expects afterwards.

What changes once the certificate is issued

Once CAC issues the certificate, the organisation can act in its own name. It can hold property, open accounts and sign contracts as itself, not through one trustee.

That status brings duties with it. The certificate is not a one-off prize to file away and forget about.

Telling CAC about a change of trustees or address

Organisations change over time. Trustees retire. New ones join. A congregation or association sometimes moves to new premises.

This article cannot confirm the exact filing CAC expects for every kind of change. Treat any change to trustees, address or the constitution as something CAC's record should reflect. Confirm the current process with CAC or a company secretary, rather than assume the change updates itself or waits until the next annual return to matter.

The annual return window

Incorporated trustees file an annual return between 30 June and 31 December each year, under section 848 of CAMA 2020. It reports the trustees, the council members, any land held, and any change to the constitution that year.

Miss it, and the penalty is ₦10,000, charged against the organisation. See incorporated trustees: CAC annual return and fee for the full detail on that filing, rather than repeating it here.

The separate statement of affairs

Alongside the annual return, incorporated trustees file a bi-annual statement of affairs, 15 July (for January to June) and 15 January (for July to December). It is a distinct filing under CAMA. It is not another name for the annual return.

This one carries its own kind of liability. A daily penalty falls on each trustee personally if it is filed late, not on the organisation as a whole. Incorporated trustees: the statement of affairs covers this filing and its deadlines in full.

Keeping records ready for both filings

Both filings ask for similar information underneath: who the trustees are, what has changed, and the organisation's financial position. Keep records through the year, rather than piecing them together at each deadline.

A treasurer or secretary should own both dates on the compliance calendar. A board that only tracks the annual return is the board most likely to miss the statement of affairs entirely, sometimes for several years running.

Our compliance calendar tool can hold both dates alongside anything else the organisation files each year, such as a licence renewal or a tax deadline. One shared calendar, checked regularly by one named person, beats two important dates living only in two different people's memories.

Browse the CAC registration hub for more on what comes before and after registering incorporated trustees.

Questions people ask

What is the first thing to do after CAC approves the registration?

Keep the certificate of incorporation safe, and diarise the annual return window, between 30 June and 31 December each year, straight away.

Do we need to tell CAC if a trustee leaves or a new one joins?

This article cannot confirm the exact filing CAC expects for every change. Treat it the same way you would any other change to the organisation's official record, and confirm the current process with CAC or a company secretary.

Is the annual return the only filing incorporated trustees owe?

No. A separate statement of affairs falls due twice a year, 15 July (for January to June) and 15 January (for July to December). See incorporated trustees: the statement of affairs for that filing in full.

Who is liable if a filing is late?

For the annual return, the penalty is ₦10,000. See incorporated trustees: CAC annual return and fee for how that penalty is assessed.

Sources

Last checked 27 Sep 2026. Fees and rules change; the agency that issues the document has the final word. See our editorial policy.

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