Incorporated trustees often plan their year around one CAC filing. There is a second one, on a different clock entirely.
A second filing most trustee boards do not know about
Alongside the annual return, incorporated trustees file a bi-annual statement of affairs. It is a separate requirement under CAMA, not a different name for the same document.
Boards that only track the annual return's window are the ones most likely to miss this second filing, simply because nobody put it on the calendar. A treasurer who joined after the association was registered may never have been told it exists at all.
The two deadlines: 15 July and 15 January
15 July (for January to June) and 15 January (for July to December). Each date covers a different half of the year: the first half for the July deadline, the second half for the January one.
Two shorter reporting periods, rather than one annual one, is the whole point of the structure. It gives CAC a more current picture of an association's position than waiting a full year would. Build in a few days of buffer rather than aiming for the date itself, in case it falls on a weekend or public holiday.
How it differs from the annual return
The annual return is filed on a different clock altogether: between 30 June and 31 December each year. It reports the trustees, council members and any change to the constitution for the year.
The statement of affairs is not a summary of that same information twice a year. It is its own filing, with its own content and its own two dates. Treat the two as independent items on the compliance calendar, not one task with two names.
Who the penalty actually falls on
Miss a statement of affairs deadline, and CAMA attaches a daily penalty against each trustee individually, rather than against the organisation as a single entity. That is a different liability shape from the annual return's own penalty, covered in the incorporated trustees annual return.
A board that assumes the organisation alone carries the risk is assuming the wrong structure for this particular filing. Individual trustees who are otherwise careful about the annual return can still be caught out here, simply because the liability sits with them personally rather than the association.
What to put in place so it does not slip
Put both statement-of-affairs dates on the same calendar as the annual return, not folded into a single "CAC filing" reminder. A board member or secretary responsible for compliance should own both dates explicitly.
For the fee and window on the annual return side, see incorporated trustees: CAC annual return and fee. Browse the CAC annual returns hub for the rest of this series, and the CAC annual return cost guide for how the figures compare across structures.