CAC's annual return penalty was not new law in 2024. What changed was CAC actually applying it, and the date that happened depends on which source you read.
The November 2023 notice that started the clock
CAC published a public notice on 3 Nov 2023. It warned that the penalty for a late annual return would apply in full, against the company and each of its directors and officers, not the company alone.
That notice is the clearest fixed point in this timeline. It is a CAC document, dated and still referenced by filing guides today.
The January 2024 date CAC first announced
The same notice pointed to 1 Jan 2024 as when full application would begin. Companies with unfiled returns were urged to clear them before that date.
Read on its own, this suggests a roughly two-month warning period between the notice and enforcement starting.
Why the real enforcement start slipped to April 2024
Media coverage close to the deadline reported CAC pushed the start back. 1 Apr 2024 is the date most 2024 news coverage settled on for when enforcement actually began.
We could not find a CAC notice of the extension itself in our research, only news reporting of it at the time. Both the January and April dates are on record from credible sources, which is why this article states both rather than treating one as wrong.
What changed in practice once enforcement began
Before this period, filing guides describe the annual return penalty as something companies could often avoid or negotiate down at the point of filing. After enforcement began, the figures reported by filing agents became more consistent, and the personal liability of directors and officers became a real line on invoices rather than a theoretical rule.
CAC's notice also flagged that it would chase the penalty against directors and officers of struck-off and wound-up companies, extending the same logic to companies that had already left the register.
That detail is easy to miss in coverage that focused mainly on the headline dates. It signalled that CAC saw this as a backlog to clear across the whole register, not only a rule for companies still actively filing.
How this compares with the earlier daily penalty
Before this enforcement push, a separate daily default penalty already existed in the Companies Regulations 2021. Filing guides now describe that daily charge as suspended, which is a different and more recent development than the timeline in this article.
Do not confuse the two. The 2023 to 2024 enforcement drive is about the one-off, per-return penalty and its officer charge actually being billed. The daily penalty's suspension is a separate change layered on top of that, covered in our article on the daily penalty.
Why the exact date still matters for older filings
If your company's unfiled years straddle this period, the exact date can affect how the penalty was calculated for that stretch. A company secretary or the CAC portal itself is a better source for a specific historical calculation than picking a date from this article.
For what the penalty actually costs today, see our guides to the small company, other private company and public company rates, or work through the CAC annual return penalty calculator. The CAC annual returns hub links the rest of this series, and you can start your CAC annual return once you are ready to file.