CAC Annual Returns for NGOs and Churches: 2026 Trustee Guide

In the non-profit sector of 2026, transparency is the new currency. Whether you are running a charitable NGO, a foundation, or a church, the Corporate Affairs Commission (CAC) requires more than just good intentions. Knowing how to handle CAC annual returns for NGOs and churches is vital to protect your tax-exempt status and ensure your organization isn't struck off the register.

Under the Companies and Allied Matters Act (CAMA 2020), "Incorporated Trustees" are now subject to oversight. Here is the definitive guide to non-profit compliance.

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🏗️ 1. Why Non-Profits Must File

Many trustees mistakenly believe that because they don't make "profit," they don't need to file "returns."

• The Regulatory Shift: In 2026, the CAC uses annual returns to prevent NGOs from being used as shells for money laundering or unauthorized political funding.
• Asset Protection: A church or NGO that is "Inactive" on the portal cannot easily process land titles or open corporate bank accounts.
• Donor Confidence: Major international donors (like the UN or Bill Gates Foundation) will only fund organizations that are marked "Active" on the CAC portal.

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📋 2. The Filing Requirements for Trustees

Filing for an NGO is more than filing for a business. You need:

1. Statement of Affairs: A summary of the organization's income and expenditure.
2. Trustee Details: A confirmation that the current trustees are the same as those on record.
3. Financial Audit (If Applicable): For larger NGOs, a report from a chartered accountant is mandatory.
4. Minutes of the AGM: Confirmation that the members have met and approved the accounts.

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⚡ 3. The 2026 Fee Structure

In 2026, the fees for "Incorporated Trustees" are fixed:

• The Filing Fee: ₦5,000 per year.
• The Late Penalty: ₦5,000 per year (if filed after June 30th).
• Total for Late Filing: ₦20,000.

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📝 4. The Risk of Being "Struck Off"

In 2026, the CAC is particularly about delisting non-profits that are inactive.

• The 10-Year Rule: If an NGO or Church fails to file for 10 years, it is assumed to be defunct.
• The Consequences: The organization's land and property (which are technically owned by the "Trustees" as a body) can face legal challenges or state intervention.

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🔥 5. Tax Compliance for NGOs

Filing your CAC annual returns is not the same as being "Tax Exempt."

• The FIRS Link: To maintain your tax-exempt status, you must also file your income and expenditure with the FIRS. They will issue a Tax Clearance Certificate (TCC) only if your CAC records are up-to-date.

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Frequently Asked Questions (FAQ)

1. Does the Church need to report its tithes and offerings?

Yes, in a summarized format. The CAC doesn't tax these, but they must be recorded in the Statement of Affairs to prove the organization has the funds to meet its objectives.

2. Can one trustee file for the whole NGO?

No. At least two trustees (or a trustee and the secretary) must sign off on the accounts before filing.

3. What if we haven't done any projects this year?

You must still file a "Dormancy" or "Nil" return. Compliance is about existence, not just activity.

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Protect Your Organization's Mission

A non-profit is built on trust. Don't let an "Inactive" status tarnish your reputation. Our experts specialize in CAC annual returns for NGOs and churches, handling the complex Statement of Affairs with precision.

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