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Law Relating to Annual Returns


Annual Returns is to be filed once at least in every year at the Corporate Affairs Commission provided that a company need not make a return under this section either in the year of its incorporation or, if it is not required by section 213 of this Act to hold an Annual General Meeting during the following year, in that year: section 370 of the CAMA. The time for its filing is within 42 days after the Annual General Meeting (AGM) for the year: section 374 of the CAMA.

Contents of Annual Returns of a Company having Share Capital other than a Small Company: (FORM CAC 10)

1.     Name and Registered Certificate Number (RC No) of the company.
2.    Address of the Registered Office;
3.    Situation of the Register of members and Register of Debenture holders;
4.    Summary of Share Capital and Debentures;
5.    Particulars of Indebtedness;
6.    List of past and present members;
7.    Particulars of Directors and Secretary.


Documents to be Annexed to the Annual Returns of a Public Company

By section 375 of the CAMA, it is stated that subject to the provision of section 377 of the CAMA exempting unlimited companies and small companies, the Annual Returns must have annexed to it:

1.        A written copy, certified by a Director and the Secretary of the company, to be a true copy of every balance sheet and profit and loss account laid before the company in general meeting held in the year to which the return relates.

2.     A copy certified by a Director and Secretary of the copy of the Auditors Report and the Report of the Directors accompanying the balance sheet.

3.       Where the balance sheet contains amendments, the fact that the copy has been so amended shall be stated on it.

Certificates to be Annexed to the Annual Returns of a Private Company- section 376(1) of the CAMA.

In the case of a Private Company, the Annual Return shall be accompanied by:

·             A certificate by a Director and the Secretary to the effect that the company has not since the date of incorporation or last annual return, issued any invitation to the public to subscribe for any share or debenture of the company;
·             A certificate stating that the number of members does not exceed 50;
·             Directives as to when certain companies are to start and end their financial year. (Please note that by CBN Directive all Banks end their financial year on 31st December of every year)



Conditions for a Small Company: (section 351 of the CAMA)

A company qualifies as a small company in a year if for that year the following conditions are satisfied:

(a)     it is a private company having a share capital;
(b)     the amount of its turnover for that year is not more than N2 million or such amount as may be fixed by the Corporate Affairs Commission;
(c)     its net assets value is not more than N1 million or such amount as may be fixed by the Corporate Affairs Commission;
(d)     none of its members is an alien;
(e)     none of its members is a Government or a Government corporation or agency or its nominee; and
(f)     the directors between them hold not less than 51 per cent of its equity share capital.

Certificate to be Annexed to Annual Returns of Small Companies

For a small company, in addition to the documents required in section 376(1) of the CAMA, it shall deliver to the Corporate Affairs Commission, a certificate signed by a director and the secretary that:

a.    It is a private company limited by shares.
b.    The amount of its turnover for that year is not more than N2 million or such amount as fixed by the Corporate Affairs Commission.
c.    Its net assets value is not more than N1 million or such amount as fixed by the Corporate Affairs Commission.
d.    None of its members is an alien.
e.    None of its members is a government, a government agent or nominee.
f.    the directors among them hold not less than 51% of the equity share capital of the company: section 376(2) of the CAMA.



Obligation to File Annual Returns

The obligation to file Annual Return starts after incorporation. The Annual Return shall be completed, signed by both a director and a Secretary and filed at the Corporate Affairs Commission within 42 days after the Annual General Meeting for the year, whether or not that meeting is the first or only ordinary general meeting of the company in that year: section 374 of the CAMA.

Every company must at least once every year make and deliver to the Corporate Affairs Commission (CAC) an Annual Return or have in the form and containing the specified matters relating to the company: section 370 of the CAMA, for companies limited by shares or guarantee.

Forms of Annual Return by Companies

The Annual Return shall be in the form stated in the following schedules of PART A of CAMA. Schedule 8    is for a company having share capital other than small company. Schedule 9 is for a small company. Schedule 10 is for a Company Limited by Guarantee. Other forms are as follows. Form CAC/BN/7 is for the Annual Returns of Business Names. Form CAC/IT/4 is for the Annual Returns of Incorporated Trustees.

Consequences of Failure to File Annual Returns

           i.          Penalty:  By section 378(1) of the CAMA, there is a penalty of N1000 for a public company and N100 fine for a private company. Please note that these penalties can be changed at any time.

          ii.          It is an offence and directors are guilty and liable with the company to the penalty of fine.

         iii.          Striking off a defunct company:  By section 525 of the CAMA, the Corporate Affairs Commission can assume a company’s failure to file Annual Returns as an indication that it is defunct and no longer a going concern. Accordingly, the Corporate Affairs Commission complying with the proper procedure, may proceed to strike off the Name of the company. Please note that in any case, where any existing liability incurred by the Directors and officers subsists, the court can still formally wind up the company.

Proper Procedure to be Adopted By the Corporate Affairs Commission to Strike-Off Defunct Company: section 525 of the CAMA.

1.        The Corporate Affairs Commission sends a letter inquiring whether the company is carrying on business or in operation requesting the company to reply within one month.

2.       If within one month, no response is made by the company to the Corporate Affairs Commission, the Corporate Affairs Commission (CAC) shall within 14 days of expiration of the one month write a second letter referring to the first letter and giving another one month to respond and stating that after that one month, the Corporate Affairs Commission (CAC) would publish a Notice in the Gazette with a view to striking the name of the company off the Register of companies.

3.       If within one month, the Corporate Affairs Commission (CAC) receives an answer confirming that the company is not carrying on business or in operation or the company fails to respond, after expiration of the one month (that is to say the 2nd one month), the Corporate Affairs Commission (CAC) may publish in the Gazette and notify the company by post that at the expiration of 3 months from the date of the notice, it shall proceed to strike off the name of the company from the Register and the company shall be dissolved.



Procedure to Restore a Struck Off Company

By section 525(6) of the CAMA, where a company’s name is struck off the Register of Companies by the Corporate Affairs Commission (CAC), it can be restored when;

1.        An application is made to the Federal High Court (by any company or member or creditor) within 20 years of publishing the Notice to restore the company to the Register.

2.        If the court is convinced it would make an order restoring the company in the Register of companies at the Corporate Affairs Commission (CAC), the court may give an order placing the company and other persons in as nearly the same position as if the name had not been struck off the Register.

3.       The Restoration takes effect upon delivery to CAC a Certified True Copy of the court order.

Enforcement of Return 


By section 565 of the CAMA; within 14 days after service on the company by the Corporate Affairs Commission (CAC), a Notice to file its Annual Return as required, a member, creditor or the Corporate Affairs Commission (CAC) can apply to the Federal High Court by way of Originating Motion/Summons to Order the company to comply, by filing its Annual Returns. Please note that it is the duty of the Corporate Affairs Commission to serve on a company a Notice to File Annual Return.

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