CAC Annual Returns Nigeria — Penalties, Struck-Off Risk & Restoration
CAMA 2020 Primary-Source Legal Research | Verified CAC Regulatory Intelligence
You are reading Daily Reality NG — Nigeria's independent publication for verified financial and regulatory intelligence. Editorial policy →
The Corporate Affairs Commission published notice on July 15, 2026, targeting 100,000 more companies for deregistration. This follows more than 400,000 companies already struck off in 2025. Affected companies have been given a 90-day window to file outstanding annual returns and PSC information or face being permanently struck off. If your company has not filed annual returns for any year from 2015 onwards, you may be on the list. Check the CAC official website at cac.gov.ng immediately. Sources: Tribune Online | Nairametrics, July 16, 2026.
What Happens When a Nigerian Company Fails to File Annual Returns — CAC Penalties, Struck-Off Risk, and How to Restore a Dormant Company
More than 400,000 Nigerian companies were struck off the register in 2025. Another 100,000 received notice in July 2026. Your company may be next. This is what CAMA 2020 actually says, what the penalties are, and exactly how to fix it.
⏱️ Before You Read Any Further — Check This First
Has your company filed annual returns for every year since incorporation? If yes for all years — you are compliant. Read this article to understand the rules and protect yourself going forward. If no for any year — your company is currently accumulating penalties against you personally and the company. Jump directly to Section 3 (Penalty Cascade) and Section 8 (How to Fix It Now). If your company has already been struck off — go directly to Section 9 (Restoration Process). Do not delay — the CAC's 90-day window from July 15, 2026 is running.
Check your company's status at icrp.cac.gov.ng right now, then return to this article.
📰 Why Daily Reality NG Wrote This Article — And Why It Matters Right Now
You are reading Daily Reality NG — an independent Nigerian publication based in Warri, Delta State. This article was written because the CAC's Batch 6 deregistration notice of July 15, 2026 places 100,000 more companies at imminent risk of losing their legal existence. According to Daily Reality NG research across verified primary legal sources — including CAMA 2020, the Companies Regulations 2021, CAC official notices, and analysis from tier-one Nigerian law firms — most Nigerian business owners do not understand the full consequences of non-filing until the damage is done. This guide documents the complete legal picture: what you owe, what happens if you don't pay, and what it takes to come back from being struck off.
💡 Quick Answer — What Happens When You Don't File Annual Returns?
In order of escalation under CAMA 2020:
- Immediate penalties accrue: ₦50,000 initial fine on the company + ₦10,000 per day continuing, against both the company and each director personally (Section 415, CAMA 2020)
- Flat annual penalties also enforced: ₦5,000/year for small companies and ₦10,000/year for other private companies per year of default (Companies Regulations 2021)
- 10 consecutive years of non-filing: CAC triggers the striking-off process under Section 692, CAMA 2020
- Strike-off notice: CAC sends notice to your registered address; you have 90 days to respond
- Federal Gazette publication: If no response, CAC publishes your company name and strikes it off
- Company ceases to exist: Cannot operate, sign contracts, access bank accounts, or obtain TCC
- Assets vest in the Federal Government of Nigeria under CAMA 2020
- Restoration: Requires Federal High Court order, ₦200,000–₦500,000 in legal fees, 6–12 months timeline, plus all outstanding fees
Lagos. March 2024. A call that should never have been necessary.
Emeka had been running his construction company for seven years. He had staff, contracts, and a brand reputation he'd built from nothing. He wasn't a tax evader. He wasn't hiding. He just didn't know that "annual returns" to the CAC was a different obligation from his annual tax filing with FIRS. He assumed — as many Nigerian entrepreneurs do — that paying his taxes meant he was fully compliant with every government requirement.
In March 2024, he tried to open a new corporate account for a ₦45 million government contract. The bank's due diligence check came back with a problem: his company had been flagged in the CAC system for seven years of non-filing. The penalties against him personally ran into hundreds of thousands of naira. And the contract — which required evidence of an active, compliant corporate entity — was at risk of being pulled.
What followed was months of legal and administrative work to regularise his status. The company survived — but barely. This article is written for every Emeka who doesn't yet know this is happening to their company.
If you registered a company in Nigeria and have not filed annual returns for every year since — or are not even certain when your last filing was — you are in a position that affects tens of thousands of Nigerian business owners right now. The CAC's announcement on July 15, 2026, making it the sixth consecutive batch of mass deregistrations, confirms that this is not a dormant regulation being selectively enforced. It is an active enforcement campaign that has already eliminated more than 400,000 companies from the Nigerian corporate register. Your company's legal existence is not guaranteed just because you are still operating. It is only guaranteed if you have filed.
✅ What This Article Gives You
By the time you finish reading, you will have: a complete understanding of what annual returns are and why they are legally separate from tax filings; the exact penalties under CAMA 2020 and the Companies Regulations 2021 — against both your company and you personally as a director; a clear timeline of what happens from the first missed deadline to full striking off; a documented understanding of what a struck-off company cannot do; the step-by-step restoration process from Section 692 of CAMA 2020 and the Federal High Court procedure; verified cost estimates for restoration; and a compliance checklist to prevent this from ever happening again. Every claim in this article cites a named primary or authoritative secondary legal source.
🔍 The Number That Should Alarm Every Nigerian Director
The CAC Registrar-General disclosed by February 2026 that more than 400,000 companies had been struck off the Nigerian corporate register in 2025 alone — before the Batch 6 notice of July 2026 added another 100,000 to the target list. These are not shell companies or ghost entities. Many were active businesses whose owners simply did not know annual returns were a separate, annual obligation from their tax filings. The CAC's database integration with FIRS and NIMC in mid-2026 means there is now no invisible space in which non-compliant companies can quietly operate. Enforcement is now structural, not incidental.
📋 Table of Contents — Navigate This Guide
- What Annual Returns Are — and What They Are Not
- Who Must File, When, and What Is Required
- The Penalty Cascade — What Happens the Moment You Miss a Deadline
- Directors' Personal Liability — You Are Not Protected by the Corporate Veil
- The Striking-Off Process — How the CAC Actually Does It
- The July 2026 Breaking Update — Batch 6 and 400,000 Companies Gone
- What Happens to Your Business After Being Struck Off
- How to Regularise Now — If You Are Behind But Not Yet Struck Off
- How to Restore a Struck-Off Company — Complete Step-by-Step
- Cost Comparison — Compliance vs Restoration
- Key Takeaways and Compliance Checklist
- Frequently Asked Questions (15)
🎯 Decision Box — Find Your Situation
✅ "My company is up to date on all annual returns"
Read Sections 1–2 to understand the full scope of the obligation, and Section 11 for the compliance checklist. Also confirm your PSC register is up to date — this is now a separate co-requirement with annual returns.
⚠️ "I have missed one to three years of annual returns"
You are accumulating penalties against both the company and yourself personally. You are not yet at striking-off risk if you act immediately. Go to Section 3 to understand what you owe, then Section 8 for how to regularise right now.
🚨 "I have missed many years — possibly on the CAC deregistration list"
Urgent. Check the CAC official website at cac.gov.ng for the Batch 6 list. If your company is listed, you have 90 days from July 15, 2026. File everything immediately and submit evidence to CAC's designated email. Read Sections 5, 6, and 8 now.
❌ "My company has already been struck off"
You need a lawyer now. Read Section 9 (Restoration) for the complete court process, then engage a qualified Nigerian solicitor experienced in Federal High Court CAC restoration applications. Timeline: 6–12 months. Cost: ₦200,000–₦500,000+ in legal fees before back-payments.
📍 Situation Snapshot — Understand Where You Stand
| Your Situation | Legal Status | Penalty Exposure | Immediate Risk | Required Action |
|---|---|---|---|---|
| Fully compliant — filed all years | ✅ Active & compliant | None | None | File next year's returns on schedule. Update PSC register. |
| 1–2 years late | ⚠️ Non-compliant | ₦10,000–₦20,000/year + director liability | Penalty accumulation; no immediate strike-off risk | Log into icrp.cac.gov.ng and file overdue returns immediately. Pay arrears. |
| 3–9 years late | ❌ Seriously non-compliant | ₦30,000–₦90,000+ against company; same personally against each director | May be on current deregistration list; high risk | Check CAC deregistration list immediately. File all arrears. Engage compliance consultant or lawyer. |
| 10+ years late / on deregistration list | ❌ Imminent striking-off | ₦100,000+ + full penalty schedule + potential personal prosecution | 90-day window from CAC notice — extremely urgent | Act within 90 days of notice. File ALL outstanding returns. Submit PSC information. Send evidence to CAC email. |
| Already struck off | ❌ No longer legally exists | All accumulated penalties apply + restoration costs | Cannot operate, contract, or bank in company name | Engage a solicitor for Federal High Court restoration application. Prepare ₦200,000–₦500,000+ budget and 6–12 months timeline. |
| ⚠️ Check current CAC compliance status at icrp.cac.gov.ng. Batch 6 target list published at cac.gov.ng on July 15, 2026. | ||||
📋 Section 1: What Annual Returns Are — and What They Are Not
You are reading Daily Reality NG — an independent Nigerian publication. Every legal claim in this section is sourced directly from CAMA 2020 and the Companies Regulations 2021.
The single most common source of non-compliance among Nigerian business owners is a simple conceptual confusion: they believe that filing their annual tax returns with the Federal Inland Revenue Service (FIRS) discharges their corporate compliance obligation. It does not. Annual returns to the CAC are a completely separate obligation, filed with a completely separate government body, covering completely different information, with completely different consequences for non-compliance.
| Obligation | Filed With | What It Covers | Deadline | Penalty Authority |
|---|---|---|---|---|
| CAC Annual Returns | Corporate Affairs Commission (CAC) | Company structure: directors, shareholders, registered address, share capital, Persons with Significant Control | Within 42 days of incorporation anniversary (private companies) | CAC under CAMA 2020 and Companies Regulations 2021 |
| Annual Tax Returns | Federal Inland Revenue Service (FIRS) | Company income, taxable profit, taxes due — financial performance | Within 6 months of financial year-end | FIRS under Companies Income Tax Act (CITA) |
| Annual Financial Statements | Primarily for shareholders; some filing to CAC required | Audited accounts showing financial position — must comply with accounting standards | Before AGM; AGM within 15 months of incorporation or 6 months of year-end | FIRS and CAC for different aspects |
| 💡 All three are separate, independent, mandatory obligations. Filing one does not satisfy the others. The CAC annual return is the one most commonly missed — and the one that triggers the striking-off process. Source: Business Cardinal, "Filing Annual Returns with CAC in Nigeria," May 27, 2026 | Section 421, CAMA 2020. | ||||
What does a CAC annual return actually contain? According to the CAC Annual Returns FAQ at cacannualreturns.com, a company's annual return provides updated information on: the company's registered office address; details of shareholders; statement of share capital; the company's turnover and net assets; and — under CAMA 2020 — information on Persons with Significant Control. It is essentially a confirmation to the government that the company still exists, is still operating, and that its governing structure is accurately recorded.
The obligation is not contingent on profitability, trading activity, or company size. A company that has not traded in a given year still has the obligation to file — either as an active annual return or a Statement of Affairs confirming its dormant status. Silence is not an acceptable response to the CAC.
📅 Section 2: Who Must File, When, and What Is Required
Section 415 of CAMA 2020 requires every company incorporated in Nigeria to file annual returns with the CAC every year. The specific filing deadlines and requirements vary by company type.
| Company Type | Filing Deadline | First Filing | Filing Fee (approx) | Key Contents |
|---|---|---|---|---|
| Small Private Company (Section 394, CAMA 2020) | Within 42 days of incorporation anniversary annually | From 3rd year after incorporation | ~₦3,000 filing fee | Directors, shareholders, registered address, share capital, PSC register |
| Other Private Limited Company | Within 42 days of incorporation anniversary annually (or 42 days after AGM) | From 1st year after incorporation | ~₦5,000 filing fee | Directors, shareholders, registered address, share capital, PSC register, financial position statement |
| Public Company | Within 42 days of AGM | From 1st year after incorporation | ~₦10,000+ filing fee | Full financial statements plus all standard items above; SEC filings also required |
| Business Name (Sole Proprietor/Partnership) | Annually — through CAC online portal | Simplified process | Lower fees | Business activities update; registered address; proprietor/partner details |
| 📎 Sources: SmartSMS Solutions, "CAC Annual Returns Filing Guide 2026," March 2026 | Business Cardinal, "Filing Annual Returns with CAC in Nigeria," May 2026 | EBC Consults, "CAC Annual Returns Nigeria," June 2026 | Section 394 and Section 421(1), CAMA 2020. Note: A small company under CAMA 2020 is one with annual turnover of ₦120 million or less, net assets of ₦60 million or less, fewer than 50 employees, and not a holding or subsidiary company. | ||||
📋 What CAMA 2020 Added — The PSC Requirement
Under Sections 119 and 791 of CAMA 2020 and the PSC Regulations 2022, companies must maintain a Register of Persons with Significant Control (PSC) — also called beneficial ownership information. A PSC is any natural person who directly or indirectly holds 5% or more of shares or voting rights, or who has the right to appoint or remove a majority of directors.
Critically: the CAC's current Batch 6 deregistration campaign requires affected companies to file BOTH outstanding annual returns AND PSC information. Companies that have filed annual returns but have not submitted PSC data are also at risk.
The obligation to file PSC information is within one month of incorporation or when someone becomes a PSC. Non-compliance is an independent offense — not contingent on annual returns status.
📎 Sources: Qrafteq, "CAC Penalties Nigeria 2025 Guide," November 2025 | Tribune Online, July 16, 2026
The CAC's November 2023 public notice — published at cac.gov.ng — was a formal warning that from January 1, 2024, the CAC would commence full application of the penalties prescribed by the Companies Regulations 2021 against both companies AND their individual directors and officers. Before this notice, a historical pattern existed where penalties were applied at reduced rates or selectively. That era is now definitively over. The notice specifically stated that the CAC had "observed large scale non-compliance with this requirement" and would no longer exercise discretion. Directors who assumed CAC enforcement was slow or lenient were operating on outdated assumptions.
📎 Source: Corporate Affairs Commission Official Notice, November 3, 2023 — cac.gov.ng
⚡ Section 3: The Penalty Cascade — What Happens the Moment You Miss a Deadline
The penalty structure for non-filing is a cascade — it starts as a manageable fine and grows exponentially if ignored. Understanding each stage is critical because the appropriate response at each stage is different.
Initial Penalty Attaches
From the day after your filing deadline passes, the initial penalty of ₦50,000 on the company becomes due under Section 415 of CAMA 2020. A daily continuing penalty of ₦10,000 per day for every day the default continues also attaches — against both the company and each director and officer personally. Additionally, the flat annual penalty under the Companies Regulations 2021 (₦5,000/year for small companies; ₦10,000/year for other private companies) begins to accumulate. Note: As of mid-2026, the daily penalty is currently suspended by the CAC; the flat annual penalty structure is actively enforced.
Penalties Compound Per Year
Each year of non-filing adds another annual penalty cycle against both the company and each director personally. After three years, a company's accumulated penalty exposure for a private company (non-small) stands at approximately ₦30,000 in back-annual penalties — plus the same amount against each individual director. The total personal exposure for a director of a company five years in default can reach ₦50,000–₦70,000 in flat annual penalties alone, before the initial penalty and any daily penalties are calculated.
Strike-Off Process Triggered Under Section 692
Section 692 of CAMA 2020 empowers the CAC to initiate striking-off proceedings when it has reason to believe a company has not been operating or has not complied with the Act for a consecutive period of 10 years. This is the primary legal trigger. In practice, the CAC has also been striking off companies based on non-filing through its deregistration campaign exercises, which are run periodically — the current Batch 6 (July 2026) being the latest.
Formal Notice to Company's Registered Address
Under Section 692(3) of CAMA 2020, the CAC sends a formal notice to the company's registered address. This is why maintaining an accurate registered address in the CAC system matters critically — a company that has moved without updating its address may never receive the notice and miss the response window entirely. The notice gives the company a specified period (currently 90 days in the Batch 6 campaign) to respond and regularise its records. Failure to respond within this window moves the company to Stage 5.
Public Notice in Gazette and CAC Website
Under Section 692(4) of CAMA 2020, if the company fails to respond to the CAC's notice within the specified period, the CAC publishes a notice of intent to strike off in the Federal Government Gazette and on its official website. National newspapers are also used. This publication constitutes the company's final opportunity to respond before being struck off. After this publication, a further waiting period passes, after which the striking off becomes final.
Legal Existence Terminated
The company's name is removed from the Nigerian corporate register. It legally ceases to exist. All the consequences in Section 7 of this article now apply. The company's assets vest in the Federal Government of Nigeria. Directors lose limited liability protection. The company name becomes available for anyone else to register. Restoration now requires a Federal High Court order — typically 6 to 12 months and ₦200,000–₦500,000+ in legal fees before back-payments.
Based on verified figures from EBC Consults (June 2026) and Qrafteq (November 2025), consider this documented illustration: a company that was 12 years late by April 2024 faced an accumulated penalty bill of over ₦736,000 — compared to ₦6,000 if it had filed before April 1, 2024 (when the CAC's amnesty-adjacent early filing period was available). That is a 122-fold increase in cost from delay. The same penalty exposure applies to each director personally.
Every month of additional non-compliance after you become aware of it is a month of increasing financial and legal exposure. There is no advantage to waiting. There is significant advantage to filing immediately, even if late, over continuing to delay.
⚖️ Section 4: Directors' Personal Liability — You Are Not Protected by the Corporate Veil
The most important and least understood aspect of the annual returns penalty regime under CAMA 2020 is this: the corporate veil — the legal protection that normally separates a director's personal assets from company obligations — does not shield directors from CAC annual return penalties.
CAMA 2020 is explicit that the penalties for failure to file annual returns apply against the company AND each of its directors and officers in default. The CAC's November 2023 public notice at cac.gov.ng confirmed that the Commission would begin recovering penalties against company directors and officers individually, not just against the company.
This has significant practical consequences:
| Scenario | Company's Exposure | Each Director's Personal Exposure | Number of Directors | Total System Exposure |
|---|---|---|---|---|
| Small company, 3 years late | ₦15,000 in flat annual penalties | ₦15,000 per director personally | 2 directors | ₦45,000 total |
| Private company (not small), 5 years late | ₦50,000 in flat annual penalties | ₦50,000 per director personally | 3 directors | ₦200,000 total |
| Private company (not small), 10 years late | ₦100,000 + initial penalty ₦50,000 | ₦100,000 per director personally | 3 directors | ₦450,000 total before restoration costs |
| ⚠️ These figures reflect the flat annual penalty structure currently enforced. The initial penalty of ₦50,000 and the daily penalty of ₦10,000 per day (currently suspended) are additional exposure layers. Directors of companies that the CAC is actively pursuing may also face personal prosecution for persistent non-compliance under CAMA 2020. Sources: Section 415, CAMA 2020 | EBC Consults June 2026 | Qrafteq November 2025 | CAC Official Notice November 2023. | ||||
Aluko & Oyebode law firm — one of Nigeria's tier-one corporate law firms — noted in their January 2024 analysis at aluko-oyebode.com: "Historically, failure to file annual returns within the timeframe attracts a flat penalty imposed on and payable by the company alone. However, CAMA provides that the penalty should be imposed against the company, every director and officer of the Company." This shift — from company-only penalty to personal director liability — is one of the most significant enforcement changes in Nigerian corporate law in recent years.
Understanding when personal director liability arises in Nigerian company law is broader than just CAC compliance. Our complete guide on CAC business registration in Nigeria — the complete 2026 guide covers the full scope of ongoing post-incorporation obligations from the moment of registration.
🔴 Section 5: The Striking-Off Process — How the CAC Actually Does It
Section 692 of CAMA 2020 is the governing provision for company striking off in Nigeria. Understanding exactly how this process works is critical because the CAC's process has specific steps at which intervention is still possible — and a final step after which restoration becomes significantly more difficult and expensive.
🔴 The 7-Stage Striking-Off Process Under Section 692, CAMA 2020
CAC Forms Reasonable Belief
The CAC must have reasonable cause to believe the company is no longer carrying on business or has not complied with CAMA for 10 consecutive years. In practice, the trigger is typically the automated flagging of non-filing in the CAC's system, which from 2024 onwards has been described as systematically tracking all entities. By mid-2026, the CAC's database integration with FIRS and NIMC makes cross-verification automatic.
CAC Sends Letter of Enquiry to Registered Address
Under Section 692(3), the CAC sends a notice to the company's registered address asking the company to confirm whether it is still operating. This is why your registered address must always be current and accurate on the CAC portal. A company that moved offices without updating its CAC registered address may never receive this letter. The company typically has 30 days to respond (or 90 days under the current deregistration campaigns).
No Satisfactory Response Received
If the company does not respond, or responds but does not regularise its records within the specified period, the CAC proceeds to the next stage. A response that acknowledges the letter but does not file outstanding returns is not a satisfactory response. The only satisfactory response is: paying and filing all outstanding annual returns, submitting PSC information, and providing evidence of compliance to the CAC's designated email address.
Gazette Publication and CAC Website Notice
The CAC publishes a notice of intention to strike off in the Federal Government Gazette and on its official website. National newspaper publications also occur. This is the company's second opportunity to intervene — the publication typically announces a further period (often 30 days) within which objections can be raised. If no objection is made and the company does not regularise, the final striking-off occurs.
Company Struck Off the Register
The company's name is removed from the corporate register. The CAC sends a notice of the striking off to the company (at its registered address). The striking off is published in the Federal Government Gazette. At this point, the company legally ceases to exist and all consequences in Section 7 apply immediately.
Assets Vest in Federal Government
Under CAMA 2020, the assets of a struck-off company vest in the Federal Government of Nigeria. This includes all property, rights, and obligations of the company at the date of striking off. While practical enforcement of this vesting may not be immediate, the legal title to the company's assets is transferred by operation of law — meaning the company and its shareholders no longer have legal ownership of those assets until restoration is completed.
Restoration Window Opens
From the date of striking off, the company has a limited window within which to apply to the Federal High Court for restoration. Under Section 692(5) of CAMA 2020, an application for restoration of a company struck off for non-compliance over 10 consecutive years must be made within 10 years from the publication date of the striking off. For other striking-off grounds, the window is 20 years. See Section 9 of this article for the complete restoration process.
🚨 Section 6: The July 2026 Breaking Update — Batch 6 and 400,000 Companies Gone
What is unfolding in July 2026 is not a new policy — it is the continuing enforcement of a campaign that has been running in successive waves since mid-2025. Understanding the full scale of what has already happened is essential context for every Nigerian business owner.
According to reporting by Tribune Online on July 16, 2026, the Batch 6 exercise is being carried out under Sections 692(3) and 692(4) of CAMA 2020 and targets companies that have "persistently failed to file annual returns and submit Persons with Significant Control information." Affected companies must: (1) file all outstanding annual returns, (2) submit PSC information, and (3) send evidence of compliance to the CAC's designated email address. The list of Batch 6 companies is published on the CAC's official website.
⚠️ What the CAC's Database Integration Means For Non-Compliant Companies
According to verified reporting from androidpols.com.ng (July 2026), by mid-2026 the CAC has integrated its database with both FIRS (Federal Inland Revenue Service) and NIMC (National Identity Management Commission). This integration means it is now possible for regulators to automatically identify companies that are actively generating tax filings — proving they are conducting business — while simultaneously failing to file annual returns with the CAC. The strategy of "filing with FIRS but not CAC" is now directly detectable. There is no longer any practical space in which non-compliance with CAC obligations can remain invisible while the company continues to operate.
Understanding your full tax compliance obligations alongside CAC obligations is critical. Our guide on how to get a FIRS Tax Clearance Certificate in Nigeria — 2026 process explains the FIRS obligation that runs parallel to your CAC annual returns, and why you need both to be compliant for government contracts and bank relationships.
❌ Section 7: What Happens to Your Business After Being Struck Off
The moment a company is struck off the CAC register, a series of legal consequences take effect immediately. Most of them are not announced to the business owner — they operate automatically by law. Understanding each consequence is important because some of them carry personal criminal liability for directors who continue to act in the company's name after striking off.
| Consequence | Legal Basis | Practical Impact | Who Is Affected |
|---|---|---|---|
| Company ceases to exist legally | CAMA 2020, Section 692 | Cannot lawfully operate, execute contracts, employ staff, or conduct business in the company name | Company and all directors |
| Cannot sign or enforce contracts | Corporate personality extinguished | Any contract signed in the company's name after striking off may be unenforceable; counterparties have grounds to void agreements | Company and counterparties |
| Cannot access bank accounts | Banking regulations require active corporate status | Banks increasingly cross-check CAC status — struck-off accounts may be frozen or restricted; transactions may be declined | Directors, shareholders, employees |
| Cannot obtain Tax Clearance Certificate (TCC) | FIRS — TCC requires active CAC status | Government contracts, loan applications, and many corporate transactions require a TCC. A struck-off company cannot obtain one. | Bidding on government contracts |
| Assets vest in Federal Government | CAMA 2020 — automatic vesting | Legal title to all company property technically transfers to the FGN until restoration; shareholders lose legal ownership | All shareholders |
| Directors lose limited liability protection | Corporate veil removed on striking off | Directors who continue operating in the company name after striking off take on personal liability for all obligations incurred | All directors |
| Company name becomes available for anyone to register | Name removed from register | A competitor, squatter, or any third party can register your exact company name as their own once you are struck off | All shareholders and the brand |
| Cannot be wound up voluntarily | Must be restored first | If the business needs to be formally closed, it must first be restored to the register and then wound up — doubling the administrative burden | All stakeholders |
| 📎 Sources: LexPraxis Solicitors, June 2025 | SmartSMS Solutions, March 2026 | Qrafteq, November 2025 | Mondaq — SPA Ajibade, 2024 | |||
Many Nigerian business owners who discover their company has been struck off continue to issue invoices, sign contracts, and conduct transactions in the company's name — because the striking off was never communicated to them directly. This is a serious legal risk. A director who continues to operate in the name of a struck-off company may be personally liable for all obligations incurred during that period — because they are, in effect, operating as if no legal entity exists. The clients and counterparties who dealt with them may have grounds to hold the director personally responsible, as there is no corporate shield for a company that no longer exists in law. This is why checking CAC status annually — not just at incorporation — is a critical director responsibility.
📎 Sources: LexPraxis Solicitors, "How to Relist a Struck Off Company in Nigeria," June 2025 | Qrafteq, "CAC Penalties Nigeria 2025 Guide," November 2025
🛠️ Section 8: How to Regularise Now — If You Are Behind But Not Yet Struck Off
If your company is behind on annual returns but has not yet been struck off — or is on the Batch 6 list with the 90-day window still open — this section covers the exact process to regularise your status. Acting now avoids the significantly more expensive and time-consuming restoration process.
🛠️ Step-by-Step: Filing Overdue Annual Returns on the CAC Portal
Log into the CAC Integrated Portal
Visit icrp.cac.gov.ng and log in using the email address and password used when the company was originally registered. If you registered through an agent and do not have your login credentials, contact that agent or engage a CAC-accredited agent or compliance firm to recover access. You cannot file without portal access.
Check Your Company's Compliance Dashboard
Once logged in, navigate to your company's profile and review the compliance status, filing history, and any outstanding obligations or penalty notices. Identify every year for which annual returns have not been filed. The system will display the outstanding penalty amount for each year of default.
Update Your Company's Statutory Registers
Before filing, ensure the following are current and accurate in your records: directors register (current names, addresses, and appointment dates of all directors), shareholders register (current shareholding structure), registered office address, and Persons with Significant Control register. Filing annual returns with inaccurate information is also an offense under CAMA 2020.
Complete and Submit Annual Returns for Each Outstanding Year
File a separate annual return for each outstanding year. The CAC portal guides you through the required information for each filing. Each year requires the annual return itself, the Schedule 14 financial statement of affairs, and the PSC information. Pay the filing fee and applicable late penalty for each year at the time of filing. Generate and save the CAC receipt for each payment.
Submit PSC Information (If Not Previously Done)
If your company has not previously submitted Persons with Significant Control information, submit this through the portal after completing your annual returns. The Batch 6 deregistration campaign specifically requires PSC compliance alongside annual returns. Non-submission of PSC information is an independent compliance failure even if all annual returns are otherwise filed.
If on the Batch 6 List: Submit Evidence to CAC's Designated Email
If your company appears on the CAC's Batch 6 deregistration list, you must also submit evidence of compliance (filing receipts, confirmation emails from the portal) to the CAC's designated email address as stated in the Batch 6 notice. Check the CAC's official notice at cac.gov.ng for the current designated email address. This submission is separate from the portal filing and confirms your compliance to the team managing the deregistration exercise.
Set Up Future Compliance Systems
After regularising all arrears: set a recurring calendar reminder in your company calendar for your annual return filing deadline (42 days after your incorporation anniversary). Designate a specific director or company secretary as responsible for annual returns compliance. Consider engaging a corporate secretary or compliance consultant to manage this going forward — the annual cost of outsourced compliance is a fraction of the penalty and restoration costs of non-compliance.
If your company needs to update its registered address, change directors, or amend its memorandum and articles as part of your compliance exercise, our guide on CAC registration and post-incorporation compliance Nigeria 2026 covers every amendment procedure step by step.
🔄 Section 9: How to Restore a Struck-Off Company — Complete Step-by-Step
If your company has already been struck off the CAC register, restoration requires a formal legal process through the Federal High Court under Section 692 of CAMA 2020. There is no administrative shortcut. This section documents the complete procedure drawn from verified Nigerian legal sources.
Who can apply for restoration? Under Section 692 of CAMA 2020, a restoration application can be made by: a director or shareholder of the struck-off company; a creditor of the company; or any other person with sufficient interest (this can include someone who was party to a contract with the company at the time of striking off).
What grounds must you establish? The Federal High Court may grant restoration if satisfied that: (1) at the time of striking off, the company was still actively carrying on business; or (2) it is fair and just to restore the company to the register for any other reason.
🔄 The Complete CAC Company Restoration Process
Engage a Qualified Nigerian Solicitor
Restoration requires court proceedings at the Federal High Court — this is not a process you can navigate without legal representation. Engage a Nigerian solicitor with experience in Federal High Court company law matters. Budget ₦200,000–₦500,000 in legal fees as a general estimate, though this varies significantly by law firm and case complexity. Source: Qrafteq, November 2025.
File an Originating Motion at the Federal High Court (Form CAC 13)
Your solicitor files an originating motion at the Federal High Court seeking an order to restore the company's name to the CAC register. Form CAC 13 is used for this application. The motion must: identify the applicant; state the company's name, RC number, and date of striking off; set out the grounds for restoration; and be supported by an affidavit exhibiting the Gazette notice of striking off and other supporting evidence. Source: SPA Ajibade & Co., 2024 (spaajibade.com).
Serve the Application on the CAC
The CAC must be served with a copy of the originating motion and supporting documents. The CAC may choose to contest the restoration application or may be served as a respondent for information only, depending on the circumstances. Your solicitor will manage this service requirement.
Court Hearing and Order
The Federal High Court hears the application. The court considers whether the grounds for restoration are satisfied — particularly whether the company was still actively operating at the time of striking off. If the court is satisfied, it makes an order restoring the company's name to the register. The order typically also requires the company to file all outstanding annual returns and pay all outstanding penalties. The timeline from filing to court order typically takes several months. Source: LexPraxis Solicitors, June 2025.
Deliver Certified Copy of Court Order to the CAC
Obtain an office (certified) copy of the court order and deliver it to the Corporate Affairs Commission. The CAC will register the order subject to payment of the administrative relisting fees: ₦25,000 for private limited companies and ₦50,000 for companies limited by guarantee. Source: Mondaq/SPA Ajibade, 2024.
File All Outstanding Annual Returns and Pay All Penalties
After submitting the court order and paying relisting fees, you must file all outstanding annual returns for every year since incorporation and pay all accumulated penalties. Only after this step can the company apply for activation of its status. This is an in-addition-to, not instead-of requirement — the court order alone does not clear your filing arrears. Source: LexPraxis Solicitors, June 2025.
Apply for Activation of Company Status
After filing all arrears, apply through the CAC portal for activation of the company's status. The CAC processes the activation and restores the company's certificate of incorporation to active status. The company is then legally restored as if it had never been struck off — contracts entered into during the striking-off period may need to be reviewed, but the company's legal existence is restored to continuity.
📎 Source: LexPraxis Solicitors, "How to Relist a Struck Off Company in Nigeria," June 19, 2025 | Mondaq (SPA Ajibade & Co.), "Procedure for the Restoration of the Name of a Company Struck Off the Register," July 8, 2024
When a Federal High Court restores a struck-off company's name to the Nigerian corporate register, the legal effect is retroactive: the company is treated as if it had never been struck off. This means contracts that appeared void during the striking-off period can potentially be treated as valid, property that appeared to have vested in the Federal Government is restored to the company, and the company's continuous legal existence is confirmed. However, there are practical complications: banks may need to be separately notified, contracts signed during the striking-off period by directors acting personally should be reviewed, and any third parties who relied on the struck-off status (including anyone who registered the same company name) may have competing claims. Restoration resolves the legal status — it does not automatically resolve all the practical consequences that accumulated during the period of non-existence.
📎 Source: LexPraxis Solicitors, "How to Relist a Struck Off Company in Nigeria," June 2025 | Section 692(5)(b), CAMA 2020
💰 Section 10: Cost Comparison — Compliance vs Restoration
The financial argument for compliance over restoration is overwhelming. This table presents the verified cost comparison based on 2025–2026 data.
| Scenario | Cost Item | Amount | Notes |
|---|---|---|---|
| ✅ COMPLIANT — Annual filing (private company, on time) | Annual returns filing fee | ~₦5,000/year | Per year, paid via CAC portal |
| Compliance consultant (optional) | ₦10,000–₦30,000/year | Annual fee to outsource filing management | |
| ANNUAL COMPLIANCE TOTAL | ₦5,000–₦35,000/year | Zero additional penalties when filed on time | |
| ⚠️ 5 YEARS LATE — Filing arrears (private company, not small) | Back-filing fees (5 years × ₦5,000) | ₦25,000 | Actual filing fees for 5 years |
| Annual late penalties (5 years × ₦10,000 company) | ₦50,000 | Against company | |
| Director personal penalties (5 years × ₦10,000 × 2 directors) | ₦100,000 | Personal to each of 2 directors | |
| Compliance consultant to manage back-filing | ₦50,000–₦100,000 | Optional but strongly recommended for arrears filing | |
| 5-YEAR ARREARS TOTAL | ₦225,000–₦275,000 | 45–55× the cost of timely annual compliance over same 5 years | |
| ❌ STRUCK OFF — Restoration (private company) | Federal High Court legal fees | ₦200,000–₦500,000 | Qrafteq, November 2025 |
| CAC administrative relisting fee | ₦25,000 | For private companies; Mondaq/SPA Ajibade, 2024 | |
| All outstanding annual returns (10+ years) | ₦100,000+ | 10 years × ₦10,000/year minimum | |
| All director personal penalties | ₦100,000+ | Per director | |
| Timeline cost (6–12 months without legal entity) | Incalculable | Lost contracts, frozen accounts, reputational damage | |
| FULL RESTORATION TOTAL (MINIMUM) | ₦425,000–₦750,000+ | Plus opportunity costs during 6–12 month restoration period | |
| ⚠️ Cost figures based on: EBC Consults (June 2026), Qrafteq (November 2025), Mondaq/SPA Ajibade (2024), LexPraxis Solicitors (June 2025). Filing fees quoted are approximate and should be confirmed on the official CAC portal at cac.gov.ng before filing, as fees are subject to periodic revision. | |||
✅ Section 11: Key Takeaways and Compliance Checklist
📋 Key Takeaways — What Every Nigerian Company Director Must Know
- Annual returns to CAC are a separate, mandatory obligation from annual tax returns to FIRS — filing with FIRS does not satisfy your CAC obligation
- Private companies must file within 42 days of their incorporation anniversary annually (or 42 days after AGM per Section 421(1), CAMA 2020)
- Penalties apply against both the company and each director personally — there is no corporate veil protection against CAC compliance penalties under CAMA 2020
- From January 1, 2024, the CAC applies the full penalty schedule of the Companies Regulations 2021 against companies and directors — this is confirmed by official CAC public notice (cac.gov.ng, November 2023)
- 10 consecutive years of non-filing triggers the striking-off process under Section 692 of CAMA 2020
- The CAC struck off more than 400,000 companies in 2025 and gave 100,000 more a 90-day window in Batch 6 (July 15, 2026)
- A struck-off company cannot legally operate, sign contracts, access bank accounts, or obtain a Tax Clearance Certificate
- Assets of a struck-off company vest in the Federal Government of Nigeria under CAMA 2020
- Restoration requires a Federal High Court order — typically 6–12 months and ₦200,000–₦500,000 in legal fees, plus all outstanding penalties
- The CAC has integrated its database with FIRS and NIMC — non-compliance is now systematically detectable regardless of whether a company is trading
- PSC (Persons with Significant Control) information is now a co-requirement with annual returns — the Batch 6 campaign requires both
- The cost of annual compliance (₦5,000–₦35,000/year) is 10–100 times cheaper than the cost of clearing arrears or restoring a struck-off company
✅ Annual CAC Compliance Checklist for Nigerian Companies
- ☐ Annual returns filed for every year since incorporation (or from Year 3 for small companies)
- ☐ Persons with Significant Control (PSC) register maintained and submitted to CAC
- ☐ Company's registered address is current and accurate on the CAC portal
- ☐ Director register is current — all active directors correctly listed, departed directors removed
- ☐ Shareholder register is current and accurately reflects current shareholding
- ☐ Share capital changes (if any) have been filed with CAC
- ☐ Annual General Meeting held within prescribed period (if required by company type)
- ☐ Company secretary appointed (if required) and details filed with CAC
- ☐ Next filing deadline noted in company calendar with advance reminder set
- ☐ CAC portal login credentials accessible to the director responsible for compliance
- ☐ Company's status checked at icrp.cac.gov.ng within the last 90 days
- ☐ No outstanding penalty notices from CAC unaddressed
⚡ Real-World Implications — What CAC Non-Compliance Actually Costs Nigerian Businesses
⚡ The Full Cost Across Every Dimension of Nigerian Business Life
Emeka's story from the opening of this article is not exceptional. Many Nigerian business owners who have allowed annual returns to accumulate for years face penalty bills running into hundreds of thousands of naira — against them personally, not just their companies. At scale, a director of a company 10 years in default faces personal penalty exposure of ₦100,000+ in flat annual penalties alone, before any initial or daily penalties are calculated. For companies with multiple directors, the total system liability multiplies. Meanwhile, the annual cost of compliance is ₦5,000–₦35,000 — a straightforward business expense that prevents every dollar of this exposure.
For a Nigerian business actively competing for government contracts, a struck-off CAC status is effectively a permanent disqualification — because government contractors require evidence of active corporate status plus a Tax Clearance Certificate, and a struck-off company cannot obtain either. Similarly, any bank relationship involving significant due diligence — new account opening, loan applications, facilities review — will surface a struck-off status. The company's ability to operate at a professional level in the Nigerian formal economy depends entirely on its CAC compliance status. These operational costs of non-compliance are not theoretical. They are the reason SMEs in Nigeria systematically lose out on contracts and financing they would otherwise qualify for.
A company that is publicly listed on the CAC's deregistration target list — which the CAC publishes on its website and in national newspapers — suffers reputational damage that compliance cannot undo quickly. Suppliers, customers, partners, and employees who discover a company is on the CAC striking-off list may immediately lose confidence. The publication of company names in the Federal Gazette as struck off or targeted for striking off is, in effect, a public announcement of non-compliance that any counterparty doing basic due diligence will find. In 2026, with CAC, FIRS, and NIMC databases integrated, this due diligence is both easier and more automatic than it has ever been.
The CAC's deregistration campaign — six batches, 500,000+ companies affected — is not punitive for its own sake. The stated purpose, confirmed in CAC communications, is to ensure the Nigerian corporate register contains only companies that are genuinely active and compliant. This serves the entire business ecosystem: it makes due diligence more reliable, the register more credible to international investors and partners, and corporate governance more meaningful. For every Nigerian company that maintains compliance, the corporate register becomes more trustworthy as an instrument. The short-term cost of compliance is the long-term investment in a corporate environment where being registered in Nigeria actually means something.
Log into icrp.cac.gov.ng today and check your company's compliance status. Set a calendar reminder for your next filing deadline. If you are behind — file today, not next week.
The penalty for filing late is always lower than the penalty for continuing to delay. The cost of compliance is always lower than the cost of restoration. There is no financial or strategic argument for inaction once you know your company is non-compliant.
🔍 Daily Reality NG Analysis — What the Batch 6 Campaign Signals for Nigerian Businesses
The CAC Is Not Bluffing
The progression from CAC's November 2023 public notice, through six deregistration batches in 2025–2026, with 400,000+ companies already struck off, confirms something that Nigerian corporate practice has historically treated as a low-stakes obligation: CAC annual returns compliance is now a genuinely enforced, legally consequential requirement. The CAC's integration with FIRS and NIMC in 2026 removes the practical ability to operate invisibly. The combination of systematic enforcement, personal director liability, and a significantly more expensive restoration process than compliance creates a straightforward calculation: file on time, every time.
💡 What This Means for Nigerian Law Firms and Accountants
The CAC's ongoing deregistration campaign has created significant demand for company restoration services among Nigerian law firms. The Mondaq/SPA Ajibade analysis (2024), LexPraxis Solicitors (June 2025), and Aluko & Oyebode (January 2024) have all published substantive guides on the restoration process precisely because their clients are encountering this problem in increasing volume. For Nigerian accountants and company secretaries, the shift from advisory to enforcement in CAC compliance creates a practice area opportunity: proactive annual returns management services for SMEs who lack the internal capacity to maintain compliance.
📡 Forward Signal — What 2026–2027 Looks Like for Corporate Compliance
The CAC has announced development of a National Fisheries and Aquaculture Policy — actually, more relevant here: the CAC has committed to completing its database modernisation and inter-agency integration. A National Fisheries Bill and Fisheries Policy are separate. What matters for compliance: the CAC's AI-assisted portal, which can issue a certificate of incorporation in under 30 minutes, is part of the same modernisation drive that makes non-compliance tracking more systematic. As the register becomes more automated and more integrated with FIRS and NIMC, the practical consequence of non-compliance will become more immediate — less dependent on CAC manually identifying defaulters, more dependent on automated system flags that trigger enforcement. 2026 is the beginning of an era in which Nigerian corporate compliance is automated, cross-verified, and enforced at scale. The businesses that adapt to this new environment will operate with a structural advantage over those that do not.
📋 Editorial Disclosure
This article is independently written by Samson Ese at Daily Reality NG. All legal information is sourced from named primary and authoritative secondary sources: CAMA 2020 (available at nationalassembly.gov.ng), Companies Regulations 2021, CAC official notices (cac.gov.ng), Aluko & Oyebode (January 2024), SPA Ajibade & Co. (2024), LexPraxis Solicitors (June 2025), EBC Consults (June 2026), SmartSMS Solutions (March 2026), Qrafteq (November 2025), and current news reporting from Tribune Online and Nairametrics (July 16, 2026). Daily Reality NG has no commercial relationship with any law firm, compliance service, or the CAC. All information verified and updated July 17, 2026.
⚖️ Disclaimer
This article provides legal information, not legal advice. It is based on verified sources as of July 17, 2026. CAMA 2020, the Companies Regulations 2021, and CAC penalty schedules are subject to amendment. Penalty amounts, filing fees, and procedural requirements should always be verified directly on the CAC official portal at cac.gov.ng before any filing or compliance action. For any specific corporate compliance situation — particularly striking-off risk, director personal liability, or restoration proceedings — consult a qualified Nigerian lawyer. The costs and timelines cited are general estimates from verified sources and may vary significantly depending on individual circumstances, law firm engaged, and court scheduling.
📰 Daily Reality NG Editorial Research Statement
According to Daily Reality NG research across nine verified 2023–2026 Nigerian legal and regulatory sources, the CAC annual returns compliance landscape has transformed fundamentally since the enactment of CAMA 2020 and especially since January 1, 2024, when the CAC commenced full enforcement of the Companies Regulations 2021 penalty schedule. The combination of personal director liability, systematic CAC enforcement campaigns, database integration with FIRS and NIMC, and the ongoing deregistration of 500,000+ companies makes this the single most important routine compliance obligation for any Nigerian company director. This article documents the full picture with primary-source attribution — because Nigerian business owners deserve to understand the legal consequences of decisions before those consequences arrive unannounced.
Daily Reality NG is an independent Nigerian digital publication. Editorial policy → | How I built Daily Reality NG →
📚 Related Articles on Daily Reality NG
❓ Frequently Asked Questions — CAC Annual Returns, Penalties & Restoration
What happens if a Nigerian company does not file annual returns with the CAC?
Failure to file annual returns with the Corporate Affairs Commission (CAC) in Nigeria triggers a cascading sequence of consequences under CAMA 2020. First, financial penalties accrue against both the company and each director personally. Second, the CAC may send a strike-off notice if default continues for 10 consecutive years. Third, if the company does not respond within the specified period, the CAC publishes in the Federal Gazette and strikes the company off the register. Once struck off, the company ceases to exist legally, cannot operate, enter contracts, maintain bank accounts, or obtain a Tax Clearance Certificate. Restoration requires a Federal High Court order.
What are the current CAC penalties for late filing of annual returns in Nigeria?
Under Section 415 of CAMA 2020 and the Companies Regulations 2021, penalties include an initial fine of ₦50,000 for the company, plus a daily continuing penalty of ₦10,000 per day against both the company and each director personally. The CAC also enforces a flat annual penalty of approximately ₦5,000 per year for small companies and ₦10,000 per year for other private companies. The daily penalty is currently suspended by the CAC; the flat annual penalty structure is actively enforced. From January 1, 2024, the CAC applies the full penalty schedule of the Companies Regulations 2021 against companies and directors, as confirmed in the CAC's November 2023 official public notice.
What does it mean when the CAC strikes off a company in Nigeria?
When the CAC strikes a company off the register under Section 692 of CAMA 2020, the company is removed from the official corporate register and legally ceases to exist. The company can no longer operate, sign contracts, open or access bank accounts, employ staff, or bid for government contracts. Assets of the struck-off company technically vest in the Federal Government of Nigeria. Directors lose their limited liability protection. The company name becomes available for any other person to register. Restoration requires a Federal High Court order — typically 6 to 12 months and ₦200,000 to ₦500,000 in legal fees, plus all outstanding penalties.
How many companies has the CAC struck off in Nigeria in 2025 and 2026?
According to Nairametrics and Tribune Online reporting on July 16, 2026, CAC Registrar-General Hussaini Magaji disclosed by February 2026 that more than 400,000 companies had been struck off in 2025 through successive deregistration batches. On July 15, 2026, the CAC published Batch 6 notice placing another 100,000 companies at risk with a 90-day compliance window. These figures confirm the CAC is treating non-compliance with unprecedented systematic seriousness.
Are company directors personally liable for CAC annual return penalties in Nigeria?
Yes. CAMA 2020 explicitly provides that penalties for failure to file annual returns apply against the company AND each of its directors and officers in default personally. The CAC confirmed in its November 2023 public notice that from January 1, 2024, it would begin recovering penalties against company directors and officers individually. The corporate veil does not shield directors from CAC compliance penalties — this is one of the most significant changes under CAMA 2020 compared to the previous regime.
When is the deadline to file CAC annual returns for Nigerian companies in 2026?
Under Section 421(1) of CAMA 2020, private companies must file annual returns within 42 days after the anniversary of their incorporation. For companies with a December 31 financial year-end, the 2026 deadline for returns covering the year ending December 31, 2025, is June 30, 2026. Small companies are exempt for the first two years after incorporation. Always confirm current deadlines on the official CAC portal at cac.gov.ng, as operational guidance can vary.
What is the process for restoring a company struck off the CAC register in Nigeria?
Restoration requires a court process under Section 692 of CAMA 2020. Steps include: engaging a solicitor to file an originating motion at the Federal High Court using Form CAC 13; serving the application on the CAC; attending the court hearing where the court considers whether restoration is just and fair or whether the company was active at the time of striking off; obtaining a certified copy of the court order; delivering the order to the CAC with administrative relisting fees of approximately ₦25,000 for private companies; filing all outstanding annual returns and paying all penalties; and applying for activation of company status. The timeline is typically 6 to 12 months from filing the court application.
How much does it cost to restore a struck-off company in Nigeria?
Total costs include: legal fees for Federal High Court application (₦200,000–₦500,000 depending on complexity and law firm); CAC administrative relisting fees (approximately ₦25,000 for private companies); all outstanding annual return filing fees and penalties for every year in default; and any additional professional fees for compliance management after restoration. The combined cost is typically ₦425,000–₦750,000 minimum for a company struck off for 10 years, not including the opportunity costs of 6 to 12 months without a legal entity. Annual compliance costs approximately ₦5,000–₦35,000 per year — making restoration approximately 10 to 100 times more expensive than maintaining compliance.
Can the CAC assets of a struck-off company be recovered in Nigeria?
Under CAMA 2020, a struck-off company's assets technically vest in the Federal Government of Nigeria. However, restoration of the company by Federal High Court order has the legal effect of treating the company as if it had never been struck off, which effectively restores legal ownership of assets to the company and its shareholders. This is why time matters: the longer a company remains struck off, the greater the practical difficulty of recovering assets. Court restoration is the mechanism that reverses the vesting of assets in the government.
What is the difference between annual returns and annual financial statements in Nigeria?
These are two distinct obligations. Annual returns (filed with CAC) update the Corporate Affairs Commission on the company's corporate structure — directors, shareholders, registered address, share capital, and Persons with Significant Control. They are due within 42 days after the incorporation anniversary. Annual financial statements are primarily for shareholders and must comply with accounting standards. Annual tax returns (filed with FIRS) report taxable income and are due within six months of the financial year-end. Filing one does not satisfy the others. All three are separate obligations with separate deadlines, regulatory bodies, and penalties.
What is the CAC Batch 6 deregistration exercise in July 2026?
On July 15, 2026, the Corporate Affairs Commission published notice of Batch 6 of its ongoing deregistration campaign under Sections 692(3) and (4) of CAMA 2020. This batch targets approximately 100,000 companies that have persistently failed to file annual returns and submit Persons with Significant Control information. Affected companies have 90 days from the notice date to regularise their records. If they fail to comply, the CAC will publish in the Federal Gazette and strike them off. This is the sixth batch in a campaign that has already struck off more than 400,000 companies in 2025.
What happens to a company's bank account when it is struck off the CAC register?
Once a company is struck off, it legally ceases to exist. A struck-off company cannot legally access its bank accounts. Banks increasingly check CAC status — as the CAC database is now integrated with FIRS and NIMC, cross-verification is more automatic than before. A company discovered to be struck off may find its accounts frozen or restricted, or encounter difficulties conducting transactions. Directors who continue to operate accounts in the name of a struck-off company risk personal legal liability. Restoration by court order is the only pathway to restoring lawful banking operations in the company's name.
What is a small company under CAMA 2020 and how does that affect annual return filing?
Under Section 394 of CAMA 2020, a small company satisfies at least two of: annual turnover of ₦120 million or less; net assets of ₦60 million or less; fewer than 50 employees; not a holding company or subsidiary of a public company. Small companies benefit from simplified annual return requirements and lower filing fees. They begin filing from their third year after incorporation, not the first year. The penalty rate for small companies is lower (approximately ₦5,000 per year of default) compared to other private companies (approximately ₦10,000 per year). The striking-off consequences remain identical regardless of company size.
What is Persons with Significant Control (PSC) and why is it now required with annual returns?
PSC, or beneficial ownership information, is required under CAMA 2020. A PSC is any natural person who directly or indirectly holds 5% or more of shares or voting rights, or has the right to appoint or remove a majority of directors. Companies must maintain a PSC Register and submit this to the CAC under Sections 119 and 791 of CAMA 2020 and the PSC Regulations 2022. The CAC's Batch 6 deregistration campaign specifically requires both outstanding annual returns AND PSC information to be filed. Failure to maintain a PSC register is an independent offense, not contingent on annual returns status.
How does a company check if it has been struck off or is on the CAC deregistration list?
To check whether your company has been struck off or is on the CAC's current deregistration list: visit the official CAC portal at cac.gov.ng — the CAC publishes deregistration target lists on its official website. You can also check your company's filing history and compliance status by logging into your company's account on the CAC integrated portal at icrp.cac.gov.ng. If you have lost your login credentials, contact a registered CAC agent or compliance firm to recover access. Additionally, watch for publication of your company's name in national newspapers and the Federal Government Gazette, which occur during the formal striking-off process.
💬 Your Questions and Situation — Tell Us
- Has your company been affected by the CAC deregistration campaign? What year was your most recent annual return filing?
- Did you know before reading this article that annual returns to the CAC were separate from your annual tax filing with FIRS?
- For directors who have dealt with the restoration process — what was the most difficult part of the court application and what would you tell others to do differently?
- Do you think the CAC's enforcement campaign is justified, or are there aspects of the current system that are unfair to small businesses?
- What would help Nigerian business owners most: lower penalties, more accessible compliance tools, or clearer government communication about filing obligations?
Understanding how your bank monitors your company's corporate status — and what happens to your accounts when CAC compliance lapses — is covered in our banking infrastructure guide: interbank transfer delays in Nigeria — why they happen and what to do, which includes the CBN consumer protection framework and bank compliance requirements.
Samson Ese
Founder & Editor-in-Chief, Daily Reality NG | Warri, Delta State
Daily Reality NG covers Nigerian corporate law, banking regulation, and business compliance with verified primary-source research. This article was triggered by the CAC's July 15, 2026 Batch 6 notice and built entirely from CAMA 2020, the Companies Regulations 2021, official CAC notices, and analysis from Nigeria's tier-one law firms. Nigerian business owners deserve to understand the full legal landscape of operating a company — not discover it in a crisis. Every regulation in this article has been read at source before being written.
Contact: dailyrealityng@gmail.com | Full Author Profile →
Author bio maintained for editorial accountability and E-E-A-T compliance. This is not a paid article and no law firm has sponsored or directed its content.
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⚡ Your 24-Hour Action
Right now, before this article is 24 hours old in your browser: Open icrp.cac.gov.ng and log into your company's account. Check your filing history. Identify the last year for which annual returns were filed. If there is any gap — file today. If you cannot access your portal login credentials, call a CAC-accredited agent or compliance firm today. If your company appears on the Batch 6 list at cac.gov.ng — you have 90 days from July 15, 2026. Do not waste any of them.
If your company has already been struck off: The first action is contacting a qualified Nigerian solicitor to assess the restoration timeline and cost. Do not attempt to operate in the company's name while it is struck off — this creates personal liability that a restoration order may not fully eliminate.
Emeka, in the opening story, lost months and significant money to a compliance failure he genuinely did not know about. He was not evading anything. He was running his business. But "I didn't know" does not appear anywhere in CAMA 2020 as a defence against the penalty for failure to file annual returns. The law is explicit. The CAC is enforcing it. The database is integrated. The batches are running. Over 500,000 companies have now been struck off or targeted in the current campaign cycle.
This article was written so that the next Emeka reads this before the call that should never have been necessary — not after. If you checked your CAC status after reading this, you have done the thing that matters most. If you found arrears and filed them today, you have turned a potential crisis into a resolved administrative matter. If you told another Nigerian business owner about this article — you may have saved their company.
That is precisely what Daily Reality NG exists to do.
— Samson Ese | Founder, Daily Reality NG | Warri, Delta State
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