A church, NGO, foundation or association registered as incorporated trustees needs to maintain its registry and financial records. Annual returns are an ongoing obligation separate from registration, trustee changes and tax filings.
Identify the registered organisation
Confirm the exact legal name, registration number, incorporation date and previous returns. A religious or charitable activity does not by itself establish which legal structure was registered. Start with the certificate and governing documents.
The information submitted should match the association’s current records. If trustees, the registered office or constitutional particulars have changed, establish which separate record updates are needed.
Annual-return timing
Section 848 of CAMA 2020 sets a filing window from 30 June to 31 December, excluding the year of incorporation. Review the return period and any other applicable reporting obligations rather than applying a company’s AGM deadline or a blanket 18-month rule.
Maintain a yearly record of submitted and outstanding returns. If several years need work, establish the information for each period before beginning the applications.
Trustee and association particulars
The annual return covers the association and information about trustees and the governing body, with relevant property and constitutional particulars. Prepare current information and the supporting record of changes.
- Legal name, registration number and office details.
- Trustee and governing-body particulars.
- Relevant property information.
- Changes affecting the constitution or registered record.
- Previous returns and any queries.
Accounts and audit requirements
Section 848 requires an audited statement of accounts with the annual return. Section 846 addresses accounting records. A statement of affairs should not automatically be described as a substitute for the required audit.
A period with little activity still needs an accurate record. Donations, grants, contributions, bank charges, assets and unpaid expenses may exist even where programmes have not started.
Gather the bank statements, cash records, receipts, expense schedules, asset information and earlier accounts. Prepare the appropriate financial statements and arrange the required professional audit.
Annual returns and statements of affairs
CAMA also contains a distinct bi-annual statement-of-affairs provision in section 845. That reporting requirement and an annual return with audited accounts should not be treated as the same filing.
Where a particular workflow appears to request an alternative document, clarify the applicable transaction and requirement. Do not infer a universal exemption from a single portal screen. See our guide to statements of affairs and audited accounts.
Preparing and submitting the return
- Establish the organisation’s current record and outstanding years.
- Gather period-specific financial and governance information.
- Prepare the applicable accounts and audit.
- Review the trustee and registered particulars.
- Agree the filing scope and applicable costs.
- Complete the appropriate application and retain its reference.
- Respond to queries and retain the available filing documentation.
If the organisation is inactive
Check what the status actually means. A pending return, an inactive registry record and a dissolution matter are different issues. Do not assume that the routine annual-return process resolves every status problem.
Likewise, changing trustees is not automatically the same task as filing annual returns. Review the applications together so that the supporting information remains consistent.
Keeping future reporting organised
Assign responsibility for maintaining records and reminders. Keep each year’s accounts, audit and filing documentation together. Record trustee decisions and changes promptly rather than reconstructing them only when a bank or grant provider requests evidence.
Accounting software can help organise transactions. Accurenza is complete accounting software with a payroll module; it does not replace the separate audit work required for a statutory filing.
Further guidance
- Church annual-return obligations
- Trustee changes
- National filing guide
- Discuss your organisation’s filing
Legal references: Companies and Allied Matters Act 2020, sections 845, 846 and 848.
Updated 13 October 2026. Published by Adebayo Oluwole & Associates.
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