CACAnnualReturns.com is operated by Adebayo Oluwole & Associates, a professional practice led by a Chartered Accountant and CAC-accredited agent. We assist businesses, companies and incorporated trustees with annual returns and other CAC compliance filings.
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An NGO with little activity still needs reliable financial records. A statement of affairs can help explain its financial position, but it should not automatically be treated as a replacement for the audited accounts required for incorporated-trustee annual returns.
Annual returns and financial reporting are connected
Section 848 of CAMA 2020 requires incorporated trustees to submit annual returns and an audited statement of accounts for the return year. Sections 845 and 846 address additional reporting and accounting-record obligations. These are different requirements and should not be combined into a single generic document.
A church, association or foundation registered as incorporated trustees should check the filing applicable to its status and period. An organisation’s small size or lack of income does not by itself prove that every accounting or filing requirement has disappeared.
What a statement of affairs explains
A statement of affairs generally describes assets, liabilities and the resulting financial position at a specified date. It can be useful when establishing an organisation’s opening position, documenting a period without substantive operations or explaining incomplete records.
Its purpose, format and supporting evidence should be agreed before preparation. A document used for one application is not automatically suitable for a different statutory filing.
What audited accounts do differently
Annual financial statements report the relevant period and include the information needed to explain the organisation’s income, expenditure, assets, liabilities and accounting policies. An audit is a separate professional examination with an auditor’s report.
A statement prepared by management does not become an audit simply because it has been typed, signed or submitted online. If a portal workflow appears to accept an alternative document, establish the applicable requirement for the particular transaction rather than assuming a universal exemption.
What if the NGO has not started operations?
Prepare an accurate account of what actually happened. “Not trading” does not necessarily mean that the organisation had no transactions. Registration expenses, donations, bank charges, equipment purchases and amounts contributed by trustees can all be relevant.
Check the registration date, financial period, bank records and source of funds. Document why balances are nil where they genuinely are nil. Do not invent income or leave out expenditure to simplify the filing.
Records to gather
- Registration certificate and governing constitution.
- Current trustee and governing-body details.
- Bank statements and cash records.
- Donation, grant and contribution schedules.
- Receipts, invoices and payment records.
- Asset and liability schedules.
- Previous accounts, audits and annual returns.
If records are missing, identify the gaps and reconstruct them from reliable evidence. Avoid signing a statement whose figures you cannot explain.
Preparation and filing workflow
- Identify the precise return year and statutory filing.
- Reconcile the bank, cash and supporting schedules.
- Prepare appropriate financial statements or supporting schedules.
- Arrange the required audit and resolve queries.
- Confirm the trustee and organisation details.
- Complete the annual-return application and retain the available filing documentation.
Practical questions
Does a nil bank balance remove the filing obligation?
No automatic conclusion follows from the bank balance. Check the organisation’s obligations and the full financial position.
Can one statement cover several return years?
Do not assume so. The reporting period and figures should match each filing.
Can accounting software help?
Accurenza is complete accounting software with a payroll module. Keeping transactions and accounting records organised helps preparation, but software does not replace the professional work required for an audit.
Related guidance
Professional filing support
Adebayo Oluwole & Associates is a professional practice led by a Chartered Accountant and CAC-accredited agent. We review your entity details, identify outstanding years and agree the scope before filing.
Updated 13 October 2026. Published by Adebayo Oluwole & Associates.
Adebayo Oluwole is Managing Partner of Adebayo Oluwole & Associates, a Chartered Accountant, ICAN Fellow, tax consultant and CAC-accredited agent. His practice provides CAC annual returns, registration and post-registration compliance support alongside accounting and tax consultancy services.
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