Accounts for a Nigerian incorporated trustees body

Which framework a Nigerian NGO registered as incorporated trustees reports under, what goes to the CAC with its annual return, and the records to keep.

By Achekam · 11 October 2026 · 5 min read · For Accountants & audit firms in Nigeria

A non-governmental organisation registered as incorporated trustees is not a company, but much of its reporting looks like one. It keeps accounting records, prepares annual accounts, has them audited and files them with the Corporate Affairs Commission. What differs is the timetable, the interim reporting and, for some bodies, the question of which accounting framework applies.

This article is for the accountant preparing an NGO's accounts: what the CAC expects with the annual return, the bi-annual statements that run alongside it, the framework question, the records the body must keep, and how to prepare the set in Achekam.

What goes to the CAC each year

Under the Companies and Allied Matters Act, 2020, the trustees of an incorporated association must submit an annual return to the CAC not earlier than 30 June or later than 31 December each year, other than the year of incorporation. The return must be accompanied by the audited statement of accounts for the year of return. It also shows the trustees, the council or governing body members, land held and changes to the constitution.

Regulation 36 of the Companies Regulations 2021 adds that a copy of the register of members is attached to every annual return, and regulation 33 fixes the association's financial year as 1 January to 31 December. So the accounts are always calendar-year accounts, and they must be audited before the return can be complete. The audit side is covered in audited accounts for incorporated trustees.

Bi-annual statements of affairs

Alongside the annual return, regulation 32 requires incorporated trustees to file bi-annual statements on Form CAC/IT 5, made up to 30 June and 31 December each year, not later than 15 July and 15 January following. CAMA section 845 is the provision behind them.

For the preparer, these are a reason to keep the books current all year. A body whose records are only brought up to date for the annual accounts will struggle to file the half-year statement by mid-July. A monthly close, even a light one, makes both the bi-annual statements and the year-end set easier, and gives the auditor two interim reference points.

Which framework applies

This is the question that needs a documented answer. The IFRS Foundation's jurisdiction profile for Nigeria states that IFRS Standards are required for the financial statements of all public interest entities, and that this term includes not only quoted and unquoted companies but also governments, government organisations and not-for-profit entities that are required by law to file returns with regulatory authorities.

Incorporated trustees are required by law to file annual returns with the CAC. Whether that brings a particular NGO within the profile's description is a judgement the firm should make and record for each client, taking account of who regulates it and what it files. Two cautions apply. The profile was last updated on 16 June 2016, and the FRC's own pronouncements govern. And the answer drives everything that follows, from the policies to the disclosures, so settle it before drafting rather than after. The framework choice in general is discussed in the Nigerian SME financial reporting framework.

Records to keep for six years

CAMA section 375 requires a company's accounting records to be kept at its registered office or another place in Nigeria the directors think fit, open to inspection by its officers, and preserved for six years from the date they were made. Section 847 requires incorporated trustees, too, to preserve their records for six years. For companies, section 374 describes what the records should contain: day-to-day entries of all money received and spent, and a record of assets and liabilities. That is a sensible standard for an association's books as well.

For an NGO, that means donation records, grant agreements and restricted-fund workings, as well as the cash book. For companies, section 375(3) allows electronic copies to be kept in addition to hard copies; agree with the trustees how their own archive will be kept, and where, before the first set is finished.

Preparing the set in Achekam

Each client's profile in Achekam has a Jurisdiction section with the client's own country and identifiers, and each Nigerian engagement shows its governing basis: regulator, standards, framework, company law and tax authority. Record the framework conclusion there, so that every engagement for the body starts from it. A jurisdiction override is decided by a different person, which suits a judgement as consequential as this one.

From a mapped trial balance, Achekam's Studio builds a draft set of annual financial statements with every figure calculated in code, including the directors' report, the four primary statements, policies, notes and a detailed income statement. The practitioner's report follows the level chosen. For an incorporated trustees body, the report title and wording will need adapting to the trustees rather than directors; a block a person edited is kept when the draft is rebuilt.

The Studio's standard accounting policy wording is based on IFRS for SMEs and labelled for review before issue, and staff can write their own policies. If the firm has concluded that full IFRS applies, those policies need rewriting rather than light editing. Notes take their figures from the mapped trial balance, and facts the trial balance does not hold, such as restrictions on a grant, are left as "[to be completed]" for the preparer to fill in. The drafting method is set out in drafting statements from a mapped trial balance.

Before the set goes to the auditor

1. The framework conclusion is recorded and approved.
2. The accounts cover 1 January to 31 December.
3. Both bi-annual statements for the year were filed, and differences from the year-end figures are explained.
4. Policies match the framework chosen.
5. Every "[to be completed]" placeholder is filled.
6. The register of members is ready to attach to the return.

General guidance only, not advice on your own circumstances. Tax and payroll rules change: check the current position with the authority or your adviser.