So, you’ve finally registered your NGO with the Corporate Affairs Commission. Congratulations. That alone deserves applause, considering how long and bureaucratic the process can be. But let’s pause here: registration is not the end—it’s just the beginning.
In Nigeria, thousands of registered NGOs are technically operating illegally—not because they committed fraud, but because they didn’t follow through with post-registration compliance. They think once the CAC certificate is framed and hung on the wall, the job is done.
It’s not.
This is where the real work begins. Whether you’ve just completed your registration or have been operating for years, the items below are not optional—they’re legal and operational necessities.
1. Get a Corporate Bank Account (Not a Personal One)
Let’s start with money.
Your NGO must have its own bank account—not your personal account, not your co-founder’s, not your treasurer’s. Opening a bank account in your organisation’s name is non-negotiable.
For example, one Lagos-based youth development NGO lost a $15,000 grant from a UK donor because their funds were still being received into a founder’s personal account. The donor flagged it as “high-risk” and terminated the partnership.
To open the account, your bank will ask for:
CAC Certificate (Incorporation of Trustees)
Board resolution
Valid IDs of signatories
Tax Identification Number (TIN)
NGO Constitution
If your CAC registration is complete, this should be straightforward. But without the TIN, you can’t proceed. That leads to the next step.
2. Get Your TIN and Open a Tax File
Yes, even as a nonprofit, you’re expected to register with the FIRS and obtain a Tax Identification Number. Being an NGO doesn’t mean you are exempt from all taxes. You are exempt from income tax, but only if you meet the conditions under Section 23(1)(c) of the Companies Income Tax Act—and you must apply for this exemption formally.
Without a tax file, you cannot:
Apply for grants with many international donors
Submit annual returns to CAC
Get clearance certificates
Remit PAYE tax for staff (if you have any)
Don’t wait until FIRS comes knocking. Create your file and stay in the system.
3. File Your CAC Annual Returns – Yes, Every Year
Every registered NGO must file an annual return (Form CAC/IT 4) not later than 30th June of every year, starting from the year after incorporation. This tells the Commission that you’re still active.
Non-filing attracts penalties and can lead to delisting or involuntary dissolution. Once you’re struck off, your organisation loses legal standing—no contracts, no grants, no authority.
Yet, many organisations go for years without filing. Some claim ignorance. But that’s not a valid excuse. Seek professional support if it seems confusing.
4. Register with SCUML If You Receive Funds
If your NGO receives foreign funds or deals in cash above a certain threshold, you are required to register with SCUML, an agency under the EFCC. This is in line with Nigeria’s anti-money laundering laws.
SCUML registration is now required to:
Open or operate bank accounts
Access some donor funds
Avoid being flagged as “high-risk”
Non-registration might block your access to financial systems. Some banks won’t even activate your NGO account without your SCUML certificate. You may also need professional support on this as well.
5. Prepare for PAYE and Pension if You Have Staff
Hiring staff means obligations. That includes remitting PAYE tax to the state tax authority and, in many cases, pension contributions.
A nonprofit in Port Harcourt received a labor complaint when a former staff claimed he was owed pension. He reported to PenCom. Within weeks, the NGO got a demand letter.
Even if you’re paying stipends or project-based salaries, do the right thing: calculate PAYE, deduct it, and remit monthly. It’s a small price to pay for long-term credibility.
6. Develop and Use a Conflict of Interest Policy
Founders, this is for you. Your NGO is not a family business. If your brother wins a procurement contract or your sister is both a board member and program officer, expect trouble.
Most donors now require a Conflict of Interest Policy. It shows that:
The board is independent.
Decisions are made transparently.
You’re not enriching yourself at the NGO’s expense.
Draft this policy and implement it. If the board needs capacity-building to understand it, hold a training. It’s easier than recovering from a scandal.
7. Audit Your Finances (At Least Internally)
You don’t need a Big 4 firm. But you must have basic financial statements—income and expenditure, receipts, donor disbursements. A credible NGO must be transparent. This starts with a proper financial report—income, expenditure, donor inflow, and administrative costs. If possible, get your accounts audited annually. If you can’t afford that yet, at least do internal reporting and share with stakeholders.
Donors are now requesting financial reports before funding. Some will even ask for past audit records. I once consulted with an Oyo-based child health NGO that shared their unaudited financial report on their website, and was picked up by a South African donor looking for grassroots partnerships. The donor cited “transparency” as the reason they reached out.
Start small. Document income. Track expenses. Save receipts. Use basic accounting software if possible.
8. Hold Board Meetings and Document Everything
Your organisation is governed by a Board of Trustees. This board must hold regular meetings and pass key resolutions—such as budget approval, project endorsements, or signatory changes.
All these decisions must be documented. Auditors and regulators (including CAC and FIRS) may ask for:
Minutes of meetings
Resolutions on financial matters
Attendance records
If you’re not documenting these things, you’re breaking internal governance rules, and technically, your board is inactive—even if they show up every weekend to volunteer.
9. Train Your Team on Compliance
One mistake staff often make is spending grant money without understanding the rules. Some think “NGO money” is like “church offering”—use it as needed, explain later.
Wrong.
Train your staff—especially admin and program officers—on:
Procurement processes
Documentation
Financial reporting
Donor expectations
It will save your organisation from crisis, suspension, or even criminal allegations.
10. Seek Legal and Compliance Advice at Least Once a Year
Even if you can’t afford a full-time lawyer, schedule annual legal health checks. A compliance advisor will:
Review your filings
Update your policies
Guide you through audits
Catch small issues before they grow
Don’t assume your NGO is “too small” to get into trouble. Most compliance issues don’t arise from corruption—they come from ignorance, assumptions, or neglect. One consultation can save you millions—or your entire organisation.
You Built It. Now Protect It.
The hardest part of running an NGO isn’t the registration—it’s the structure, the discipline, the systems. It’s the invisible work that doesn’t trend online.
But this is what separates serious organisations from short-lived projects.
If your goal is long-term impact, institutional funding, or eventual growth into a national or regional force, you must embrace compliance—not as a burden, but as the foundation for everything you want to build.
You’ve registered your NGO. Now, build it right.
Opeyemi Oladimeji (LLB, MSc, MBA, NPLM, ACIPM) is the Lead Consultant of DMJ-Global Consulting Limited, and the Team Lead of Future Builders Initiative (FBI). He is an academic researcher, legal analyst, and nonprofit leader specializing in management, resource mobilization and corporate governance. He helps entrepreneurs and organizations build strong foundations for sustainable growth.
