The corporate affairs commission (CAC) is now strictly enforcing rules that have existed in the Companies and Allied Matters Act (CAMA) 2020 since its enactment. Companies that haven’t complied with these rules (by updating their letterheads and invoices) are already facing rejected fillings and stalled procurement.
WHAT THE LAW ACTUALLY REQUIRES
Two CAMA provisions sit at the center of this enforcement drive, and they apply to two distinct categories of documents.
Section 304(1) and (2) govern a company’s business letters. The provision requires every company registered under CAMA 2020, or under earlier legislation the Act replaced, must state on such letters, in legible characters: the current forename (or initials) and surname of every director; any former forename or surname a director has used; and where a director is not a Nigerian national, that director’s nationality.
Section 729(1)(c) extends a related, but separate disclosure duty to a company’s invoices, receipts, notices, official publications and other business documents. On these, the company must legibly display its registered name, registration number and registered office address.
In plain English; directors particulars belong on business letters under Section 304, while the company’s registration details belong on the broader category of business documents, including invoices, under Section 729. A compliant letterhead must satisfy the first; a compliant invoice must satisfy the second. All companies need both sets of particulars across their stationery to be free from sanctions.
Importantly, Section 304(3) and Section 729(2) make non-compliance a punishable default, exposing the company and any director or officer knowingly in default to sanctions that can accrue for each day the default continues. The obligation to disclose director’s details was always there; what has changed in 2026 is the CAC’s willingness to enforce it.
FROM STATUTE TO ENFORCEMENT
In a public notice dated 7th July, 2026, the CAC stated that it would commence enforcement of Sections 304(1) – (2) and 729(1)(c) from 1 August 2026. The commission stated that the enforcement shall apply to every company registered under CAMA 2020 or any law it repealed, regardless of size, sector or ownership structure. The notice covers business letters specifically, but Section 729(1)(c) extends further into invoices, receipts and other official documents that many companies overlook when auditing compliance.
The Commission cautioned that businesses should not assume non-compliance will attract only nominal consequences, or that any further grace period will be granted beyond the stated commencement date.
BUSINESS IMPACT AND COMPLIANCE CHECKLIST
The commercial consequences are already visible. Public agencies, including the Niger Delta Development Commission, are outrightly rejecting non-compliant corporate correspondence, stalling procurement tenders and vendor onboarding until templates are corrected. To avoid statutory fines and transaction delays, businesses should:
- For business letters (Section 304): confirm every director’s current name, any former name, and nationality (for non-Nigerian directors) appears legibly on letterhead and email signature blocks.
- For invoices, receipts and other business documents (Section 729): confirm the registered company name, RC/BN number and registered office address appear legibly, matching current CAC records.
- Update the register of directors so current names, former names and nationalities are accurate before they are reproduced on official documents.
- Extend the audit to digital document pipelines and automated invoicing systems, not just printed stationery, since Section 729(1)(c) applies equally to these.
