1.0 Introduction
On July 7, 2026, the Corporate Affairs Commission (the “Commission”) released a circular notifying the general public, and in particular, companies registered under the Companies and Allied Matters Act 2020 (or any enactment repealed by the Act), that it would start the enforcement of the provisions of Sections 304 (1) and (2) and 729 (1)(c) of the Companies and Allied Matters Act, 2020 (the “Act”), with respect to business letters and the attendant consequences for non compliance effective August 1, 2026.
2.0 The Act and its Provisions
The obligations highlighted in the circular are not new; they have always formed part of the Act but will now be subject to stricter regulatory enforcement.
Specifically, Sections 304(1) and (2) of the Act require every company incorporated under the Act or any enactment repealed by it to disclose specified information relating to its directors on all trade circulars, show cards, and business letters bearing the company's name and issued or sent to any person in Nigeria. The required information includes the present forename (or initials) and surname of each director, any former forename and surname, and the nationality of every director who is not a Nigerian.
In addition, Section 729(1)(c) of the Act requires every company, after incorporation, to state its registered name and registration number in legible characters on all business letters, notices, advertisements, and other official publications, as well as on bills of exchange, promissory notes, cheques, endorsements, orders for money or goods, invoices, receipts, letters of credit, and other prescribed corporate documents.
3.0 Business Impact
The Commission’s circular signals its intention to actively enforce these statutory disclosure obligations from August 1, 2026.
Thus, failure to comply with the relevant provisions of the Act may expose companies to regulatory sanctions, as CAMA empowers the Commission to impose penalties for non-compliance.
While the Commission is yet to specify the nature or scale of the sanctions, companies are advised to achieve full compliance before the enforcement date to mitigate regulatory risk.
4.0 Recommended Steps
1. Ensure that the present forenames (or initials) and surnames of all directors as well as the nationality of every non-Nigerian director, are conspicuously written on the company’s letterhead and official corporate documents.
2. Extend the compliance review to all documents prescribed under Section 729(1)(c) of the Act, including invoices, receipts, cheques, promissory notes, letters of credit, notices, advertisements and other official publications, to ensure that the required statutory information is consistently displayed.
3. Update digital templates, including email signatures, electronic invoices, PDF letterheads, and other electronic business correspondence, to ensure that they comply with the statutory disclosure requirements and not only printed stationery.
4. Implement internal control measures to ensure that all departments consistently use templates that comply with the statutory disclosure requirements.
5. Monitor further guidance from the Commission on the scope of sanctions and non-compliance.
5.0 Conclusion
The Commission’s enforcement drive signals a renewed focus on statutory disclosure compliance and companies should treat the August 1, 2026, deadline as an opportunity to bring their corporate documentation fully in line with the Act, rather than a mere compliance formality. Companies that act early will avoid the uncertainty of the discretionary sanctions and reinforce their standing with regulators, clients and competitors alike.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
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