AI agents for business finance: what they can and can't do
What AI agents can do in bookkeeping, close, collections and compliance today, where a person must stay in charge, and how to judge a product.
The short answer
A Nigerian subsidiary of a US company generally needs audited accounts every year, because CAMA 2020 s.394 excludes companies with a foreign (alien) member from the small-company category that s.402 exempts from audit. The audited accounts then drive two deadlines: the company income tax return within six months of year end (NTAA 2025), and the CAC annual return, which for companies holding an AGM falls within 42 days after it.
Does the subsidiary need an audit at all?
Under CAMA 2020 s.402, a company is exempt from audit if it has not carried on business since incorporation, or if it is a small company under s.394. The s.394 test requires a private company with turnover of not more than ₦120,000,000 and net assets of not more than ₦60,000,000 (or amounts the CAC sets), and also that none of its members is an alien, none is a government or government nominee, and directors hold at least 51% of the equity.
A subsidiary owned by a US company fails the "no alien member" test, so it is not a small company, whatever its size. Unless it has been dormant since incorporation, plan for an annual audit. Section 402 also excludes banks, insurers and companies the CAC prescribes.
| s.394 condition | Typical US-owned subsidiary |
|---|---|
| Private company | Usually yes |
| Turnover not more than ₦120m | May be yes |
| Net assets not more than ₦60m | May be yes |
| No member an alien | No: the US parent is a foreign member |
| Directors hold at least 51% of equity | Usually no: the parent holds the shares |
The AGM and the annual return
CAMA s.237 requires an annual general meeting each year, with no more than 15 months between meetings, except for small companies and companies with a single shareholder. A first AGM held within 18 months of incorporation need not be repeated in that year or the next. The CAC can extend the deadline (other than for the first AGM) by up to three months.
- Companies holding an AGM file the annual return with audited accounts within 42 days after the AGM, per PwC's CAMA compliance summary (s.417-419).
- A wholly owned subsidiary with one shareholder is exempt from the AGM under s.237, and PwC notes that the 42-day framing excludes single-shareholder companies; confirm the filing date the CAC applies to you.
- Annual returns start 18 months after incorporation (s.417), per a Kalepron Attorneys summary.
- The CAC's gazetted fee schedule sets daily default fees for late annual returns; see CAC annual returns for amounts and how to file.
The tax deadline
The audit usually has to finish before the tax return can be filed. NTAA 2025 s.11(5)(a) sets the company self-assessment return at not more than six months after the end of the accounting year; a new company files within 18 months of incorporation or six months after its first accounting period, whichever is earlier (s.11(5)(b)). PwC (May 2026) notes an extension of up to two months at the NRS's discretion, and late-filing penalties of ₦100,000 for the first month and ₦50,000 for each month after.
A timeline for a December year end
Example only. A subsidiary with a 31 December 2026 year end and two shareholders (the US parent and a US-based director holding one share):
| Date | Step |
|---|---|
| January 2027 | Close the books, reconcile banks and intercompany |
| February to April 2027 | Audit fieldwork and US parent sign-off of intercompany balances |
| May 2027 | Directors approve and sign the audited accounts |
| AGM, e.g. 15 June 2027 | Accounts laid before members |
| By 30 June 2027 | Company income tax return on Rev360 (six months after year end) |
| By 27 July 2027 | CAC annual return with audited accounts (42 days after a 15 June AGM) |
Check: 15 June plus 42 days is 27 July (15 days left in June, then 27 in July). If the US parent's own audit needs the subsidiary's numbers in February, the Nigerian timetable has to run earlier still.
Choosing and briefing the auditor
Audit firms in Nigeria range from the international networks to small local practices. For a US-owned subsidiary, ask whether the firm can report in a format the US parent's auditors accept, whether it has audited foreign-owned companies before, and who the engagement partner is. Agree a timetable in the engagement letter that works back from the six-month tax deadline and the parent's reporting date. Give the auditor the intercompany agreements, the board minutes and the bank confirmations authority at the start, because those are the items that usually delay sign-off.
Coordinating with the US parent
- Agree the year end: aligning with the parent makes consolidation easier.
- Appoint auditors early; Nigerian audit firms are busiest before the six-month tax deadline.
- Agree intercompany balances in transaction currency before the audit starts.
- Keep transfer pricing documents with the audit file; see transfer pricing.
- Share the signed Nigerian accounts with the US accountant for any US reporting on the foreign subsidiary.
For what auditors test and how to prepare, see the annual audit of a Nigerian subsidiary. This page is information, not legal or tax advice.
Where Pryme fits
Auditors start with the bank. A Pryme Business Account gives statements per currency, and a verifiable statement through VerifyDoc.ai lets the auditor confirm it is genuine and unaltered. The Compliance agent can track the AGM, CAC and NRS dates.
Questions people ask
Does a foreign-owned Nigerian company need an audit?
Generally yes. CAMA s.394 excludes companies with an alien member from the small-company category, so the s.402 audit exemption does not apply unless the company has not traded since incorporation.
When is the company tax return due in Nigeria?
Within six months after the end of the accounting year under NTAA 2025 s.11(5)(a). New companies file within 18 months of incorporation or six months after the first accounting period, whichever is earlier.
When is the CAC annual return due?
For companies holding an AGM, within 42 days after the AGM, with audited accounts. Single-shareholder companies are exempt from the AGM; confirm their filing date with the CAC.
Does a wholly owned subsidiary have to hold an AGM?
No. CAMA s.237 exempts small companies and companies with a single shareholder.
Sources
- LawGlobalHub: Section 394 CAMA 2020, small companies · accessed Oct 2026
- LawGlobalHub: Section 402 CAMA 2020, exemption from audit · accessed Oct 2026
- LawGlobalHub: Section 237 CAMA 2020, annual general meeting · accessed Oct 2026
- PwC Nigeria: Key compliance obligations under CAMA 2020 and CR 2021 (Apr 2021) · accessed Oct 2026
- Mondaq (Kalepron Attorneys): All you need to know about annual returns with CAC (29 Jul 2024) · accessed Oct 2026
- Nigeria Tax Administration Act 2025 (gazette copy) · accessed Oct 2026
This article is general information, not financial, legal or tax advice. Products described are provided under the terms on this site and are subject to regulation and eligibility.