In most states, the president of a nonprofit can also serve as the treasurer. The Revised Model Nonprofit Corporation Act, which forms the basis for most state statutes, expressly allows one individual to hold more than one office at the same time. The harder question is whether you should: putting one person in charge of both strategic leadership and the checkbook removes the most basic check on how money moves through the organization, and both the IRS and your funders will notice.
What State Law Allows
Section 8.40 of the Revised Model Nonprofit Corporation Act requires a nonprofit to have a president, secretary, and treasurer unless the articles of incorporation or bylaws say otherwise, and it permits the same individual to hold more than one of those offices simultaneously. Most state nonprofit corporation acts follow that pattern. The default rule is permissive.
A handful of states impose specific restrictions on particular combinations, so it is worth spending a few minutes with your state’s nonprofit corporation act before finalizing the arrangement. If the statute is silent, the combination is allowed.
Check Your Bylaws and Articles First
State law sets the floor. Your governing documents can raise it. The articles of incorporation are filed with the state and always take legal precedence over the bylaws. If the articles require the president and treasurer to be separate individuals, the board cannot work around that language without formally amending the articles.
Bylaws are where most organizations spell out officer qualifications and any rules about holding multiple positions. Look for the section titled “Officers” or “Duties of Officers.” If neither document prohibits the combination, you are free to proceed. If only the bylaws restrict it, the board can amend them through whatever process the bylaws themselves prescribe, which typically means a board vote at a properly noticed meeting.
How the IRS Views the Combination
The IRS does not prohibit one person from holding both titles, but it treats governance as a signal when reviewing tax-exempt organizations. That attention shows up in Form 990 reporting, in how the agency defines an independent board member, and in the conflict of interest question.
Reporting on Form 990
Every tax-exempt organization filing Form 990 or Form 990-EZ must list all current officers, directors, and trustees, whether or not they are compensated. When one person holds multiple titles, the instructions require you to list all titles for that individual on a single line, with total compensation from the organization and any related organizations reported on the same line. Nothing about that is improper on its face. It does put a visible marker in front of any reviewer that one person controls multiple functions.1Internal Revenue Service. Instructions for Form 990 Return of Organization Exempt From Income Tax (2025)
Board Independence
Federal tax law does not technically require a majority-independent board. The IRS has stated that “the tax law generally does not mandate particular management structures, operational policies, or administrative practices.” During the exemption application process, however, the agency reviews board composition to identify the potential for insider transactions that could result in misuse of charitable assets.2Internal Revenue Service. Governance and Related Topics – 501(c)(3) Organizations
For Form 990 purposes, a voting member of the governing body qualifies as “independent” only if the member received no compensation as an officer or employee, received no more than $10,000 from the organization as an independent contractor (excluding reasonable pay for board service), and had no reportable transactions with the organization. A person serving as both president and treasurer who receives any compensation for those roles does not qualify as an independent member under this definition.1Internal Revenue Service. Instructions for Form 990 Return of Organization Exempt From Income Tax (2025)
Conflict of Interest Policy
Form 990 Part VI asks whether the organization has a written conflict of interest policy, whether officers and directors are required to disclose financial interests annually, and how the organization monitors and resolves conflicts. The IRS defines a conflict of interest as arising when “a person in a position of authority over an organization, such as an officer, director, manager, or key employee can benefit financially from a decision he or she could make in such capacity.” A person who both sets organizational direction and controls the checkbook fits that description closely.1Internal Revenue Service. Instructions for Form 990 Return of Organization Exempt From Income Tax (2025)
A written policy is not legally required, but answering “No” to that question on Form 990 invites scrutiny. If you are combining the president and treasurer roles, treat the policy as necessary. It should require the dual officer to disclose any financial interest in organizational transactions, recuse from board votes on their own compensation, and submit to independent review of any expenses they approve for themselves.
The Tax Penalty for Self-Dealing
Under Section 4958 of the Internal Revenue Code, any “excess benefit transaction” between a tax-exempt organization and a “disqualified person” triggers excise taxes. A disqualified person is anyone who was in a position to exercise substantial influence over the organization’s affairs during the five years before the transaction. A person serving as both president and treasurer meets that definition without argument.3Office of the Law Revision Counsel. 26 U.S. Code 4958 – Taxes on Excess Benefit Transactions
The penalties stack. If the IRS finds that the dual officer received an excess benefit (compensation above fair market value, unauthorized reimbursements, personal use of organizational assets), the officer owes an initial excise tax of 25% of the excess benefit amount. If the excess benefit is not corrected within the taxable period, an additional tax of 200% applies. Board members who knowingly approved the transaction face their own excise tax of 10% of the excess benefit, capped at $20,000 per transaction. The organization does not pay these taxes. The individuals do.3Office of the Law Revision Counsel. 26 U.S. Code 4958 – Taxes on Excess Benefit Transactions
When one person approves their own expenses, sets their own compensation, and controls the records that document those decisions, the conditions for an excess benefit transaction line up almost perfectly. The remaining board members carry the burden of preventing that outcome.
Controls That Compensate for the Missing Separation
The core principle of nonprofit financial management is segregation of duties: no one person should be able to initiate a transaction, approve it, record it, and reconcile the books. Combining the president and treasurer roles removes that separation. Asset misappropriation is the most common form of fraud in small nonprofits, and weak internal controls are consistently identified as the primary enabling factor.
The combination can still work, but it requires controls that produce oversight where the org chart does not. For a small organization, the highest-value measures are:
- Independent bank statement review. A board member who does not handle money receives and reviews the unopened bank statement each month before passing it along for reconciliation. This is the single most valuable control a small nonprofit can put in place.
- Limited check-signing authority. If the dual officer must be able to sign checks, set a low threshold (for example, $200) above which a second signature from another board member is required.
- Periodic financial review. At least one other board member reviews expenses regularly, checking whether amounts look reasonable, whether payroll taxes were paid, and whether expenditures align with the approved budget.
- Dual counting for cash. At any event where cash is collected, two people count together before it is deposited.
- Defined approval chains. Write down who approves invoices, who reviews reimbursements, and who checks the math. Certain approvals should route through another board member even when the president-treasurer handles daily operations.
The person at the top sets the tone. If the dual officer submits receipts, seeks board approval before major expenditures, and welcomes financial questions, the rest of the organization follows suit. If they don’t, no written policy will matter much.
Documenting the Appointment
If the board decides to combine the roles, document the decision properly. Pass a formal resolution at a properly noticed meeting recording the individual’s full legal name, the specific titles being combined, and the effective date. Note in the resolution that the board reviewed the bylaws and confirmed no prohibition exists. Keep the signed resolution in the permanent records alongside the meeting minutes.
Most states require nonprofits to file periodic updates with the Secretary of State reflecting current officer information. The update form, often called a Statement of Information or Annual Report, typically has separate fields for each officer position. When one person holds both titles, enter their name in both the president and treasurer fields. Filing fees commonly range from $25 to $150 depending on the state.
When to Split the Roles
Combining the president and treasurer positions works best as a temporary arrangement. During the startup phase or in a very small volunteer-run organization, it may be the only practical option. As the organization grows, the arrangement becomes harder to justify and riskier to maintain.
Signals that it is time to separate the roles include an annual budget above $250,000, applications for foundation grants that require specific governance standards, an independent audit (auditors will note the lack of segregation), or a board large enough that finding a separate treasurer is no longer difficult. The IRS has noted that “a governing board should include independent members and should not be dominated by employees or others who are not, by their very nature, independent individuals.” That guidance applies at any size, but it carries more practical weight as the organization’s budget and public profile grow.2Internal Revenue Service. Governance and Related Topics – 501(c)(3) Organizations