Yes, nonprofits generally do have to report salaries. Most tax-exempt organizations file an annual Form 990 with the IRS that lists, by name, the compensation paid to their officers, directors, key employees, highest-paid staff, and highest-paid outside contractors. That filing is a public document. The main exceptions are churches, government entities, and organizations small enough to file a stripped-down notice that asks for no salary data at all.
Which Nonprofits Have to Report, and Which Don’t
The IRS requires nearly every organization recognized as tax-exempt under Section 501(a) to file some version of Form 990 each year.1Internal Revenue Service. Annual Exempt Organization Return: Who Must File The version a nonprofit files is driven by its size, and that choice decides how much salary detail becomes public.
- Organizations with gross receipts normally at or under $50,000 can file Form 990-N, an electronic “e-Postcard” that collects basic identifying information and no compensation data at all.
- Organizations with gross receipts under $200,000 and total assets under $500,000 can file Form 990-EZ, which asks for some compensation reporting but less detail than the full form.
- Organizations with gross receipts of $200,000 or more, or total assets of $500,000 or more, must file the full Form 990 with the detailed, person-by-person compensation disclosures described below.
Several categories of tax-exempt organizations don’t have to file any version of Form 990, which means they also don’t publish salary data through this system.2Office of the Law Revision Counsel. 26 US Code 6033 – Returns by Exempt Organizations The biggest ones are churches, interchurch organizations of local units, conventions or associations of churches, and the integrated auxiliaries of churches, along with the exclusively religious activities of religious orders. Federal, state, and local government entities with tax-exempt status are also outside the Form 990 system. And certain small religious, educational, and publicly supported charitable organizations are exempt when their gross receipts are normally $5,000 or less.
The church carve-out is wide. Because churches have no filing obligation, they can’t miss one, and they face no automatic revocation for not filing.3Internal Revenue Service. Exempt Organizations Annual Reporting Requirements – Overview – Annual Return Filing Exceptions A church can voluntarily file Form 990 if it wants to make its finances public, but nothing requires it to.
Private foundations file their own version, Form 990-PF, with lower thresholds for who gets named (covered further down).
Whose Salaries Get Named on Form 990
The full Form 990 names people in Part VII. The categories are specific, and the thresholds matter if you’re trying to figure out whether a particular person’s pay should appear.4Internal Revenue Service. Exempt Organizations Annual Reporting Requirements – Form 990 Part VII and Schedule J: Whose Compensation Must Be Reported
Officers, Directors, and Trustees
Every current officer, director, and trustee is listed, even those paid nothing. For IRS purposes, “officer” means anyone with ultimate responsibility for managing the organization or overseeing its finances, no matter what the job title is. A top executive is an officer whether the organization calls them CEO, Executive Director, or something else.5Internal Revenue Service. Exempt Organization Annual Filing Requirements Overview
Key Employees
A key employee is someone who is not an officer or director but meets all three of these tests: reportable compensation over $150,000 for the year, responsibilities comparable to an officer’s or management of a significant segment of the organization (at least 10% of its activities, assets, income, or expenses), and substantial influence over the organization. If more than 20 people qualify, only the 20 with the highest compensation have to be reported.5Internal Revenue Service. Exempt Organization Annual Filing Requirements Overview
Top Five Earners and Former Insiders
Beyond officers and key employees, the organization reports its five highest-compensated employees who earned more than $100,000 during the year. Former officers and key employees also appear if they received over $100,000, and former directors and trustees appear for payments above $10,000.5Internal Revenue Service. Exempt Organization Annual Filing Requirements Overview
Independent Contractors
Salary reporting isn’t limited to employees. An organization filing the full Form 990 also lists its five highest-compensated independent contractors who received more than $100,000 for services during the year.4Internal Revenue Service. Exempt Organizations Annual Reporting Requirements – Form 990 Part VII and Schedule J: Whose Compensation Must Be Reported Consultants, law firms, and fundraising companies with six-figure contracts show up by name.
Pay From Related Organizations
Anyone listed on Part VII who also receives pay from a related entity (a parent, subsidiary, or brother-sister organization under common control) has that pay reported too, provided it reaches at least $10,000 from any single related organization.6Internal Revenue Service. Exempt Organization Annual Reporting Requirements: Reporting Compensation Paid by Related Organization on Form 990 This closes the gap that would otherwise let an organization hide executive pay by routing it through an affiliate.
What the Compensation Number Actually Includes
The compensation shown on Form 990 is not just base salary. The IRS splits it into two columns. “Reportable compensation” matches the amount shown in Box 5 of an employee’s W-2 (or Box 7 of a 1099-MISC for non-employees) and covers wages, salary, bonuses, incentive payments, and severance.7Internal Revenue Service. Exempt Organization Annual Reporting Requirements: Meaning of Reportable and Other Compensation in Form 990
“Other compensation” picks up what the W-2 or 1099 misses: employer contributions to retirement plans, the value of employer-paid health insurance, housing and car allowances, and personal-use club memberships. A specific type of other compensation under $10,000 for a given person generally doesn’t need to be itemized, but retirement plan contributions and health benefit values are always reported no matter the amount.7Internal Revenue Service. Exempt Organization Annual Reporting Requirements: Meaning of Reportable and Other Compensation in Form 990
Schedule J for the High Earners
When a current officer, director, trustee, key employee, or top-five earner has total compensation over $150,000, the organization also files Schedule J.8Internal Revenue Service. Instructions for Schedule J (Form 990) Schedule J itemizes each person’s pay into base compensation, bonus and incentive pay, other reportable amounts, retirement and deferred compensation, and nontaxable benefits. All former officers, directors, trustees, and key employees listed on Part VII also appear on Schedule J, regardless of amount. If you want to see how a nonprofit executive’s package is built, Schedule J is where to look.
Private Foundations Report at Lower Thresholds
A private foundation files Form 990-PF rather than the standard Form 990, and the salary thresholds are lower. Every officer, director, and trustee is listed even if unpaid, the same as the standard form. But a private foundation reports its five highest-paid employees who earned more than $50,000 (versus $100,000 on the standard form), and the same $50,000 threshold applies to its five highest-paid independent contractors providing professional services such as legal or accounting work.9Internal Revenue Service. Instructions for Form 990-PF Return of Private Foundation
How to Look Up a Nonprofit’s Salaries
Compensation data on Form 990 is public. Federal law requires a tax-exempt organization to make its annual returns available for inspection for three years from the filing due date. It has to honor an in-person request the same day and answer a written request within 30 days. It can charge reasonable copying and postage fees, but it can’t refuse the request.10Internal Revenue Service. EO Disclosure FAQs An organization that stonewalls faces a penalty of $20 per day up to $10,000 per return.11Internal Revenue Service. Public Disclosure and Availability of Exempt Organizations Returns and Applications: Penalties for Noncompliance
One common confusion is worth clearing up. Donor identities on Schedule B are generally shielded from public inspection for most nonprofits.12Internal Revenue Service. Public Disclosure and Availability of Exempt Organizations Returns and Applications: Contributors Identities Not Subject to Disclosure Salary data in Part VII and Schedule J is not. No redaction is permitted on compensation.
You rarely have to contact an organization to see its filings. The IRS runs a Tax-Exempt Organization Search tool where filed returns can be pulled up.13Internal Revenue Service. Tax Exempt Organization Search Independent databases, including ProPublica’s Nonprofit Explorer and Candid’s GuideStar, compile millions of Form 990 filings and let you search by organization name, which is usually the fastest route to finding what a given nonprofit paid its leadership.