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Can Officers Be Compensated?
Liz Myers avatar
Written by Liz Myers
Updated over 4 months ago

A common question for nonprofits is whether their officers can be compensated for the work they do. The answer is yes—officers may be compensated, but the key is that their compensation must be reasonable and in line with industry standards. Nonprofits are still subject to IRS guidelines and legal requirements around fair and appropriate compensation, and ensuring compliance is essential to maintaining tax-exempt status.

What Is “Reasonable” Compensation?

The IRS requires that any compensation paid to nonprofit officers be reasonable and appropriate for the duties and responsibilities of the position. This means that the salary or benefits offered to an officer must reflect industry standards for similar positions at comparable organizations in terms of size, budget, and geographic location.

For example, paying an officer $50,000 in salary when your nonprofit only receives $100,000 in total revenue during its first year might be viewed as unreasonable by the IRS. In contrast, an organization with larger revenue may be able to justify paying officers higher salaries, provided they are in line with market rates.

Researching Compensation Standards

It’s important to research compensation standards for nonprofit officers in your area. Tools such as salary surveys, nonprofit compensation reports, and benchmarking studies can provide valuable insights into what similar roles are paying in terms of salary, benefits, and bonuses. By aligning your officer compensation with industry norms, you’ll reduce the risk of scrutiny from the IRS and avoid penalties for overcompensation.

IRS Scrutiny and Private Inurement

The IRS is particularly vigilant about ensuring nonprofit funds are not used for private inurement, which occurs when an individual within the nonprofit (such as an officer) benefits personally from the organization’s earnings beyond what is considered reasonable compensation. To avoid this, it's important to document how compensation decisions are made, ideally by an independent board or compensation committee.

If compensation is deemed unreasonable, the IRS can impose penalties, revoke the nonprofit’s tax-exempt status, or take other corrective actions.

Reporting Compensation

Nonprofits must also report any compensation paid to officers, directors, and key employees. This is done through the annual Form 990, which requires organizations to publicly disclose salaries, bonuses, and other compensation packages for their top officers. This transparency helps ensure accountability and demonstrates that the nonprofit is using its resources appropriately.

Nonprofit organizations must also comply with regular payroll reporting requirements, just like any other business. This means:

  • Withholding and paying payroll taxes (e.g., Social Security, Medicare)

  • Filing W-2 forms for employees, including officers

  • Filing Form 941 quarterly for payroll taxes withheld

Ensuring compliance with these reporting requirements is critical to maintaining your organization’s standing with the IRS and avoiding potential penalties.

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