I'm looking at a the Form 990 for a small non-profit, and I'm noticing that under administrative/management expenses only the Executive Director's salary is listed. I know there is a Deputy Director and a Director of Business Communications who draw salaries at the organization, but they are not listed. Is this legal? It's definitely misleading...

1 Answer 1


For a small nonprofit, I'd assume that those positions would not need to be listed.

Under current IRS guidance, the organization must list:

  1. "All of its current officers, directors and trustees." The positions you've mentioned do not appear to match any of these categories, at least as defined in the Form 990 Glossary.
  2. "Up to 20 current employees who satisfy the definition of key employee." Key employees are those with responsibilities similar to officers, directors, or trustees, and with compensation exceeding $150,000. For a small nonprofit, I'd be surprised if either of those positions you mentioned drew a salary exceeding $150,000, so I wouldn't expect either to need to be reported.
  3. "Its five current highest compensated employees with reportable compensation greater than $100,000." On this question, it doesn't matter what the employee's responsibilities are. If their compensation exceeds $100,000, they should be included. But if those employees are making less than that, then no, they don't need to be listed.

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