Understanding nonprofit executive pay
Executive salary lines on a 990 are a frequent flashpoint — a number in isolation can look alarming, or can be used to make an organization look alarming, without context. Here's the context.
Why nonprofits pay salaries at all
A common misconception is that a “real” charity should be run entirely by volunteers, or that any paid leadership is itself suspicious. In practice, running a nonprofit at scale — especially one operating programs across multiple countries, managing safeguarding obligations, and reporting to donors and regulators — requires the same professional skills (finance, operations, program management, fundraising) that any organization of comparable size needs, and those skills command a market wage. An organization that can't attract or retain competent leadership because it refuses to pay competitively often serves its mission worse, not better.
How the IRS expects compensation to be set
Federal tax law gives nonprofits a structured way to establish that compensation for senior staff is reasonable, generally known as the rebuttable presumption of reasonableness. In broad terms, it involves three elements: the pay is approved in advance by an independent body (typically the board or a committee free of conflicts of interest); the decision relies on appropriate comparability data (what similar organizations of similar size pay for similar roles); and the process and rationale are documented at the time the decision is made. When all three are followed, the IRS presumes the pay is reasonable unless there's evidence to rebut that presumption.
Where to check it yourself
- Form 990, Part VII lists titles, hours and reportable compensation for officers, directors, and the highest-paid employees;
- Schedule J adds detail on bonuses, deferred compensation and certain benefits, when applicable — see the walkthrough in how to read a Form 990;
- Schedule O sometimes explains the compensation-setting process directly, including whether comparability data and independent board approval were used.
How to judge a figure, not just read it
- Compare to organization size and complexity, not to a flat number — a multi-country operating charity is a different management job than a small local one;
- Compare to sector peers of similar budget and scope, using the watchdog and comparability resources in charity rating tools compared;
- Look for the process, not just the outcome: was pay set by an independent body using comparability data, per the standard above? A documented, arm's-length process is itself a positive governance signal;
- Distinguish pay from perks: undisclosed benefits or related-party arrangements (business dealings between the organization and a board member's own company, for instance) are a governance question worth asking about directly — they are not the same thing as compensation being too high, and neither, on its own, is evidence of fraud.
If a compensation figure raises a question for you, the direct route is to ask — see questions to ask any charity for how to phrase it.