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What rules govern the disclosure of nonprofit salaries? I understand that, while only the top five highest paid employees must be disclosed on the Form 990, all salaries are public information and must be released if requested by a funder, whether private or government. Is this correct?

The Form 990 requires disclosure of the compensation of all officers, directors, trustees, key employees and the five highest paid employees (not included in the preceding group) who received more than $100,000 in compensation from the organization and any related organizations during the year.  The organization is not required to disclose the compensation of the other employees.

A prospective funder’s request for additional salary information is based on the “golden rule.”  Whoever has the gold makes the rule.  You can decide whether or not to give the information, and the funder can decide whether or not to make the grant.

The rule may be different if you already have a grant or contract, and you ought to check the language of any such agreement, but I am not aware of any general requirement to disclose salaries not required on the Form 990.

Rev. 5/16/2011