“Key management personnel” of the charity, are defined as “those persons having authority and responsibility for planning, directing and controlling the activities of the charity, directly or indirectly, including any Directors of the charity.”
This definition includes the Trustees. As you and your accountant should be aware, Trustees should not receive any “remuneration” for their roles, but are allowed expenses and the total of these plus any other trustee related costs should be stated in the accounts as per usual reporting processes.
The definition also includes those senior management personnel to whom the Trustees have delegated “significant authority or responsibility in the day-to-day running of the charity.” i.e. the CEO/Leader/Manager, deputy CEO, Finance Director etc… – essentially the SMT of the organisation.
In the charities accounts you have to disclose the numbers of staff paid more than £60,000 in £10,000 bands from £60,000 upwards. No details of the actual salaries need to be displayed – just simply a count of how many roles sit within a particular salary band. If there’s only one role shown within a particular band then it doesn’t take much to work out that it’s likely to be the CEO/leaders salary band. If no one is paid more than £60,000 then you just have to state this.
The accounts also need to report upon the “total remuneration paid to key management personnel”. This single aggregate figure doesn’t need to be broken down into which roles get paid what, but just needs to simply show a combined figure for the “key management personnel”. There’s also no requirement to detail in the published accounts which roles are to be included in this group of key management personnel – just as long as those whose salaries are included in this calculation could be realistically deemed to be in positions of “significant authority or responsibility in the day-to-day running of the charity.”
If you’re a small organisation/management team then on one hand there could just be a single persons salary contributing to the figure – therefore giving rise to concerns regarding publication of personal salary information . However there’s the potential to “interpret” who/what roles you would count as being in this group. For example, if you just have a CEO or Manager, then who else in the organisation could be deemed to have “significant authority or responsibility in the day-to-day running of the charity.” Anyone with significant budget or financial approval authority could potentially be deemed as being within this group. Also, in the CEO’s absence (when they are on holiday, ill etc…) who covers their management responsibilities e.g. do other service managers/leaders in the organisation deputise in the CEO’s absence – if so then the case could be made that they should also be included the “total remuneration paid to key management personnel” reported figure.
The accountant we consulted is happy to give feedback upon the advice your accountants are giving you upon this issue of senior personnel salary information – Charities SORP (FRS 102). Please contact us at firstname.lastname@example.org to discuss this.
We hope that this information is clear and please do let us have any feedback or comments, both upon the above guidance and also your own experiences of the Charities SORP (FRS 102). Please do remember that you should treat this information as being intended for guidance only, and not as a substitute for professional advice. No responsibility for loss occasioned as a result of any person acting or refraining from acting can be accepted by Visionary.