Compliance Corner: Key details to understand about honoraria
Before accepting that speaking fee or payment for outside work, ñ employees need to know the rules. While the university doesn't have a blanket ban on honoraria, strict adherence to the Fiscal Code of Ethics is required to prevent conflicts of interest or "private gain." Learn the key restrictions and additional disclosure requirements, plus state-level ethics and tax considerations.
Question 1: Does ñ prohibit employees from accepting honoraria?
Answer: Sometimes.
The University of Colorado does not specifically prohibit employees from receiving honoraria from outside entities. However, under the , the University does prohibit any “private gain” from an employee’s association with the University. This includes situations where an employee is:
- receiving substantial [external] compensation forperforming university duties;
- using university resources for personal gain; and
- giving rise to the “appearance” of having a conflict of interest.
As it relates to honoraria, Fiscal Compliance understands the Fiscal Code of Ethics requirements to mean that:
- (1) an employee should not be performing tasks for an outside organization during their scheduled work hours;
- (2) an employee should not be using University property or resources to support outside tasks;
- (3) the tasks performed for an outside organization cannot overlap with the employee’s official work for ñ;
- (4) the employee should not accept an honorarium if the outside organization is a CU vendor;* and
- (5) an employee should not accept an honorarium from a non-vendor if it is more than what peers receive for similar work.
For more details on gifts or payments from CU Vendors, please visit our FAQ on the subject.
If the honorarium payment is appropriate under the Code of Ethics, some types of employees are subject to additional requirements.
If the employee is responsible for the purpose, design, conduct, or reporting of research, then they may have to disclose:
- Any gift or honorarium valued at more than $5,000
- If the outside organization is a foreign entity
This list is not exhaustive. For more information on the relevant disclosure requirements and process, please review this FAQ, or consult with the Research and Innovation Office.
If the employee is a , they will have to disclose any gift or honorarium valued at more than $5,000, or certain unremunerated commitments to outside entities. For more information, please contact the Fiscal Compliance team.
If the employee, within their official university role, would like to procure goods or services from the outside organization on behalf of ñ, they must disclose any benefits received from the organization on future Marketplace orders using the (see and the ).
Question 2: Should I be aware of other (non-CU) rules governing honoraria?
Answer: Yes.
The State of Colorado bans public employees from accepting gifts worth more than $75 under . . Please consult with the to determine whether your non-CU honorarium payment would be appropriate under state public ethics requirements.
Additionally, external honoraria are taxable as supplemental income. Please discuss with a personal tax advisor how best to declare non-CU payments.