The ethics complaint was filed Tuesday by the Republican Party of Texas.
White faces GOP Gov. Rick Perry in the Nov. 2 election.
White spokeswoman Katy Bacon told the San Antonio Express-News that the money did not have to be reported as "occupational income" because it was deferred compensation. Bacon says the holdings were discussed on White's financial statements.
White's 2009 income tax return, which he released last week, shows he had almost $660,000 in adjusted gross income. White's 2009 return indicated $83,677 in deferred compensation from when he was CEO of the Wedge Group, prior to becoming mayor in 2004.