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Pay Transparency in Lithuania: What Employers Need to Know

Pay Transparency in Lithuania: What Employers Need to Know

Name: Figures
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Author: Figures

EU Pay Transparency

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Pay Transparency in Lithuania: What Employers Need to Know

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The EU Pay Transparency Directive sets new standards for pay transparency across Europe, but the practical rules depend on how each Member State transposes it into national law.

Lithuania has now transposed the Directive, turning those broad requirements into concrete rules employers need to follow. Lithuania is one of a small group of Member States, alongside Italy, Slovakia and Malta, that completed transposition legislation around the original 7 June 2026 deadline, while most Member States have missed it.

Below, we break down what Lithuania's law says, where it adds country-specific detail, and what employers should pay close attention to when preparing.

Transposition status in Lithuania at a glance

What You Need to Know About Pay Transparency in Lithuania

Lithuania — Pay Transparency Directive

Theme	Situation in Lithuania
Transposition status	Adopted. Lithuania transposed the Directive through law No. XV-969, amending articles 23, 26, 39, 40, 41, 42, 48, 51, 52, 65, 71, 79, 131, 140, 147, 148, 197, 217, 219, 226 and the annex of the Labour Code, adopted by the Seimas on 21 May 2026 and registered in the official register (TAR) on 25 May 2026.
Entry into force	7 June 2026 for most obligations; a second set of obligations enters into force progressively from 1 January 2027, and the formalized pay system must be confirmed or updated by 31 December 2026 at the latest.
Key deadlines	Implementing regulations from the Minister of Social Security and Labour are expected by 31 July 2026. From 1 January 2027, employers must transmit pay and job-group data monthly to the social security fund (Sodra), and employees individually gain the right to request pay information. The first pay gap figures calculated by Sodra are expected around March 2028 for employers with 150 or more employees, and around March 2031 for employers with 100 to 149 employees.
Main employer obligations	A universal pay system for all employers, the ban on pay history and the requirement to disclose pay before signing, the ban on pay secrecy, disclosure to employee representatives from 20 employees, the individual right to pay information from 2027, centralized gender pay gap reporting via Sodra, and joint pay assessments above a certain threshold.
Points to watch	A pay system obligation applicable to all employers regardless of size, a one-month (not two-month) response deadline for information requests, a low threshold of 20 employees for disclosure to employee representatives, and Sodra reporting deadlines pushed to later dates than those set by the Directive.

Lithuania's pay transparency law in detail

Lithuania has transposed the Pay Transparency Directive by amending its Labour Code through Act No. XV-969. The law applies to all employers regardless of size for the core pay-system obligation, while reporting duties to Sodra and other documentation requirements scale by headcount.

Theme	Position in Lithuania
Employers concerned	All employers, regardless of size, must adopt a formalized pay system. Disclosure to employee representatives applies from more than 20 employees. Reporting to Sodra applies from 100 employees (every three years) and 250 employees (annually).
Pay transparency for candidates	Employers must disclose the pay conditions of the applicable collective agreement before signing the employment contract.
Ban on pay history	Employers are prohibited from asking candidates about their current or past pay.
Employees' right to pay information	From January 1, 2027, employees may request their annual pay and average hourly pay, as well as the employer's average pay by gender within their job group. The employer must respond within one month of receiving the data from Sodra (up to two additional months for clarification). Until then, a transitional rule allows only employee representatives or unions to request anonymized average data by group and gender, from employers with more than 20 employees.
Criteria for setting and progressing pay	Every employer, regardless of size, must adopt and publish a formalized pay system grouping positions according to objective criteria. Employers with fewer than 50 employees are exempt from specifically documenting the criteria and procedure for pay increases.
Work of equal value	Assessed using four mandatory, objective, and gender-neutral criteria: skills (explicitly including soft skills such as communication, cooperation, and conflict resolution), effort, responsibility, and working conditions.
Gender pay gap reporting	From January 1, 2027, all employers monthly transmit pay, working time, and job group data to Sodra, which itself centrally calculates the pay gap figures. Employers with 100 to 249 employees receive these figures and must act every three years; those with 250 employees or more receive them annually. The first delivery for these two brackets is postponed to around March 2028, and to around March 2031 for the 100-149 bracket — later than the June 2027/2031 dates set by the Directive.
Joint pay assessments	Same test as the Directive (5% gap / 6-month deadline), carried out jointly with employee representatives and reported to the Labour Inspectorate.
Definitions of pay	"Pay" means the salary plus any other remuneration, in cash or in kind, received directly or indirectly from the employer in respect of work — covering base pay, bonuses, allowances, and other benefits in kind.
Enforcement and penalties	Compensation covers full recovery of unpaid pay and payments in kind, material and moral damages, and loss of professional opportunities, with no cap at EU level. Breaches of equal pay are also treated as a delay in salary payment, automatically triggering statutory late-payment interest during the employment relationship, or lump-sum damages equal to one month's average pay per month of delay in the event of contract termination. Courts may also depart from the usual rules on allocating legal costs in pay discrimination cases. The precise amounts of administrative fines have not yet been set.

Compensation covers full recovery of unpaid pay and in-kind payments, material and non-material damages, and lost work-related opportunities, with no EU-level cap. Equal-pay breaches are also treated like a late wage payment, triggering automatic statutory penalty interest during ongoing employment, or liquidated damages equal to a month's average pay per month of delay on termination. Courts may also depart from standard litigation-cost allocation rules in pay-discrimination cases. Specific administrative fine amounts are not yet set.

Analysis: What Lithuania's law means in practice

Employers in Lithuania now need to adapt their pay practices to meet the new rules. Four areas deserve especially close attention: the universal pay-system obligation, the works-council disclosure threshold, the centralized reporting model, and the financial consequences of a breach.

1. Every employer must formalize a pay system, regardless of size

The Directive lets documentation duties scale with headcount in most Member States. Lithuania goes further: every employer, no matter how small, must adopt and publish a formal pay system that groups roles using the same four objective, gender-neutral criteria — skills (including soft skills), effort, responsibility and working conditions.

The only size-based relief is narrow: employers with fewer than 50 employees don't have to document the pay-increase criteria and procedure within that system, though they still need the rest of it in place. For most employers, this means the pay-system build-out that other countries treat as a mid-size or large-employer obligation is, in Lithuania, a day-one requirement for everyone.

2. A low, 20-employee threshold triggers pay disclosure well before the main reporting regime starts

Ahead of the individual right to information taking effect in 2027, Lithuania already requires employers with more than 20 employees to give worker councils or unions anonymized average-pay-by-group-and-gender data on request, at least once a year. This is a lower threshold and an earlier trigger than the Directive's own reporting thresholds, which start at 100 employees.

In practice, mid-sized employers that might not expect to be in scope of pay transparency obligations for another year or two are already exposed to disclosure requests today.

3. Sodra, not the employer, calculates the pay gap: but the first figures arrive later than the Directive's own dates

Lithuania uses a distinctive centralized-calculation model. From 1 January 2027, employers submit monthly wage, working-time and position-group data to the state social insurance fund (Sodra), which computes the gender pay gap figures itself, rather than employers calculating and reporting their own numbers, as in most other Member States.

This shifts calculation effort away from employers, but it comes with a trade-off: the first data delivery for both the 150–249 and 250+ employee bands is deferred to around March 2028, roughly nine months after the Directive's own June 2027 deadline, and the 100–149 band is deferred to around March 2031. Employers should not assume the deferred delivery dates change the underlying data-quality expectations, the monthly feed to Sodra still starts in January 2027.

4. The financial and procedural consequences of a breach are unusually strong

Lithuania treats an equal-pay breach, mutatis mutandis, like a late wage payment: it triggers the same automatic statutory penalty interest during ongoing employment, or liquidated damages equal to a month's average pay for every month of delay if the employment has ended. On top of that, compensation is uncapped and can include material and non-material damages and lost work-related opportunities, and courts have discretion to depart from the standard cost-allocation rules in litigation based on how each party behaved.

Specific administrative fine amounts for failures like not reporting or not running a Joint Pay Assessment are not yet set — they likely sit in the Code of Administrative Offences or forthcoming secondary legislation. But the civil-law consequences already in force make the cost of getting equal pay wrong significant.

Key preparation steps for employers in Lithuania

Several of Lithuania's obligations are already in force, with more phasing in through 2027. If you have not yet started preparing, focus on these steps first:

Formalize (or confirm and update, by 31 December 2026) a pay system that groups every role using the four objective criteria: skills (including soft skills), effort, responsibility and working conditions.
If you have 50 or more employees, document your pay-increase criteria and procedure within that pay system as well.
Remove salary-history questions from your hiring process, and disclose applicable collective-agreement pay terms before signing any employment contract.
Review contracts and practices to remove any pay-secrecy clauses, pay can never be treated as confidential when disclosed to assert equal pay.
If you have more than 20 employees, prepare to respond to work-council or union requests for anonymized average pay by group and gender, this obligation is already active.
Build a data pipeline to submit monthly wage, working-time and position-group data to Sodra starting 1 January 2027.
Prepare a process to handle individual employee pay-information requests from 1 January 2027, with a one-month response window.
Watch for the Minister of Social Security and Labour's implementing regulations, due 31 July 2026, which will fix the detailed reporting and Joint Pay Assessment procedures.
Document your pay-setting rationale carefully, equal-pay breaches carry uncapped compensation plus wage-arrears-style penalty interest or liquidated damages.

Learn more about the Pay Transparency Directive

Pay transparency preparation will look different from one country to the next. For employers operating across several markets, Lithuania is one part of a wider country-by-country compliance picture.

To see how other countries are handling pay transparency, head to our full guide.