On 21 May 2026, Lithuania transposed the EU Pay Transparency Directive through a 15-page Labour Code amendment

On 21 May 2026, Lithuania adopted Law No. XV-969 amending the Labour Code and formally adding the EU Pay Transparency Directive requirements to the Labour Code. The law changes multiple Labour Code articles and creates a phased implementation model for pay transparency, equal pay enforcement, job grouping and gender pay gap reporting.

For employers, the main message is simple: pay transparency will no longer be only about publishing salary ranges or preparing occasional reports. It will require a documented remuneration system, objectively defined job groups, reliable pay data, and the ability to explain pay differences using gender-neutral criteria.

A detailed overview of the obligations, dates and employer-size thresholds is available here:

Lithuania_pay_transparency_obligations_XV-969_final_law.pdf

Atsisiųsti PDF • 286KB

Three implementation phases

The law does not apply all new obligations on one date. The first wave enters into force on 7 June 2026, while the main Sodra-based data reporting and employee pay information rights start from 1 January 2027. Employers must review or approve their remuneration systems by 31 December 2026.

This creates three practical phases for employers:

First, from 7 June 2026, employers must comply with the strengthened equal pay rules, recruitment-related transparency changes, confidentiality limitations regarding employees’ own pay, and the new remuneration system requirements.

Second, by 31 December 2026, employers must approve a remuneration system or review and amend the existing one. This is probably the most important practical preparation deadline.

Third, from 1 January 2027, the new Sodra-based reporting architecture starts. Sodra - the State Social Insurance Fund Board under the Ministry of Social Security and Labour - will receive pay, working time and job group data, calculate pay indicators and provide them to employers and authorities.

Job groups become the backbone of the system

The law introduces a very important requirement: positions must be grouped in the remuneration system using objective and gender-neutral criteria.

The law directly refers to criteria covering skills, qualifications, effort, responsibility and working conditions. It is more specific than a generic job architecture requirement. Skills include communication and cooperation skills, conflict resolution, the ability to work with other people and other skills important for performing the job function. Effort includes the amount of physical, mental and emotional resources required to perform tasks under the job description. Working conditions include work environment, intensity, risk, physical and psychological factors. Other relevant criteria may also be used where appropriate.

This is not only an HR documentation exercise. The same job groups will be used for pay information requests, Sodra reporting, gender pay gap indicators and potential equal pay disputes.

Remuneration systems will need to be more complete

The remuneration system must define pay forms, pay levels or pay ranges by job group or position, additional pay, allowances, bonuses, indexation and pay increase rules.

Employers with fewer than 50 employees are exempt from the obligation to include pay increase criteria and procedure in the remuneration system. However, this exemption does not remove the broader requirement to have a structured remuneration system and to group positions using objective and gender-neutral criteria.

This means many employers will need to move from informal salary decision-making to a more documented and explainable pay framework.

Recruitment: not all transparency rules are new

It is important to separate new obligations from rules that already existed in Lithuania.

Publishing pay ranges in job advertisements is not new. Lithuania already had this requirement before the latest amendments.

The new law adds further pre-contractual transparency elements. Employers may not ask candidates about pay received in current or previous employment relationships. Where a collective agreement exists, the future employer must provide the candidate with the applicable collective agreement provisions before concluding the employment contract, in a way that supports reasonable and transparent pay negotiations.

Sodra will play a central role

From 1 January 2027, employers will submit monthly data to Sodra on employees’ pay, working time and the job group indicated in the remuneration system. Sodra will use this data to calculate monthly and annual indicators, including employee-level average hourly pay and job-group pay averages by sex.

Sodra will also calculate broader gender pay gap indicators for larger employers. Employers with 100-249 insured persons are covered every three years, while employers with 250 or more insured persons are covered annually. Smaller employers may voluntarily opt into the same data-processing regime as employers with 100-249 insured persons.

The first broader indicators will be provided by Sodra to employers with 150 or more insured persons by 1 March 2028. For employers with 100-149 insured persons, and smaller voluntary participants, the first provision is due by 1 March 2031.

Employee information rights start later than many expected

The employee’s right to request pay indicators is included in Article 17 of the law, which enters into force on 1 January 2027.

However, there is an important transitional point: employers, the State Labour Inspectorate and the Equal Opportunities Ombudsperson start providing these indicators only after Sodra has provided the relevant data to them. Annual employee and job-group indicators are first to be provided by Sodra to employers by 1 March 2028.

Employees will be able to request their own annual pay, monthly and annual average hourly pay, and average pay indicators by sex in the same job group. If providing the information would directly or indirectly disclose the pay of another identifiable employee, the information must be handled through employee representatives, the State Labour Inspectorate or the Equal Opportunities Ombudsperson.

Stronger enforcement and compensation

The law also strengthens enforcement in equal pay cases.

When assessing whether women and men perform the same work or work of equal value, the comparison is not limited only to employees working for the same employer. The law allows the assessment to consider a single source setting pay conditions, such as centrally determined pay conditions across group companies.

If no direct comparator exists at the workplace, the employee may rely on other evidence, including statistical data or a hypothetical comparator.

If an equal pay breach is established, compensation may include full recovery of unpaid pay or payments in kind, material and non-material damage, and compensation for lost work-related opportunities.

What employers should do now

The most urgent task is not reporting. It is building the basis for reporting.

By the end of 2026, employers should be able to answer four questions:

1. Do we have a remuneration system that meets the new Labour Code requirements?

2. Are our positions grouped using objective and gender-neutral criteria?

3. Can we explain why jobs are placed in the same or different job groups?

4. Can we explain pay differences within the same job group?

   
   

For many organisations, this will require a practical review of job architecture, job evaluation, pay ranges, variable pay rules, performance-related pay decisions and data structures.

Final thought

Lithuania’s model is data-driven, but the real challenge is managerial. The law will create more information, but information alone will not explain pay differences.

Employers will need clear criteria, consistent decisions and managers who can explain pay in a factual and credible way.

This is where pay transparency becomes more than compliance. It becomes a test of the quality of remuneration management.

Note: this article is for information purposes only. For decisions, formal legal advice should be taken and the official legal text should be consulted.

When referenced please include source - www.kajieta.eu