Pay transparency requirements, one Linden solution
Linden scores your jobs, prepares your pay system by 31 December, checks the pay gap between men and women and informs your staff. You provide the data and approve the result.
Four numbers worth knowing
The biggest risk is not the fine. It is an employee who leaves.
An employee who leaves on bad terms can also raise pay. It is enough to point out that a colleague of the other gender doing the same work earns more.
Then the employer must prove that there was no discrimination (Labour Code art. 26(5)). Without a pay system and written reasons, there is nothing to rely on.
Unpaid wages, material and non-material damage, and compensation for lost job opportunities (Labour Code art. 219(2)).
The best protection is paperwork: an approved pay system, clear grouping criteria, and the reason each employee is paid what they are paid.
What is due, and when
- 2026-06-07 New rules on pay systems, recruitment and confidentiality took effect. Law No. XV-969, art. 23(1)
- 2026-12-31 The pay system is approved or reviewed, and available to all employees. Law No. XV-969, art. 23(4); Labour Code art. 140(3)
- 2027-01-01 Employers report pay, working time and job group to Sodra every month. Labour Code art. 23(3), as from 2027-01-01
- 2027-02-28 The first SDUP report, for January 2027. It states each employee's job group number. Ministry order No. A1-433, point 2.1; description, point 7
- 2027-03-01 Employees may ask for the average pay in their job group, by gender. You must answer within one month. Ministry order No. A1-433, point 2.3; Labour Code art. 148(5)
Five steps to an approved pay system
We need your time only in steps 1 and 2, about 2–5 hours in total. Linden does the rest.
- Client – your company
- Linden system – a guided process
- Linden lawyer
-
Check the requirements that apply to you
about 3 min- Client
Up to 9 questions about your company. You get your list of duties with deadlines, and learn whether you need to set up a works council.
Check now -
Your data into the Linden system
about 1–2 hours- Client
- Linden system
The Linden system guides you through the questions. You upload documents and your staff list (Excel or CSV).
Documents: job descriptions, pay rules, employment contracts, confidentiality agreements, work rules.
Before you start, you can book a free 30-minute call with a Linden lawyer.
Book a call -
Job scoring and groups
about 1–3 hours- Linden system
- Client
The Linden system suggests job scores, groups and pay ranges, and checks the pay gap between men and women. You assess the suggestions: accept them or comment.
When the gap in a group is 5% or more, Linden tells you and helps you make a correction plan.
-
Lawyer review
within 5 working days- Linden lawyer
A Linden lawyer checks the whole pay system against Labour Code art. 140. We fix your comments in one round.
Done by Linden. Nothing for you to do.
-
Consultation and approval
10 working days or more- Linden system
- Client
Consulting staff is mandatory (Labour Code art. 140(3)). The Linden system does it: it sends the draft to staff or their representatives, collects comments and prepares the record. You sign the approval order and get the pay system as a Word document.
A works council is informed 10 working days before the planned approval (Labour Code art. 206(2)).
-
Staff acknowledgement
about 1–2 weeks- Linden system
Acknowledgement runs through the Linden system. Each employee gets a personal link by e-mail or SMS and taps “I have read it”. Staff without e-mail sign a paper sheet.
You can show the log to a court or the State Labour Inspectorate.
Done by Linden. Nothing for you to do.
What you have at the end
- A pay system in WordPrepared under Labour Code art. 140 and checked by a Linden lawyer.
- Job groups and pay rangesA minimum and maximum salary for each group that you can justify.
- Written reasons for gapsFor each gap in a group, a reason you can show in a dispute.
- Proof that staff have read itWho tapped “I have read it”, when, and through which channel.
- A group number for each employeeYou need it for the first SDUP report to Sodra, due by 2027-02-28.
- Lithuanian and EnglishThe tool works in both languages. Useful if you employ foreign staff.
Software with lawyers behind it
A lawyer's review
The final document appears only after a Linden lawyer has reviewed the pay system.
A law firm
The service is provided by the law firm APB „Jurkonis ir partneriai LINDEN“, Pylimo g. 19-16, Vilnius.
Servers in Frankfurt
The tool's servers and database are in Frankfurt (Germany, EU). We name every service provider in the privacy policy.
Based on the text of the law
We check every deadline and duty against the Labour Code and the ministry order. Legal basis
What employers ask
Does a small company need a pay system too?
Yes. Every employer must approve or review one by 31 December 2026 (Law No. XV-969, art. 23(4)).
Employers with fewer than 50 staff do not need to set criteria and a procedure for pay rises. All other requirements apply (Labour Code art. 140(3)).
What if I miss 31 December?
In our view, a missing pay system may be treated as a breach of the rules on setting wages. The fine for that is 500–1450 Eur (Code of Administrative Offences, art. 99(1)). There is no court or Labour Inspectorate practice on this yet.
The bigger risk is a claim by an employee, because then the employer must prove its case.
Do I need an HR specialist?
No. The tool takes you step by step, and a Linden lawyer checks the final document. You only need to know your jobs and your staff's salaries.
Does the Linden system decide for me?
No. The Linden system guides you step by step and suggests scores, groups and pay ranges. It uses pay, but not employees' names: we replace those with codes first. The tool does not collect personal ID codes. You decide, and a Linden lawyer reviews its suggestions and the whole pay system.
How do I prove that staff have read the pay system?
Each employee gets a personal link by e-mail or SMS and taps “I have read it”. The tool records who confirmed and when. How staff acknowledgement works
Where is my staff data kept?
On the tool's servers and database in Frankfurt (Germany, EU). Other clients cannot see your staff's pay, and it is never combined with other companies' data. We name every service provider in the privacy policy.
Book a free call
A 30-minute video call with a Linden lawyer. Pick a time in the calendar, or write to us in the form.
We answer on working days. E-mail info@linden.lt