What employers ask
Questions employers asked us while preparing their pay system. Where an answer rests on the law, we name the article. Where it is Linden's practice, we say so.
Duties and deadlines
Does a small company need a pay system too?
Yes. Every employer must approve or review one by 31 December 2026, unless a collective agreement sets the pay system.
Employers with fewer than 50 staff do not need to set criteria and a procedure for pay rises. All other requirements apply to everyone.
Legal basis: Law No. XV-969, art. 23(4); Labour Code art. 140(3).
We have an old pay system. Is it still good enough?
You must review it, and change it if needed, by 31 December 2026. The law did not use to require grouping jobs by gender-neutral criteria, so short one-page systems usually do not meet the new rules.
You can upload your current system to the tool, and a Linden lawyer will check what is missing. You can use your own file only until you submit the system prepared in the tool for Linden's review.
Legal basis: Law No. XV-969, art. 23(4); 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. 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. Fines and disputes
Legal basis: Code of Administrative Offences, art. 99(1) (art. 99(3) from 2027-01-01); Labour Code art. 26(5).
What changes from 2027?
Every month you report to Sodra on the SDUP form. The first report is due by 28 February 2027, for January, with each employee's job group number. So the groups must be approved before then.
From 1 March 2027 an employee may ask for the average pay in their job group, by gender. You must answer within one month. You must also tell staff about this right every year. What to prepare for your accountant
Legal basis: Ministry order No. A1-433, points 2.1 and 2.3; Labour Code art. 148(4) and (5), as from 2027-01-01.
How the work goes
How long does it take, and how much work is it for us?
We need about 2–5 hours of your time: entering data and scoring jobs. A Linden lawyer checks the system within 5 working days. Consultation with staff representatives takes at least 10 working days.
If your company must have a works council but has none, it must be elected first. That takes about 4 weeks. In our experience the longest part is waiting for the company's answers, so it is worth starting now. How it works
Legal basis: Labour Code art. 206(2).
What do we need to prepare?
A list of jobs with a short description of each: what the person does and what they are responsible for. A staff list with pay (Excel or CSV).
If you have them, also upload your current pay rules, sample employment contracts, confidentiality agreements and work rules. You do not need an HR specialist: the tool guides you step by step.
Are calls and corrections included in the price?
Before you start you can have a free 30–45 minute call with a Linden lawyer. The price includes one lawyer review and one round of corrections after your comments.
Further rounds are charged at Linden's hourly rate, which we tell you in advance. Terms of use
An outside payroll firm calculates our pay. What do we do?
That is common. The system states who calculates pay: your own employee or the payroll firm.
The tool prepares a list with each employee's job group number. You pass it to your accountant, who needs that number for the first report to Sodra.
Jobs, groups and pay ranges
How are jobs sorted into groups?
Each job is scored on five criteria: skills, qualifications, effort, responsibility and working conditions. Jobs that involve the same work or work of equal value go into the same group.
The same criteria apply to jobs that are hard to describe. A short note on what the person does is enough. The Linden system suggests a score and explains why, and you accept or change it.
Legal basis: Labour Code art. 140(3).
How wide should a pay range be?
For each group or job you set an amount of pay or a range: a minimum and a maximum. The law does not set the width. Pay may not be lower than the law sets, for example the minimum monthly wage.
The Linden system suggests ranges based on your current pay. What matters most is that you can explain differences within a group by objective criteria.
Legal basis: Labour Code art. 140(2) and (3).
When and why does pay move up within the range? And what do we pay a new hire?
With 50 or more staff, the system must set criteria and a procedure for pay rises, for example better results, growing skills or more experience. Smaller employers do not have to, but may.
Our practice: use the same criteria to set a new hire's pay within their group's range. That removes the "manager's own decision", which is hard to defend in a dispute.
Legal basis: Labour Code art. 140(3).
Do bonuses and allowances have to be in the system?
Yes. The system sets the grounds, amounts and procedure for allowances, extra pay and bonuses. This also covers bonuses you grant at your own discretion.
If you pay from a pool, such as a team fund, a share of sales or a fee per extra service, describe who gets it, how it is calculated and who counts as a team member.
Legal basis: Labour Code art. 140(3).
Is a 5% pay gap between men and women allowed?
No. Men and women must get equal pay for the same work or work of equal value. Any gap you cannot justify by objective criteria is a breach.
5% is the level from which staff representatives, the Labour Inspectorate or the Equal Opportunities Ombudsperson tell an employee about the gap in their group. Where a gap in a group is 5% or more, Linden helps you draw up a plan to fix it. Pay gap check
Legal basis: Labour Code art. 140(5); art. 148(7), as from 2027-01-01.
Staff representatives and informing staff
Do we need a works council?
A works council is required when the average number of staff is 20 or more. It is not formed if a trade union whose members are more than one third of the staff operates at the employer.
With fewer than 20 staff, employees may elect a staff trustee. How the election works
Legal basis: Labour Code art. 169(1) and (4); art. 177(1).
How does consultation with staff representatives work?
Before you approve the system, you must inform staff representatives and consult them. The works council is informed 10 working days before the planned approval. Within 3 working days it may ask for consultation, which then lasts at least 5 working days unless the representatives agree otherwise.
The Linden system sends the draft, collects comments and prepares the record. If there are no representatives, our practice is to consult staff directly.
Legal basis: Labour Code art. 140(3); art. 206(1)–(3) and (5).
We already approved a system without consultation. What now?
The law requires information and consultation before a system is approved or changed. Our advice: run the consultation now and approve the system again.
Do not write in the document that consultation took place if it did not. In a dispute that is easy to disprove.
Legal basis: Labour Code art. 140(3).
What must we show staff, and what not?
Every employee must be able to read the approved system, with its groups, ranges and bonus rules. An individual employee's pay is not disclosed without their consent, unless the law requires it.
So the job scoring sheet with staff pay stays inside the company. You may show parts of it in a dispute or a Labour Inspectorate check.
Legal basis: Labour Code art. 140(3); art. 148(2).
Must we tell staff that pay is no longer secret?
Since 7 June 2026, an employee's data about their own pay cannot be treated as confidential when they disclose it to enforce their right to equal pay. A confidentiality clause that forbids this does not apply in that case.
The law does not require a separate notice. Our advice: review your confidentiality agreements and approve a list of what counts as confidential information.
Legal basis: Labour Code art. 39(1).
How do I prove that staff have read the 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. Staff without e-mail can sign a paper sheet. How staff acknowledgement works
Legal basis: Labour Code art. 140(3).
Price and payment
How much does it cost, and is the price fixed?
The price is fixed and depends on your average number of staff: 1–10 staff 290 EUR, 11–49 590 EUR, 50–149 990 EUR, 150–249 1490 EUR. For 250 or more we prepare an individual offer. VAT is added.
A works council election costs 350 EUR and a staff trustee election 150 EUR. If you want a Linden lawyer to do all the work, the full service costs 50% more, and at least 700 EUR. Prices
When and how do we pay? Do we sign a contract?
Checking your requirements and starting in the tool are free. You pay before the Linden lawyer's review: through Paysera or by invoice. Until the review starts, we refund in full. Election packages are not refunded once you download the first document.
There is no separate contract to sign. You accept the terms of use when you register. Terms of use
Data and security
Who sees my staff's pay, and where is the data kept?
Your company and the Linden lawyer who checks the system. Other clients cannot see it, and it is never combined with other companies' data. The tool does not collect personal ID numbers.
The tool's servers and database are in the European Union. The data is kept under advocates' professional secrecy. We name every service provider in the privacy policy.
What happens to the data when the work is done?
After your account is closed you can download your documents. We keep the account data, including staff data, for 1 year after the account is closed, so you can download it or come back. Then we delete it. You can ask us to delete it sooner. Terms of use
Book a free call
A 30–45 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