What the law requires from employers
Lithuania transposed the Pay Transparency Directive (EU) 2023/970 on 21 May 2026 by Law No. XV-969 amending the Labour Code. Here is a short summary with sources.
What a pay system must contain
Employers approve a pay system, or review the one they have, by 31 December 2026 (Law No. XV-969, art. 23(4)). The requirements are in Labour Code art. 140(3):
- jobs are grouped by objective, gender-neutral criteria: skills, qualifications, effort, responsibility and working conditions;
- the same work, or work of equal value, goes into the same group;
- it sets pay amounts or ranges, and the grounds and procedure for allowances, supplements and bonuses;
- staff are informed and consulted before approval;
- the approved pay system is made available to all employees.
Employers with fewer than 50 staff do not need criteria and a procedure for pay rises (Labour Code art. 140(3)).
Deadlines
| Date | Duty | Source |
|---|---|---|
| 2026-06-07 | Most changes take effect: rules on pay systems, recruitment and confidentiality. | Law No. XV-969, art. 23(1) |
| 2026-12-31 | Pay system approved or reviewed. | Law No. XV-969, art. 23(4) |
| 2027-02-28 | First monthly report to Sodra (SDUP), for January 2027. | Ministry order No. A1-433, point 2.1 |
| 2027-03-01 | Employees may ask for monthly data. You must answer within one month. | Order No. A1-433, point 2.3; Labour Code art. 148(5) |
| 2028-03-01 | Annual data for employees; pay-gap indicators for employers with 150 or more insured staff. | Order No. A1-433, point 2.3; Law No. XV-969, art. 23(5) |
Disputes and fines
If an employee points to facts that suggest discrimination, the employer must prove there was none (Labour Code art. 26(5)). The comparison is not limited to staff employed at the same time (art. 26(4), point 4).
The employee is awarded unpaid wages, material and non-material damage, and compensation for lost opportunities (Labour Code art. 219(2)).
For breaching the rules on setting, calculating and paying wages: 500 to 1450 Eur, and 1450 to 3000 Eur for a repeat breach (Code of Administrative Offences, art. 99(1) and (2)). From 1 January 2027 there is a separate fine for not providing pay information.
This summary is not legal advice. It is based on the article below, which lists its sources.
Read more on linden.lt
- Pay transparency in Lithuania: what employers must do, and by whenThe full procedure in order, with dates and article references.
- The same article in LithuanianAtlygio skaidrumas: ką darbdavys turi padaryti ir iki kada
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