Pay system example (darbo apmokėjimo sistema)
Employers must approve a pay system by 31 December 2026, and an employer that already has one must review it and change it where needed (Law No. XV-969, art. 23(4)). The system sorts jobs into groups by objective, gender-neutral criteria and sets for the groups the forms of pay, pay amounts or ranges, and the rules for allowances, bonuses, indexation and pay rises (Labour Code art. 140(3)). Information and consultation procedures come before approval, and the approved system must be made available to all employees (Labour Code art. 140(3)).
Below is the anonymised structure of the pay system the Linden tool prepares: chapters, annexes, the job evaluation method and how groups are formed.
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The full anonymised pay system sample: 16 chapters and 6 annexes, 22 pages, in Lithuanian. Enter your e-mail address and the download link appears on this page straight away. We do not send you an e-mail.
What, by when, and under which law
| What | By when | Source |
|---|---|---|
| The new pay system requirements take effect. | 2026-06-07 | Law No. XV-969, art. 23(1) |
| Information and consultation procedures with employee representatives. | Before approving or changing the system | Labour Code art. 140(3) |
| The system is approved. An existing system is reviewed and changed where needed. | 2026-12-31 | Law No. XV-969, art. 23(4) |
| The approved system is available to all employees. | Once approved | Labour Code art. 140(3) |
Other dates (Sodra reports, employee requests, fines) are on the legal basis page.
What the system covers: 16 chapters
The example is written for a fictional company. The company name, jobs and amounts in it are placeholders. Each chapter answers a requirement of Labour Code art. 140(3) or a duty linked to it.
- General provisions. Who the system covers, which laws it rests on and its principles.
- Definitions. Base and additional pay, job group, the same work and work of equal value.
- Job evaluation and grouping. The job is evaluated, not the person in it; jobs doing the same work or work of equal value go into the same group.
- Forms of pay and the make-up of pay. Monthly salary or hourly rate for each group.
- Pay ranges. Minimum and maximum base pay for each group; group ranges do not overlap.
- Allowances, supplements and bonuses. For each one: the ground, the amount and how it is granted.
- Indexation. When ranges and salaries are reviewed and against which indicator.
- Pay rises. Criteria and procedure for raises. Optional for employers with fewer than 50 employees.
- Recruitment. Pay in job ads and how starting pay is set.
- Confidentiality. An employee may disclose their own pay to enforce equal pay (Labour Code art. 39(1)).
- Right to information and annual notice. How employees request pay data and how fast they get it.
- Reporting to Sodra. Who is responsible for the monthly report and the job group number.
- Explaining and fixing a pay gap. What to do when men's and women's pay differ within a group.
- Information and consultation. How the system is agreed with the works council, trustee or trade union.
- Review. When and what to check every year.
- Final provisions. Approval, entry into force and staff acknowledgement.
Six annexes
- Job groups and pay ranges.
- Job evaluation method.
- Setting an employee's place within the group range.
- Variable pay (optional).
- Annual notice to employees (form).
- Order approving the system (form).
How jobs are evaluated
Each job is scored on 15 sub-factors. Each gets a level from 1 to 5, the level is multiplied by the weight, and the products are added up. The weights add up to 100, so a job scores between 100 and 500 points. The weights are the example's choice, not a legal requirement; the law sets only the criteria.
| Sub-factor | Labour Code art. 140(3) criterion | Weight |
|---|---|---|
| Qualification | Qualification | 6 |
| Professional knowledge | Skills | 6 |
| Communication and interpersonal skills | Skills | 8 |
| Problem-solving skills | Skills | 8 |
| Planning and organising skills | Skills | 6 |
| Physical skills | Skills | 6 |
| Responsibility for people | Responsibility | 12 |
| Responsibility for goods and equipment | Responsibility | 7 |
| Responsibility for information | Responsibility | 8 |
| Responsibility for financial resources | Responsibility | 8 |
| Mental effort | Effort | 5 |
| Psychosocial and emotional effort | Effort | 6 |
| Physical effort | Effort | 4 |
| Work environment (physical and psychological) | Working conditions | 7 |
| Organisational environment (intensity and working time) | Working conditions | 3 |
From points to groups
The example has five groups: 100–179, 180–259, 260–339, 340–419 and 420–500 points. The bands do not overlap, so every score falls into exactly one group. Each group gets a minimum and maximum base pay, and each higher group's minimum is above the lower group's maximum. You set the amounts from your own payroll; they cannot be below the minimum monthly wage approved by the Government (Labour Code art. 141(1) and (3)).
Five jobs, three groups and a 5% gap
A made-up company with five jobs. Each job is scored on the same 15 subfactors and weights described above: a level from 1 to 5 is multiplied by the weight, and the products are added up.
1. Job evaluation
| Subfactor | Weight | Cleaner | Warehouse worker | Office administrator | Accountant | Sales manager |
|---|---|---|---|---|---|---|
| Qualification | 6 | 1 | 2 | 2 | 4 | 3 |
| Professional knowledge | 6 | 1 | 2 | 2 | 4 | 3 |
| Communication and interpersonal skills | 8 | 2 | 2 | 4 | 3 | 5 |
| Problem-solving skills | 8 | 1 | 2 | 2 | 4 | 3 |
| Planning and organising skills | 6 | 1 | 2 | 3 | 3 | 3 |
| Physical skills | 6 | 3 | 4 | 1 | 1 | 1 |
| Responsibility for people | 12 | 1 | 1 | 1 | 1 | 1 |
| Responsibility for goods and equipment | 7 | 2 | 4 | 2 | 1 | 2 |
| Responsibility for information | 8 | 1 | 1 | 3 | 4 | 3 |
| Responsibility for financial resources | 8 | 1 | 2 | 2 | 5 | 4 |
| Mental effort | 5 | 1 | 2 | 2 | 4 | 3 |
| Psychosocial and emotional effort | 6 | 1 | 2 | 3 | 3 | 4 |
| Physical effort | 4 | 4 | 4 | 1 | 1 | 1 |
| Work environment (physical and psychological) | 7 | 3 | 4 | 1 | 1 | 2 |
| Organisational environment (intensity and working time) | 3 | 2 | 3 | 2 | 3 | 3 |
| Total points | 100 | 156 | 231 | 207 | 277 | 272 |
2. Groups and pay ranges
The scores fall into the first three groups of the example. The warehouse worker and the office administrator do different work, but their scores fall into the same group, so their work counts as work of equal value.
| Group | Points | Jobs | Monthly base pay |
|---|---|---|---|
| 1 | 100–179 | Cleaner (156) | 1250–1400 EUR |
| 2 | 180–259 | Office administrator (207), warehouse worker (231) | 1450–1750 EUR |
| 3 | 260–339 | Sales manager (272), accountant (277) | 1800–2600 EUR |
The amounts are illustrative only. No range is below the 2026 minimum monthly wage of 1153 EUR (Government resolution No. 700). You set your own ranges from your company’s pay.
3. Gap check in group 2
Four people work in group 2. All work full time and the same hours, so comparing monthly pay gives the same result as comparing hourly pay.
| Employee | Job | Sex | Pay |
|---|---|---|---|
| A | Warehouse worker | Man | 1660 EUR |
| B | Warehouse worker | Man | 1620 EUR |
| C | Office administrator | Woman | 1558 EUR |
| D | Office administrator | Woman | 1558 EUR |
Men’s average: (1660 + 1620) / 2 = 1640 EUR. Women’s average: 1558 EUR. Gap: (1640 − 1558) / 1640 = 5.0% of the men’s average. This is also how Sodra calculates the gap (order No. A1-433, description point 5.77).
4. What the employer does
- Looks for an objective reason. It must be provable with documents and gender-neutral, for example the employee’s place within the group range under the rules in annex 3. Warehouse working conditions are already in the points. Using them to justify the gap as well would count the same factor twice, which is hard to defend. So the rules for placement within a group range should not reuse factors already in the points either.
- If there is no reason, closes the gap. In this example the two administrators get 1640 EUR each. That is within the group range, and the gap becomes 0%. The State Labour Inspectorate stresses that 5% is not an allowed gap: any unjustified gap is a breach (VDI FAQ, question 7.1).
- Writes down the decision and the reasons. In a dispute, the employer must prove there was no discrimination (Labour Code art. 26(5)).
- Pays attention to the 5% threshold. Employers with 100 or more insured staff carry out a joint pay assessment with staff representatives when Sodra’s data show a gap of at least 5% in any group that is not justified and not corrected within six months of receiving Sodra’s indicators (Labour Code art. 23(11), wording from 2027-01-01). Sodra gives the first indicators by 2028-03-01 to employers with 150 or more insured staff, and by 2031-03-01 to those with 100 to 149 (order No. A1-433, point 3.1.1).
The gap in group 3 is smaller: the sales manager (a man) earns 2150 EUR and the accountant (a woman) 2100 EUR, which is 2.3%. It is below 5%, but the reason still has to be written down. Only one cleaner, a woman, works in group 1, so there is no one to compare with.
Questions about the example
Is filling in a template enough?
No. Jobs must be sorted into groups by objective, gender-neutral criteria: skills, qualification, effort, responsibility and working conditions. Jobs doing the same work or work of equal value go into the same group (Labour Code art. 140(3)). So the groups can only be formed after your own jobs are evaluated.
Is a pay system required if we have fewer than 20 employees?
Yes. Until 7 June 2026 the duty applied to workplaces with an average of 20 or more employees. Now every employer must approve a pay system unless a collective agreement sets one (Labour Code art. 140(3)).
What can an employer with fewer than 50 employees leave out?
Only the criteria and procedure for pay rises (Labour Code art. 140(3)). In the example that is chapter VIII. All other requirements apply to everyone.
We have an old pay system. Must we change it?
You must review it and change it where needed by 31 December 2026, following Labour Code art. 140 (Law No. XV-969, art. 23(4)). The earlier wording did not require jobs to be grouped by gender-neutral criteria.
What is work of equal value?
Work that, measured by the objective and gender-neutral criteria of Labour Code art. 140(3), is of the same value as the other work it is compared with. Men and women must get equal pay for the same work or work of equal value (Labour Code art. 140(5)).
How is the Linden tool different from the example?
The example shows what a pay system looks like. The tool helps you evaluate your jobs, proposes groups and pay ranges, checks pay differences and prepares the document in Word. A Linden lawyer checks the final document. How it works
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