Preparing for the Pay Transparency Directive: what employers in Lithuania must do by 2026-12-31
Lithuania transposed the Pay Transparency Directive (EU) 2023/970 by the law amending the Labour Code, No. XV-969, adopted on 21 May 2026. The main duty for every employer is to approve a pay system, or review the one it has, by 31 December 2026 (Law No. XV-969, art. 23(4)). In the pay system, jobs must be grouped by objective, gender-neutral criteria, and staff representatives must be informed and consulted before it is approved (Labour Code art. 140(3)).
Below: the steps in order, a table of dates with sources, and answers to common questions. We checked every legal text on e-TAR and EUR-Lex on 2026-10-21.
Steps for the employer
- List every job and evaluate it. Score each job by skills, qualifications, effort, responsibility and working conditions, and other relevant criteria where appropriate (Labour Code art. 140(3)). You evaluate the work, not the person.
- Group the jobs. Jobs doing the same work or work of equal value go into the same group (Labour Code art. 140(3)). You will later report the group number to Sodra.
- Set pay for each group or job. The pay system must set the forms of pay, pay levels or ranges (minimum and maximum), the grounds, amounts and rules for allowances, supplements and bonuses, and the criteria and rules for indexation and pay rises. Employers with fewer than 50 staff do not need criteria and rules for pay rises (Labour Code art. 140(3)).
- Check the pay gap between men and women in each group. Men and women must be paid the same for the same work or work of equal value (Labour Code art. 140(5)). You can work out the gap per group with the free pay gap check.
- Inform and consult staff representatives before you approve it. Labour Code art. 140(3) requires this. A works council must be set up when the average number of staff is 20 or more, unless a trade union at employer level has more than one third of the staff as members (Labour Code art. 169(1) and (4)). More on the Works council page.
- Approve the pay system by 31 December 2026. If you already have one, review it and change it where needed (Law No. XV-969, art. 23(4)). If a collective agreement sets the pay system, no separate employer pay system is needed (Labour Code art. 140(3)).
- Make the pay system available to every employee. This is a requirement of Labour Code art. 140(3). How to record that each employee received it: Staff acknowledgement.
- Get payroll ready for the Sodra report. From 2027, employers report each month to Sodra the pay, working time and job group of each employee (Labour Code art. 23(3), version from 2027-01-01). The first report is due by 28 February 2027, for January 2027 (ministry order No. A1-433, point 2.1).
- Be ready to answer employee requests. From 1 March 2027, an employee may ask for their own average hourly pay for the month and the average hourly pay by gender in their job group (order No. A1-433, point 2.3). The employer answers in writing within one month and tells staff about this right every year (Labour Code art. 148(4) and (5), version from 2027-01-01).
- With 100 or more insured staff, prepare for the pay gap indicators. Sodra will first send them to employers with 150 or more insured staff by 1 March 2028, and to those with 100 to 149 by 1 March 2031 (Law No. XV-969, art. 23(5)). If the gap in any group is at least 5% and is not justified by objective criteria, it must be corrected within six months, together with the staff representatives (Labour Code art. 23(10) and (11), version from 2027-01-01).
Start by checking which requirements apply to your company, and look at the pay system example.
How long it takes when a Linden attorney does all the work
About 8 weeks. A works council election, if you need one, runs at the same time.
Pay system
Works council (if needed)
Who, by when, and what fine
| What | By when | Source |
|---|---|---|
| Member States transpose the directive into national law | 2026-06-07 | Directive (EU) 2023/970, art. 34(1) |
| Most Lithuanian changes take effect (pay system, recruitment, confidentiality rules) | 2026-06-07 | Law No. XV-969, art. 23(1) |
| Every employer approves a pay system or reviews its existing one | 2026-12-31 | Law No. XV-969, art. 23(4); Labour Code art. 140(3) |
| New Labour Code art. 23 (data to Sodra) and art. 148(4)–(9) (employee requests) take effect | 2027-01-01 | Law No. XV-969, art. 23(2) |
| First monthly report to Sodra (SDUP), for January 2027 | 2027-02-28 | Order No. A1-433, point 2.1 |
| Employees may request monthly data; answer within one month | from 2027-03-01 | Order No. A1-433, point 2.3; Labour Code art. 148(5) |
| Sodra sends pay gap indicators to employers with 150 or more insured staff | 2028-03-01 | Law No. XV-969, art. 23(5); order No. A1-433, point 3.1.1.1 |
| Sodra sends pay gap indicators to employers with 100 to 149 insured staff | 2031-03-01 | Law No. XV-969, art. 23(5); order No. A1-433, point 3.1.1.2 |
The fine for breaching the rules on setting, calculating and paying wages laid down in the Labour Code or a pay system is EUR 500 to 1,450 for employers or other responsible persons, and EUR 1,450 to 3,000 for a repeat breach (Code of Administrative Offences art. 99(1) and (2); from 2027-01-01, art. 99(3) and (4)). All fines and the changes from 2027: Legal basis.
The directive sets reporting dates for employers themselves (250 or more and 150 to 249 staff: from 7 June 2027 at the latest; 100 to 149: from 7 June 2031; directive art. 9(2)–(4)). In Lithuania, Sodra calculates the pay gap indicators from the employers' monthly reports, so the Lithuanian dates in the table are the ones that matter for a Lithuanian employer.
Common questions about preparing
What is the Pay Transparency Directive?
It is Directive (EU) 2023/970 of the European Parliament and of the Council of 10 May 2023. It strengthens the principle of equal pay for men and women for equal work or work of equal value. Member States had to transpose it by 7 June 2026. Lithuania did so by the law amending the Labour Code, No. XV-969.
By when must we be ready?
The pay system must be approved or reviewed by 31 December 2026. The first report to Sodra is due by 28 February 2027, and employees may request data from 1 March 2027.
Does this apply to a small company?
Yes. Every employer must approve a pay system unless a collective agreement sets it. Employers with fewer than 50 staff do not need criteria and rules for pay rises (Labour Code art. 140(3)).
We already have a pay system. Do we need to do anything?
You need to review it and change it where needed by 31 December 2026 (Law No. XV-969, art. 23(4)). Check that jobs are grouped by the criteria in Labour Code art. 140(3) and that each group has pay levels or ranges.
Do we need to consult staff?
Yes. Before a pay system is approved or changed, the information and consultation procedures must be carried out (Labour Code art. 140(3)). They take place with the staff representatives: the works council, a trade union or an employee trustee, where there is one.
What fine can apply?
For breaching the rules on setting, calculating and paying wages, employers or other responsible persons can be fined EUR 500 to 1,450, and EUR 1,450 to 3,000 for a repeat breach (Code of Administrative Offences art. 99(1) and (2); from 2027-01-01, art. 99(3) and (4)). In a dispute, an employee can claim unpaid pay and compensation for damage (Labour Code art. 219(2)).
Read more
- Legal basisLabour Code, order No. A1-433 and fines, with sources.
- Pay system exampleWhat a pay system must contain, with a worked example.
- Pay gap checkWork out the gap between men and women in each group, free.
- Requirements that apply to youA few questions about your company and a list of what applies.
- Pay transparency in Lithuania: what employers must do, and by whenFull article on linden.lt.
Prepare your pay system
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