EU Pay Transparency in Lithuania: a practical checklist for 2026–2027

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By Simona Kerpiškienė, Co-Founder, Human Resources

Lithuania has already transposed the EU Pay Transparency Directive. The law was adopted on 21 May 2026 and most of it has applied since 7 June 2026. The more demanding parts – job grouping, monthly pay data to Sodra and the employee right to compare pay – start on 1 January 2027.

If you employ people in Lithuania, you have roughly three months to get your pay system in order. This guide explains what changed, what applies to your company size, and what to do first.

What already applies since 7 June 2026

These rules apply to every employer, regardless of size:

  • Pay range before hiring. Job ads must show the proposed pay or pay range, and candidates must have this information before the interview. Lithuania already required salary in job ads; the new rules make it stricter and apply it to every recruitment channel.
  • No salary history questions. You can no longer ask candidates what they earn now or earned before.
  • Employees may discuss pay. Contract clauses that forbid employees from sharing their own pay are no longer enforceable for equal pay purposes. Review your employment contract templates.
  • Burden of proof shifts to the employer. If an employee presents facts suggesting pay discrimination, the employer has to prove there was none.
  • Gender-neutral criteria. Pay and pay progression must be based on objective mandatory criteria – skills, qualification, effort, responsibility and working conditions.

What starts on 1 January 2027

Obligation Who From
Pay system aligned with objective, gender-neutral criteria All employers 31 December 2026
Job groups (“work of equal value”) defined All employers 1 January 2027
Employee right to request their pay level and average pay by gender for their job group (reply within one month) All employers 1 January 2027
Monthly pay, working time and job group data to Sodra All employers 1 January 2027
Gender pay gap indicators calculated by Sodra 250+ employees first by 1 March 2028
Gender pay gap indicators calculated by Sodra 100–249 employees first by 1 March 2031
Joint pay assessment if the gap in a job group is 5% or more and not justified Employers that report after the first report

A useful detail for foreign companies: in Lithuania, Sodra calculates the gender pay gap indicators from the data you submit. You do not need to produce the report yourself – but the quality of your job grouping decides what the report will show. However Sodra will calculate only a few general averages that might not be very clear to employees. Therefore it is advisable to produce own report with mandatory and additional data for clarity and transparency.

What your company size means

  • All companies: monthly reporting to Sodra from January 2027. A gap of 5% or more in any job group that you cannot justify triggers a joint pay assessment with employee representatives.
  • Under 20 employees: recruitment rules, gender-neutral pay criteria and the right to information apply. Keep it simple, but document how you set pay. A written remuneration system (“darbo apmokėjimo sistema”) becomes mandatory for all companies even with 1 employee.
  • 20–49 employees: Lithuanian law already requires a written remuneration system (“darbo apmokėjimo sistema”) for employers with 20 or more employees. Now it must also define job groups and objective criteria.
  • 50–99 employees: as above, plus you must already have an equal opportunities policy. Expect employee questions about pay – have your answers ready.
  • 100–249 employees: Your first annual gender pay gap indicators come in 2028 (150–249) or 2031 (100–149).
  • 250+ employees: Annual indicators from 2028.

Fines and risks

  • Administrative fines for breaching equal pay rules range from about €500 to €6,000; failing to answer an employee’s information request costs €460–700, and €700–1,400 when repeated.
  • Employees who prove pay discrimination can claim back pay – potentially from the moment it started.
  • The bigger risk is often reputational: pay gap indicators for larger employers become publicly visible.

Enforcement is shared by the State Labour Inspectorate, the Equal Opportunities Ombudsperson and Sodra.

Checklist: what to do before 1 January 2027

  • Update recruitment. Add pay ranges to every job ad and remove salary history questions from application forms, interview guides and recruiter scripts.
  • Review contracts. Remove or reword pay confidentiality clauses.
  • List all roles and group them. Compare roles by the mandatory criteria, listed in the labour code: skills, qualification, effort, responsibility and working conditions – not by job titles or departments.
  • Write down your pay criteria. How is pay set at hiring? What decides raises and bonuses? If it isn’t written, it isn’t defensible.
  • Run a pay check before Sodra does. Compare pay by gender within each job group. Fix unjustified gaps now, while it is your decision.
  • Prepare managers. Employees will ask. Managers need a clear, consistent answer on how pay is set.
  • Plan the Sodra data flow. Make sure your payroll system can tag each employee with a job group.

The most common mistake companies make when writing a remuneration system is filling in the document with all the details as-is. “A cohesive and logical system starts from identification of jobs in the company (actual jobs, not position titles) and grouping them into meaningful groups,” says Jurgita Galkauskiene, Rewards consultant. “Best practice would be to dedicate a few hours to create groups of jobs and only then define pay rules for those groups. There will certainly be discrepancies on employee level, action plans can be created afterwards how to address those discrepancies”.

How Amber Axis can help

We help companies in Lithuania build pay systems that meet the new rules without turning them into bureaucracy: role mapping and job grouping, pay criteria, a pay gap check and manager training.

If you are ready to document your pay system, but need a template, here is the working template to use.

If you are not sure where your company stands, start with a short HR audit or contact us.

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