By Sally Makreff
BLOG OVERVIEW: Earlier this year, Lithuania became one of the first EU member states to transpose the EU Pay Transparency Directive, enacting Labour Code amendments effective June 7, 2026 while delaying compensation-system updates until December 31, 2026 and monthly data submissions and right-to-information provisions until January 1, 2027. Lithuania’s law mirrors the Directive in most respects but goes further in several areas, mandating a formal remuneration system, specific job-classification criteria, and a centralized reporting model in which employers submit raw payroll data to SoDRA, which then calculates the gender pay gap reports. A two-tier reporting timeline applies. Employers now face concrete next steps to prepare, and DCI Consulting can serve as a partner for worker categorization, gender pay gap analyses, remediation, and right-to-information support.
On May 21, 2026, Lithuania joined Slovakia and Italy as one of the first EU member states to enact legislation implementing the European Union Pay Transparency Directive (the Directive). Lithuania’s Parliament (Seimas) gave final approval to Labour Code amendments under Law No. XV-969, officially incorporating the Directive into national law.
Although most of the Directive’s requirements took effect on June 7, 2026, Seimas delayed two key measures: Updates to compensation system structures and the monthly data submission requirement. Employers now have until December 31, 2026, to bring their pay systems into compliance. Monthly submissions to the State Social Insurance Fund Board (SoDRA) and right-to-information requirements will begin on January 1, 2027.
Despite Lithuania’s delay in implementing those two key elements, the other deadlines and requirements outlined in the Labour Code amendments are not significantly different from those of the Directive. However, they do include a more detailed and structured framework for how employers implement and demonstrate compliance.
How Does Lithuania’s Legislation Align with the Directive?
Lithuania’s Labour Code amendments closely mirror the fundamental requirements of the Directive by defining equal pay for equal work or work of equal value, increasing transparency in pay-setting practices, and expanding employees’ access to pay information. Under the amended law and in alignment with the Directive, employers in Lithuania must use objective, gender-neutral criteria to evaluate and classify jobs, and provide employees with information about their pay and the average pay of comparable workers broken down by gender. In addition, Lithuania has incorporated the Directive’s key enforcement elements that include protections for employees, a shift in the burden of proof in pay discrimination cases, and the right to full compensation for workers who experience pay discrimination.
How Does Lithuania’s Legislation Go Beyond the Directive?
While the Labour Code amendments are largely a direct transposition of the Directive, several key differences exist:
- Pay Structure and Progression Transparency: The Directive requires employers to establish objective and gender-neutral pay-setting and pay progression criteria, leaving implementation details to individual EU states. Lithuania mandates that employers maintain a formal remuneration system that includes job groupings, salary ranges, bonus rules, and allowances. In addition, pay progression criteria must be included in remuneration systems, although employers with fewer than 50 employees are exempt from documenting pay progression procedures.
- Defining “Same Work” and “Work of Equal Value”: While the Directive instructs employers to use objective, gender-neutral criteria for “work of equal value,” Lithuania requires jobs to be classified using specific criteria such as skills, qualifications, effort, responsibility, and working conditions, creating a more structured approach to determining work of equal value.
- Reporting Mechanism: The biggest difference between the Directive and Lithuania Labour Code amendments is the pay data reporting mechanism. The Directive requires employers to extract, calculate, and report their own gender pay gap data and metrics. Lithuania builds on its previously established centralized model for reporting pay data and requires employers to submit raw payroll data, working time, and job group data on a monthly basis to SoDRA, which will calculate and prepare the detailed gender pay gap reports based on the monthly pay data.
Reporting Timeline Under Lithuania’s Legislation
The final law establishes a two-tier permanent reporting cycle: Employers with 250 or more insured persons must report annually, while employers with 100-249 insured persons must report every three years. For first reporting deadlines, the law introduces a transitional 150-person split: employers with 150 or more insured persons will first receive their calculated indicators for SoDRA by March 1, 2028, with public disclosure by April 1, 2028. Employers with 100-149 insured persons will first receive data by March 1, 2031, with public disclosure by April 1, 2031. SoDRA will also initially provide employers with annual average pay data by job group and gender by March 1, 2028.
Penalties for Non-Compliance
Under the Labour Code amendments that transposed the directive, administrative offenses are categorized as follows:
- Transparency and reporting: Fines are between €400–€6,000 for pay transparency or reporting omission violations.
- Information Withholding: Employer representatives (e.g. HR officers) can be fined between €460–€1,400 for failing to provide required pay information to employees which increases upon repeat offenses.
In addition, the compensation remedies under the Labour Code Article 219 implementing the Directive are very broad and include full recovery of unpaid wages or payments in kind, compensation for lost opportunities, non-pecuniary damage, and damages arising from multiple discrimination (harm arising from a combination of grounds, such as gender and ethnicity or age).
Next Steps for Employers
Now that Lithuania has enacted legislation to implement the Directive, there is a legal obligation for employers to comply with all of the elements of the legislation. This includes updating job advertisements to include starting salary information, evaluating and documenting job classifications based on gender-neutral criteria, and setting up payroll systems to track and log the required information that will need to be submitted to SoDRA.
In addition, employers need to review salary discrepancies based on gender, research any gender pay gaps of 5% or more, and be prepared to respond to employee requests for written explanations regarding their individual pay and average pay levels for workers doing comparable work.
DCI will continue to monitor EU Pay Transparency Directive updates as they occur.
DCI Consulting helps employers turn complex EU Pay Transparency requirements into clear, defensible pay decisions before reporting becomes mandatory. We partner with your organization to establish or review worker categories, conduct required gender pay gap analyses, develop targeted remediation strategies, and provide guidance on right to information requests. Visit our EU Pay Transparency Directive page to learn how your organization can prepare to confidently meet upcoming deadlines and subsequent reporting requirements.
