EU Pay Transparency Directive Lithuania: A Compliance Guide

At a Glance

• Status: Fully enacted. The Law Amending the Labour Code No. XIV-2894 was passed by the Seimas and integrated directly into the Lithuanian Labour Code (Darbo kodeksas), published on 25 June 2026 with effect from 7 June 2026

• EU transposition deadline: 7 June 2026

• Existing framework: Built on the Labour Code (Articles 140 and 148) and the Law on Equal Opportunities. Lithuania mandated salary ranges in job ads and banned salary history questions in 2019

• Reporting threshold: Mandatory remuneration system for all employers regardless of size; Sodra-based reporting for 100+

• Distinctive feature: Sodra - the State Social Insurance Fund. They automatically calculate the seven required pay gap indicators from monthly employer filings. There is no annual "reporting season"

• Reporting cadence: Monthly data submission to Sodra; annual derived reports for 100+

Implementation Status: The Pioneer of the Baltics

Lithuania has been the EU pay transparency pioneer since 2019, when it mandated salary ranges in job ads and banned salary history questions. While other countries are scrambling to build new systems for the 2026 deadline, Lithuania is upgrading an existing framework.

According to DCI Consulting's analysis, the Government approved the Labour Code amendments on 18 March 2026. The Seimas then passed the Law Amending the Labour Code No. XIV-2894, which was published on 25 June 2026 and took effect from 7 June 2026. According to Sorainen's implementation guide, the 2026 update primarily adds the right to information and the 5% remediation trigger. See PayAlign's Full Directive Guide for more on Article 7 (right to information) and Article 10 (joint pay assessment).

The Lithuanian approach is distinctive in three ways:

1. Sodra automation. Employers submit monthly data on pay, hours and job categories to Sodra (the State Social Insurance Fund). The state calculates the seven required pay gap indicators directly from this data.

2. No reporting season. Compliance is a monthly data accuracy obligation.

3. Universal remuneration system mandate. Every employer regardless of size must operate a formal, written remuneration system from June 2026.

Enforcement responsibility sits with two bodies:

• Valstybinė darbo inspekcija (VDI) - the State Labour Inspectorate

• Lygių galimybių kontrolieriaus tarnyba - the Office of the Equal Opportunities Ombudsperson

Sodra publishes average pay data by gender for firms with 8+ employees through the Sodra public data portal.

Scope and Thresholds

The EU Pay Transparency Directive applies to all Lithuanian employers in both the public and private sectors. The Lithuanian transposition produces an unusual scope structure:

• All employers (any size): mandatory written remuneration system, salary ranges in job ads and a salary history ban

• 8+ employees (more than three of each gender): Sodra automatically calculates and publicly publishes average monthly hourly pay differences by gender

• 20+ employees: share annual anonymised average remuneration breakdowns by occupational group and gender with the local Works Council or Trade Union

• 50+ employees: the remuneration system must include specific criteria for wage increases

• 100+ employees: Sodra-derived pay gap reporting

The 15 May reporting date reflects Sodra's existing administrative cycle. Reports are derived automatically from monthly Sodra submissions. Companies with fewer than 100 employees are exempt from public filing, while those with fewer than 50 are also exempt from documenting formal career progression criteria.

Under the Lithuanian transposition, employees can request gender-segregated average pay data for their job category. The employer has a strict one-month turnaround to respond, substantially shorter than the EU baseline two-month window.

Key Metrics

Sodra automatically calculates the seven required EU Directive indicators from monthly employer filings:

• The gender pay gap (mean)

• The gender pay gap in complementary or variable components

• The median gender pay gap

• The median gender pay gap in variable components

• The proportion of female and male workers receiving variable components

• The proportion of female and male workers in each quartile pay band

• The gender pay gap by category of workers performing equal work or work of equal value

Under the Lithuanian transposition, every role must belong to a defined job group (pareigybių grupė) using the four-factor methodology (darbo vertės nustatymas) of skills, effort, responsibility and working conditions.

The remuneration system (darbo užmokesčio sistema) must be formal and written. For employers with 50+, it must additionally include specific criteria for wage increases.

Most EU member states give employers an annual reporting window. This is a 12-month opportunity to clean up payroll data before submission. Lithuania does not.

Sodra calculates the seven pay gap indicators automatically from monthly employer filings. A clerical error in any month becomes part of the annual gap calculation. There is no opportunity to audit and correct before the state derives the figures.

For Lithuanian HR teams, this changes the operational model:

1. Data accuracy is a monthly obligation. Job category misallocation, hours errors and pay component miscoding feed directly into the state's gap calculation.

2. Audit happens in real time. A 5% gap notification arrives the moment Sodra's monthly computation flags it.

3. Public visibility compounds the risk. Sodra already publishes average pay by gender for firms with 8+ employees. Errors are not just regulatory exposure, they are public-data exposure.

The 2026 amendments add a 5% hard stop. If Sodra's data shows a gap of 5% or more in any category that is not justified by objective factors, the employer has 6 months to remediate before a mandatory Joint Pay Assessment with the Works Council or Trade Union is triggered.

Where Lithuania Goes Beyond the Directive

Lithuania's transposition is one of the most rigorous in the EU:

Universal remuneration system mandate. Every employer regardless of size must operate a formal written remuneration system. The EU Directive only requires this for 100+.

Sodra automated reporting. No other EU member state has the state automatically calculate the seven pay gap indicators.

One-month response window. The right to information operates on a 30-day deadline rather than the EU baseline two months.

Salary ranges in job ads since 2019 and salary history ban since 2019. Lithuania has been ahead of the EU pay transparency curve for seven years.

Public Sodra pay visibility. For firms with 8 or more employees (more than three of each gender), Sodra automatically publishes average monthly hourly pay differences by gender.

Internal disclosure for 20+ employers. Employers with 20 or more staff must share annual anonymised average remuneration breakdowns by occupational group and gender with their Works Council or Trade Union.

Wage increase criteria for 50+ employee employers. The remuneration system must include specific criteria for raises.

Annual notification (metinis pranešimas). Employers must notify all employees annually of their pay information rights.

Penalties and Risks of Non-Compliance

Lithuanian enforcement operates through the State Labour Inspectorate (Valstybinė darbo inspekcija, VDI). VDI fines for pay transparency breaches range from €1,000 to €3,000 for initial offences and rise to €5,000 for repeat issues.

Three changes materially shift the litigation risk profile:

1. Reversal of the burden of proof. Where pay transparency obligations have not been met, the employer must prove no discrimination occurred.

2. Sodra data accuracy exposure. Errors in monthly Sodra submissions become evidence in equal pay claims. There is no buffer between submission and regulator visibility.

3. 5% hard stop with 6-month remediation. Where Sodra flags a gap, the 6-month remediation window starts immediately. Failure to remediate triggers a mandatory Joint Pay Assessment.

4. The right to compensation under Articles 16 and 17 includes full recovery of back pay, lost opportunities and non-material damages with no statutory upper limit.

How PayAlign Helps Irish Employers Prepare

PayAlign is a compliance platform built specifically for the Irish Gender Pay Gap Information Act and the EU Pay Transparency Directive. It takes Irish & EU payroll data through the full compliance workflow without the spreadsheet engineering most employers currently rely on.

The platform handles automated gender pay gap reporting calculations across all 14 mandatory Irish and the EU Directive metrics, category-of-workers reporting, joint pay assessment workflow including documentation, audit-ready data supporting the reversed burden of proof and submission-ready outputs for the centralised public portal.

If you are an Irish enterprise with operations or an entity inside Lithuania, PayAlign maps your Lithuanian headcount to the Sodra-driven model alongside your Irish reporting obligations in a single workflow. To see how it works, book a demo.

Frequently Asked Questions

When does the EU Pay Transparency Directive take effect in Lithuania?

The Law Amending the Labour Code No. XIV-2894 took effect on 7 June 2026 and was published on 25 June 2026. The Government had approved the amendments on 18 March 2026.

What is Sodra and why does it matter for pay transparency?

Sodra is the Lithuanian State Social Insurance Fund. Lithuanian employers already submit monthly data on pay, hours and job categories to Sodra. From June 2026, Sodra will use this data flow to automatically calculate the seven required EU Directive pay gap indicators which makes compliance a monthly data accuracy obligation rather than an annual reporting cycle.

Does the Directive apply to all Lithuanian employers regardless of size?

Substantive obligations apply to all employers: the mandatory written remuneration system, the salary history ban (since 2019) and salary ranges in job ads (since 2019). Employers with 50+ must additionally include specific criteria for wage increases. Employers with 100+ are subject to Sodra-derived pay gap reporting. Sodra also publicly publishes average pay differences by gender for firms with 8 or more employees, while employers with 20 or more must share annual anonymised breakdowns with their Works Council or Trade Union.

How does Lithuanian law differ from the EU Directive itself?

Lithuania goes beyond the EU minimum: a universal remuneration system mandate, Sodra automated reporting, a one-month response window and existing salary range and salary history rules in place since 2019.

What happens if Sodra detects a 5% pay gap?

The employer has 6 months to remediate before a mandatory Joint Pay Assessment with the Works Council or Trade Union is triggered. The remediation window starts immediately when Sodra flags the gap.