Pay transparency in Lithuania
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Pay information requests Pending
Own monthly hourly pay and sex-disaggregated average monthly hourly pay for employees in the same job category; annual hourly averages are added from 2028.
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Time to respond 2 months
Every request starts a clock. Answering one needs pay structures and equal-value groupings that already exist.
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Salary history questions are banned
Applicants learn the pay range before the interview, and employers may not ask what they earn today.
Lithuania has already moved from proposal to law. The Labour Code amendments implementing pay transparency entered into force on 7 June 2026, and the core employer obligations apply nationwide from that date.
This is not a future draft you can watch from a distance. Salary publication in job advertisements and the ban on asking about salary history are already active, and employees can already ask for their own pay information. What is still ahead is the operational side: building the data flows that feed Lithuania’s central reporting system through Sodra.
Because Lithuania combines an already-active information regime with a staged, centralised reporting model, the practical work now is less about waiting for a law and more about getting your pay systems and data ready in time for each deadline.
The measure
- Law or measure
- Lietuvos Respublikos darbo kodekso 23, 26, 39, 40, 41, 42, 48, 51, 52, 65, 71, 79, 131, 140, 147, 148, 197, 217, 219, 226 straipsnių ir priedo pakeitimo įstatymas
- Core obligations start
- 7 Jun 2026
- Who is covered
- Labour Code employers and employees; related package extends aligned rules to specified public-sector employment/pay regimes.
What the law requires
- Pay range before the interview Source for: Pay range before the interview
- Salary history questions banned Source for: Salary history questions banned
- Gap reporting from 100 employees Source for: Gap reporting from 100 employees
- Joint pay assessment at a 5.0% gap Source for: Joint pay assessment at a 5.0% gap
1 further dimension is still being verified against official sources.
How Lithuania differs from the Directive
Lithuania retains salary publication in job advertisements and uses a central Sodra data model. From 2027 employers submit payroll, working-time and job-group data to Sodra. Sodra publishes monthly sex-disaggregated average hourly pay only where an employer has at least 8 employees, including more than 3 women and more than 3 men.
On at least one point the national rules go beyond the Directive minimum, so preparing to the EU baseline alone is not enough here.
What this means for employers
Your immediate obligations are already live. You must publish salary ranges in job advertisements, you cannot ask candidates about salary history, and employees can request their own pay figures along with average pay by sex for people doing the same or similar work. You have two months to respond to those requests.
The bigger operational shift is the move to Lithuania’s centralised reporting model. From 2027, employers submit payroll, working-time and job-group data to Sodra, which then calculates and publishes the required indicators using the Directive’s seven standard metrics. A joint pay assessment can be triggered where an unexplained pay gap in any category reaches 5%, alongside the other required conditions.
- By 31 December 2026: have a gender-neutral pay system in place, since this is the deadline the national timeline points to for getting pay structures ready.
- From 1 January 2027: start submitting payroll, working-time and job-group data to Sodra.
- By 2028: employers with at least 150 employees deliver their first annual pay-gap report, covering 2027 data.
- By 2031: employers with 100 to 149 employees deliver their first report, covering 2030 data.
- Ongoing: keep your recruitment and employee-information processes ready to answer requests within the two-month window.
Sodra will only publish monthly sex-disaggregated average pay for an employer where that employer has at least 8 employees, including more than 3 women and more than 3 men, so smaller job categories are handled differently. Preparing your data now helps you meet these staged deadlines without a last-minute scramble.
Enforcement and open questions
- Competent authority
- Valstybinė darbo inspekcija (VDI); Valstybinio socialinio draudimo fondo valdyba (Sodra) administers pay-transparency data flows; labour disputes bodies/courts provide remedies.
- Equality body
- Lygių galimybių kontrolieriaus tarnyba
- Penalties
- Administrative liability applies for failures to provide required pay information; other Labour Code breaches remain subject to labour-law and administrative enforcement.
- What could still change
- Core Labour Code amendments are in force but operational duties are staged. Sodra's implementation page was updated on 2 September 2026 with the SDUP data-structure description and JSON validation schema. The specification materially clarifies the fields and validation needed for system/file submissions; JSON generation is not mandatory for employers that use the Sodra employer-account form. Existing 28 February 2027 / 1 March 2027 / 1 March 2028 milestones remain unchanged.
Common questions
Is the EU Pay Transparency Directive already law in Lithuania?
Yes. Lithuania implemented it through Labour Code amendments that entered into force on 7 June 2026, so the core employer obligations are already binding nationwide, not just proposed.
Can employees in Lithuania ask what they are paid compared to colleagues?
Yes, employees can request their own pay information and the average pay by sex for people doing the same or similar work, and employers have two months to respond.
When do employers in Lithuania have to submit pay-gap reports?
Employers with at least 150 employees deliver their first annual report in 2028 using 2027 data, while employers with 100 to 149 employees deliver their first report in 2031 using 2030 data. Employers below 100 employees are not subject to this annual reporting duty.
How does Lithuania's reporting system actually work?
Lithuania uses a hybrid, centralised model: employers submit payroll, working-time and job-group data to the Sodra social insurance authority starting 1 January 2027, and Sodra calculates and publishes the required indicators. This is different from a system where employers calculate and publish the figures themselves.
What happens if an employer in Lithuania fails to provide required pay information?
Administrative liability applies for failing to provide required pay information, and other breaches of the Labour Code rules remain subject to standard labour-law and administrative enforcement. The State Labour Inspectorate and Sodra oversee these duties, with labour dispute bodies and courts providing remedies.
- Pay information request right Art. 7(1)
- Pending
- Response deadline Art. 7(4)
- 2 months
- Salary range in recruitment Art. 5(1)
- Yes
- Salary history questions banned Art. 5(2)
- Yes
- Joint pay assessment trigger Art. 10(1)
- 5.0%
Own monthly hourly pay and sex-disaggregated average monthly hourly pay for employees in the same job category; annual hourly averages are added from 2028.
Legacy composite is Partial / conditional because the right is enacted but operational information is staged: monthly own/comparator information first from 1 Mar 2027 and separately staged annual information from 1 Mar 2028.
Read the sourceThe employer must answer in writing within this period.
The employer response deadline is two months.
Read the sourceApplicants receive the pay or pay range before the interview, based on objective, gender-neutral criteria.
Salary publication in job advertisements remains required under the national framework.
Read the sourceWhether employers are prohibited from asking applicants about their current or previous pay.
The implementation summary confirms the salary-history restriction.
Read the sourceThe unjustified gap that obliges the employer and worker representatives to assess pay together.
JPA is required where a job-category average gender pay gap is at least 5%, the employer has not justified it using objective gender-neutral criteria, and the unjustified gap has not been corrected within six months.
Read the source- Reporting threshold
- 100 employees
- Reporting model
- Hybrid / centralised Operational data-production and filing model for pay-gap reporting: employer-calculated, authority-calculated, hybrid, proposed, pre-existing or absent.
- First report, 250 or more employees
- 2028 (for 2027 data)
- First report, 100 to 149 employees
- 2031 (for 2030 data)
- Metrics required
- EU seven only Art. 9(1): Seven metrics: mean gap; variable-component gap; median gap; median variable gap; variable-pay participation by sex; quartile distribution by sex; category-level gap split basic and variable.
- Pre-existing regime
- Salary publication in job advertisements pre-dated the Directive; Sodra data and disclosure duties are staged from 2027/2028.
- Formal transposition stage
- Fully in force
- Scope
- Nationwide
Next milestone
Finalise pay systems by 31 December 2026; submit the first January-2027 data to Sodra by 28 February 2027; monthly employee pay-information requests become operational from 1 March 2027.
Primary sources
- Lietuvos Respublikos darbo kodekso 23, 26, 39, 40, 41, 42, 48, 51, 52, 65, 71, 79, 131, 140, 147, 148, 197, 217, 219, 226 straipsnių ir priedo pakeitimo įstatymas Primary source, checked 4 September 2026
- Formal transposition stage Fully in force · in force · high confidence
- Core employer obligations Partly operational · in force · high confidence
- Transposition scope Nationwide · in force · high confidence
- Salary range in recruitment Yes · in force · high confidence
- Salary history questions banned Yes · in force · high confidence
- Pay information request right Partial / conditional · in force · high confidence
- Response deadline 2 months · adopted future · high confidence
- Reporting threshold 100 · adopted future · high confidence
- First report, 250 or more employees 2028 (for 2027 data) · adopted future · high confidence
- First report, 100 to 149 employees 2031 (for 2030 data) · adopted future · high confidence
- Reporting model Hybrid / centralised · adopted future · high confidence
- Joint pay assessment trigger 5.0% · in force · high confidence
- Info reference period Multiple / mixed · in force · high confidence
- Info pay basis Actual remuneration paid / earned · in force · high confidence
- Info pay components scope Total remuneration / all components · in force · high confidence
- Info request frequency At any time / no stated limit · in force · high confidence
- Info employee reference period eligibility No prior-period employment condition was identified; information availability follows the Sodra-calculated monthly/annual data model. · in force · high confidence
- Info normalisation method Monthly average hourly pay; from 2028 annual average hourly pay is calculated from calendar-year gross remuneration divided by paid hours. · in force · high confidence
- Reporting reference period Previous calendar year · in force · high confidence
- Reporting pay basis Actual remuneration paid / earned · in force · high confidence
- Reporting pay components scope Base + variable · in force · high confidence
- Reporting population basis Employees who worked during the relevant calendar year are included in the annual data model. · in force · high confidence
- Reporting normalisation method Annual average hourly pay is calendar-year gross remuneration divided by paid working hours; monthly hourly metrics are also calculated. · in force · high confidence
- Employer required input data For SDUP: employer code and reporting month; for each employee, name, surname, sex and at least one permitted identifier (personal code, social-insurance number or ILTU; birth date conditionally), plus job-group number, work-time norm, work-time regime, gross accrued pay, additional gross pay and paid work hours. Manual Sodra-account filing is available; the published JSON schema governs file/integration submissions. · in force · high confidence
- First data period needed First monthly worker comparator dataset is January 2027; employers submit it plus required job-group data to Sodra by 28 February 2027. Annual 2027 data underpins annual worker information from 1 March 2028 and the first 2028 reporting outputs. · in force · high confidence
- Own pay information Yes · in force · high confidence
- Comparator information Yes · in force · high confidence
- Comparator information start 1 Mar 2027 · in force · high confidence
- Annual average information start 1 Mar 2028 · in force · high confidence
Change history
Recent updates
Lithuania publishes technical specification for 2027 SDUP pay-transparency filings
Sodra has published the official SDUP data-structure and JSON validation specification for Lithuania's staged pay-transparency reporting process.
This page is maintained by Evenpay from official primary sources and reviewed before publication. It is general information, not legal advice. Requirements vary by member state and change as national laws progress; figures described as proposed are subject to amendment.
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