Lithuania: EU Pay Transparency Directive legislation at a glance

Many of the requirements, timelines, and employer size thresholds in Lithuania’s new laws track the EU Directive’s baseline guidance. However, there are some key exceptions that have the effect of making the law more comprehensive and stringent. 

• Most noteworthy, all employers of any size must have a written remuneration system that classifies job roles into groups based on objective, gender-neutral criteria; the deadline is December 31st, 2026. However, only employers with 50 or more employees must document their pay progression criteria.
• Starting on February 28th, 2027,  SoDRA will require expanded monthly payroll data.
• Employers do not need to calculate their own pay gaps. This will be done by SoDRA, which will make this data public beginning in 2028.
• There are exceptions to the above for employers with temporary employees. These employers must calculate and report data for all temporary employees for 7 required indicators. Annual reports are required for employers with 250+ employees and triennial reports for those with 100–249 employees.
• There is a required response time of only 1 month to respond to right to information (RTI) requests from employees (EUPTD baseline is 2 months).
• The new law does not nullify Lithuania’s pre-existing internal disclosure requirements. Employers with an average of 20 or more employees must report data (average salary by occupational group and gender) annually to their labor council or trade union.