Complying with the Lithuanian transposition of the EUPTD

Lithuania’s formal transposition of the EU Pay Transparency Directive (EUPTD) was established via Law No. XV-969, which introduces sweeping amendments to the Lithuanian Labor Code. This regulation sets extensive compliance obligations for employers operating in Lithuania regarding standardized remuneration systems, hiring transparency, employee information rights, and automated equal pay reporting.

Because the legislation introduces a two-track compliance timeline starting June 7, 2026, organizations must closely evaluate when specific requirements become legally binding. This article details the objective compliance timelines, highlights where Lithuanian law deviates from or aligns with the broader EU Directive, and explains how to use beqom’s PayAnalytics solution to align your compensation data with local standards and manage upcoming data obligations.

Compliance timeline & effective dates

Under the new amendments, Lithuania applies a phased implementation strategy. Initial candidate protections take effect immediately, while structural pay architectures and automated reporting roll out over a series of deadlines.

Requirements effective on June 7, 2026

The following core pre-employment compliance protocols apply to all covered employers as of June 7, 2026:

• Pre-employment transparency: Employers must provide job applicants with information regarding the initial basic salary or the applicable salary range for the position, determined on the basis of objective and gender-neutral criteria. This requirement is satisfied if the range is clearly disclosed in the published job advertisement. Prior to contract signing, employers must also inform candidates of applicable collective agreement provisions.

• Salary history ban: Employers are strictly prohibited from inquiring about a candidate's current or historical compensation, whether directly during interviews or indirectly through third-party recruitment agencies.

Requirements effective on December 31, 2026

• Mandatory compliant pay systems: All employers, regardless of headcount, must formally establish or update a written remuneration system by December 31, 2026. This architecture must classify positions into groups based entirely on objective, gender-neutral criteria, including qualifications, hard and soft skills (such as interpersonal abilities), effort (physical, mental, and emotional resources), responsibility, and specific working conditions (environment, risk, and intensity).

This is an note/information message.

The obligation to formally document and disclose criteria for pay progression (e.g., performance-based raises) is restricted to employers with 50 or more employees.

Requirements effective on January 1, 2027

• Individual right to information (RTI): Employees gain the formal right to request and receive in writing detailed data regarding their individual annual pay, average monthly hourly pay, and average annual hourly pay, as well as the corresponding averages by gender for workers in the same position group. Employers must fulfill these requests within a strict one-month window.

• Monthly data submissions: Beginning January 1, 2027, all employers must submit expanded monthly payroll data directly to the State Social Insurance Fund Board (SoDRA). This submission must detail employee gross fixed wages, variable wages (such as performance bonuses), working hours, schedules, and designated job classification groups.

Mandatory reporting & public disclosure deadlines

Unlike most EU Member States, employers in Lithuania do not self-report macro pay gaps manually. Instead, SoDRA automatically calculates and publishes the indicators directly from the monthly payroll submissions. The phased roll-out for these calculated indicators follows employer size:

• Employers with 250+ employees: The initial annual indicators will be calculated and distributed by March 1, 2028 (data on indicators 1–6 made public for the first time by April 1, 2028)

• Employers with 150–249 employees: The initial triennial indicators will be calculated and distributed by March 1, 2028 (data on indicators 1–6 made public for the first time by April 1, 2028)

• Employers with 100–149 employees: The initial triennial indicators will be calculated and distributed by March 1, 2031 (data on indicators 1–6 made public for the first time by April 1, 2031)

• Public micro-tracking (8+ employees): For any employer with at least eight employees (where there are at least three of each gender), SoDRA will publicly disclose the average monthly hourly pay for men and women on an ongoing, monthly basis.

Exception regarding employees with temporary employment contracts:

• Employers with 100 to 249 employees shall calculate the data on the indicators (1-7) of the previous calendar year of the employees with a temporary employment contract themselves and submit them to the State Social Insurance Fund Board every three years, and

• Every year, employers with 250 employees or more must submit data on the indicators of the previous calendar year to the State Social Insurance Fund Board and to the representatives and employees if there are more than two employees of the respective sex in the group of positions.

Data on the indicators must be shared with employees and employees’ representatives, provided that there are more than two employees of the respective sex in the group of positions.

If the data reveals an unjustified gender pay gap of 5% or more in any position group, employers have a six-month window from the moment they are notified of or identify the gap to remedy it. Failure to correct an unjustified gap triggers a mandatory Joint Pay Assessment alongside worker representatives.

Alignment and deviations from the EUPTD

While Law No. XV-969 adheres closely to the core objectives of Directive (EU) 2023/970, the Lithuanian framework features distinct local mechanisms designed to maximize public accountability and automate compliance.

Strategic alignments

• The 5% threshold: The trigger initiating a Joint Pay Assessment and its accompanying six-month remediation window aligns exactly with the EU Directive's 5% variance framework.

• Candidate protections: The structural bans on salary history tracking and mandates for upfront pay ranges match the European baseline standard.

Local deviations & specificities

• SoDRA-driven automation: Employers in Lithuania are spared from manually drafting macro annual compliance reports, except for employees with temporary employment contracts. Instead, SoDRA acts as the centralized calculating engine, using monthly mandatory payroll and job-group inputs to determine and publish the official indicators.

• Accelerated RTI window: Under the Lithuanian Labor Code, employers have only one month to respond to individual employee pay information requests, cutting the standard two-month EU allowance in half.

• Universal pay system mandate: While previous Lithuanian law required formal remuneration policies only for companies with 20+ workers, the new transposition extends the mandatory gender-neutral pay architecture requirement to every single employer operating in the country by December 31, 2026.

• Aggressive public tracking for small firms: Lithuania exposes smaller businesses to high external transparency. Any company with eight or more employees (and at least three of each gender) will have its baseline gender pay gap open to public tracking on SoDRA's platform every single month.

• Salary disclosure rights: Employment contracts can no longer contain pay confidentiality clauses. Employees are explicitly permitted to share and discuss their own salary details to defend their right to equal pay.

• Small business progression exemption: Lithuania leveraged the available EU exemption to completely excuse companies with fewer than 50 employees from the obligation to document and share pay progression criteria.

Managing the response pipeline – small groups

Lithuania has enacted strict privacy guardrails for small sample sizes.

If providing peer-average pay data within a small or unique position category could directly or indirectly reveal the exact salary of an identifiable colleague, direct delivery to the employee is legally prohibited. In these cases, the data must be routed securely through employee representatives, the State Labor Inspectorate, or the Office of the Equal Opportunities Ombudsperson to evaluate compliance confidentially.

HR teams should utilize their internal portals primarily to share the objective, gender-neutral remuneration policies and job-evaluation frameworks required by the December 31, 2026 deadline, while processing actual employee pay data requests reactively and securely.

Meeting the requirements with PayAnalytics

beqom’s PayAnalytics solution is designed to automate your data auditing well ahead of Lithuania's two-track deadlines, protecting your organization before payroll information becomes visible to SoDRA. The general EUPTD guidelines form the foundation, which can be fine-tuned to meet the specificities for Lithuania. We recommend starting with Getting ready for the EUPTD with PayAnalytics.

1. Data preparation and configuration: Your employee dataset must contain the exact fields required to match the incoming SoDRA submission requirements. The PayAnalytics platform supports the configuration and mapping of your position groups based on the mandatory Lithuanian evaluation criteria, alongside your core compensation elements.

   To set up your data correctly, follow the steps in Preparing your data for the EUPTD.

2. Employee pay transparency reports: The built-in employee pay transparency report helps HR teams communicate to each employee how their pay compares to their specific Category of Worker group. Because Lithuania applies a compressed one-month timeline for individual responses starting January 1, 2027, having these reports configured and ready to pull on demand ensures compliance without manual administrative delays.

   Step-by-step guidance is available in the Employee pay transparency report and Pay explainability report Help Center articles.

3. Privacy risk auditing (small group security): To prevent data privacy violations under the Lithuanian disclosure rules, you can rely on the PayAnalytics small group compliance threshold, which by default is set to five employees by gender group. In case the group threshold is not met, the employee pay transparency report displays "-" instead of the worker category average, to avoid data privacy violations. For these employees, the disclosure needs to be routed through employer's relevant employee representatives. You can use the Compensation by category table in the PayAnalyticsWorkforce Analytics report to view aggregated, gender-disaggregated average compensation tables by role category. By selecting the Category of Worker as role and the relevant compensation element, the table provides the required data to share with your employee representatives.

   The Workforce analytics article offers more insights.

4. Proactive 5% gap auditing: Because SoDRA will automatically calculate and publicly publish your internal gender pay gaps starting in 2027, running a statistical audit early is critical. PayAnalytics identifies any job cluster approaching or exceeding the 5% adjusted gender pay gap threshold long before SoDRA pulls the data, saving your firm from a mandatory public remediation process.

   See Measuring & closing pay gaps by group in the Help Center for details.

5. Targeted compensation remediation: If an unexplainable gap is caught during your pre-reporting audit, the platform calculates objective, cost-effective adjustments. This allows your team to execute salary modifications and re-balance position groups within the legal six-month remediation window.

   For more information, refer to the Getting suggested remediation actions and Advanced settings for remediation actions Help Center articles.

6. Pre-employment pay ranges: PayAnalyticsCompensation Assistant is designed to help your hiring teams and people managers make decisions that align with both the main compensation drivers in your organization, and the individual’s characteristics at the time of hiring, promotion, transfer, or reemployment. It is essential to ensure equitable compensation decisions as your workforce evolves. While not designed specifically for the EUPTD pre-employment pay ranges, the tool can help generate equitable, data-backed salary ranges based on objective criteria, for use in Lithuanian job advertisements.

   You can find a full walkthrough in Using the Compensation assistant.

This is an attention message.

This article is for informational purposes only and does not constitute formal legal, financial, or compliance advice.

The transposition of the EUPTD into Lithuanian local law is an actively evolving regulatory process. National legislation, administrative guidelines, and court interpretations may change frequently. While we strive to provide accurate, high-quality insights and intend to update this article periodically to reflect major changes, regulatory frameworks move fast, and we cannot guarantee that all information remains valid.

Our solution is designed to help organizations streamline and manage their compliance workflows based on current directive standards. However, because individual corporate structures and local enforcement nuances vary, we strongly recommend consulting with a qualified legal counsel or compliance specialist to ensure your specific implementation aligns fully with the latest Lithuanian statutory requirements.