Lithuania's pay transparency law: Labour Code amendments (Law XV-969)

The law at a glance

Lithuania implemented Directive (EU) 2023/970 through Law No. XV-969, a package of amendments to the Labour Code (with consequential changes to the Code of Administrative Offences). The Seimas adopted it on 21 May 2026 and it entered into force on 7 June 2026 for most provisions. The administratively demanding parts — job grouping, monthly data submission to Sodra, the right to information and gender pay gap reporting — are deferred to 1 January 2027.

Who is covered

The duty to have a remuneration system based on a gender-neutral pay structure applies to all employers, regardless of headcount (removing Lithuania's previous 20-employee threshold for a formal remuneration system). The duty to publish pay-progression criteria applies to employers with 50 or more employees. The new gender pay gap indicator reporting applies to employers with 100 or more employees, phased by size. A pre-existing internal disclosure duty (annual anonymised average pay by occupational group and gender to the works council or trade union) continues to apply to employers with 20 or more employees.

What employers must do (from 7 June 2026)

• Show pay in job adverts. Employers must disclose the amount or range of basic pay in the job notice. (Lithuania has required salary ranges in job ads since 2019.)
• Stop asking about pay history. Employers may not ask candidates about their current or previous pay.
• Disclose collective-agreement terms. Where pay is set by a collective agreement, the applicable provisions must be disclosed to applicants before the contract is concluded.
• Use objective, gender-neutral criteria for job evaluation and pay structures.
• Tell employees about their rights at least once a year.

The right to pay information (from 1 January 2027)

From 1 January 2027, employees can request, in writing, their own annual salary and monthly and annual average hourly wage, and the average wage of their worker category broken down by sex. Lithuania sets a one-month response window — shorter than the directive's two-month default — with up to two months for further explanations where data is inaccurate or incomplete, and 10 working days where the request comes via the Labour Inspectorate or the Equal Opportunities Ombudsperson.

Gender pay gap reporting via Sodra

Lithuania's distinctive feature is a centralised, government-calculated model. From 1 January 2027, all employers submit monthly pay, working-time and job-category data to Sodra (the State Social Insurance Fund Board), which calculates the gender pay gap indicators and publishes or returns them. The indicators include the overall and median pay gaps (with and without variable pay), the proportion of each sex receiving variable pay, the proportion of each sex in each pay quartile, and the gap by job category.

The 5% rule and joint pay assessment

If Sodra's data show a gap of 5% or more between men's and women's pay in any worker category that is not justified by objective, gender-neutral criteria, the employer must rectify it within six months in consultation with employee representatives. A joint pay assessment is required where all three conditions are met — a gap of at least 5% in a category, no objective justification, and no correction within six months — and the completed assessment must be submitted to employees, their representatives and the State Labour Inspectorate.

Enforcement and penalties

Administrative fines fall on company directors or responsible persons (rather than the company itself): an equal-pay violation is €500–€1,450 (repeat €1,450–€3,000; intentional €2,700–€6,000), and failing to provide required information to employees is €460–€700 (repeat €700–€1,400). The larger exposure is civil: the burden of proof is reversed in discrimination cases, and remedies can include unpaid wages and benefits, material and non-material damages, lost-opportunity compensation and interest on back pay.

Key dates for employers

How to prepare — and how Cleira helps

Because Sodra performs the official calculation, Lithuanian employers do not file the report themselves — but they still need to understand their own position before the state publishes it, get worker categories and data clean ahead of the January 2027 monthly submissions, and be ready to justify or fix any gap at or above 5% within six months.

Cleira lets you do exactly that. You can run a complete, decision-grade gender pay gap analysis free in your browser right now — mean and median gaps on base and variable pay, quartile distribution, bonus participation and automatic per-category 5% flagging — with no login and no data leaving your device, so there are no surprises when Sodra publishes. When you are ready to dig deeper, Professional adds the adjusted analysis and exportable reports, with multi-year tracking.

Cleira lets you do exactly that. From 1 July 2026 you will be able to run a complete, decision-grade gender pay gap analysis free in your browser — mean and median gaps on base and variable pay, quartile distribution, bonus participation and automatic per-category 5% flagging — so there are no surprises when Sodra publishes. Get early access and we'll let you know the moment it's live.

Sources and official documentation

• Official text: Law No. XV-969 (Labour Code amendments) in the Register of Legal Acts (e-tar.lt).
• Sorainen — Implementation of the EU Pay Transparency Directive in Lithuania
• Trusaic — Lithuania pay transparency guide

Other countries with laws already in force: Italy · Slovakia · Malta · EU directive overview