Pay Transparency Directive: Key Changes Taking Effect from 1 January 2027
By: Inesa Greičė
10 Nov 2026 5 min read
New pay transparency requirements take effect on 1 January 2027
We would like to inform you that amendments to the Labour Code of the Republic of Lithuania related to pay transparency will take effect on 1 January 2027. The amendments were adopted by Law No. XV-969 of 21 May 2026 to implement Directive (EU) 2023/970.
The amendments will introduce new requirements for employers:
- prepare or update their remuneration system by 31 December 2026;
- classify positions into job categories using objective, gender-neutral criteria;
- submit additional pay data to Sodra every month from 1 January 2027;
- ensure employees’ right to receive information about their own pay and comparative pay indicators;
- take action to address any gender pay gap that cannot be justified by objective, gender-neutral criteria.
Remuneration systems will be mandatory for all employers
By 31 December 2026, all employers, regardless of company size, must prepare a clear and objective remuneration system or review and, where necessary, update their existing system. If the remuneration system is not established in a collective agreement, the required information and consultation procedures must be completed before the system is approved or amended. Once approved, the remuneration system must be accessible to all employees.
The remuneration system must set out pay conditions by job category or position, based on objective, gender-neutral criteria. It must specify the forms of remuneration, pay levels or ranges (minimum and maximum), the grounds, amounts and procedures for granting allowances, additional payments and bonuses, as well as the criteria and procedures for pay indexation and increases. Employers with fewer than 50 employees will not be required to establish criteria and procedures for pay increases.
By 31 December 2026, all positions within the company must also be classified into job categories. Positions must be grouped based on objective, gender-neutral criteria, such as skills, qualifications, effort, responsibility and working conditions. Positions involving the same work or work of equal value must be assigned to the same job category.
Data submission to Sodra
From 1 January 2027, all employers will be required to submit monthly data to Sodra on each employee’s gross pay, additional pay and paid working hours. The data will be submitted using the SDUP form.
When submitting the first report, employers will also need to provide the employee’s contractual working hours, working time arrangement, and assigned job category number under the company’s remuneration system. This information will only need to be updated if it changes.
No data will need to be submitted to Sodra for employees working under temporary agency work contracts.
The first report must be submitted to Sodra by 28 February 2027. Thereafter, data for the previous month must be submitted by the last day of the current month.
Pay indicators calculated by Sodra
Based on the data submitted by employers, Sodra will calculate each employee’s average monthly hourly pay, as well as the average pay of women and men by job category. Once a year, Sodra will also calculate annual indicators, including each employee’s average annual hourly pay and the average annual pay of women and men by job category. This information will be available to employers through their personal Sodra accounts.
Some pay data will be made publicly available. If an employer has at least eight employees, including more than three men and more than three women, the average hourly pay of women and men will be published and updated monthly.
Sodra will also calculate gender pay gap indicators, including the overall pay gap, differences in additional and median pay, the proportion of women and men receiving additional remuneration, and their distribution across pay quartiles. Pay gaps will also be assessed by job category, with basic and additional pay considered separately.
How often the indicators will be provided will depend on the employer’s size:
- employers with 250 or more employees will receive the indicators annually;
- employers with 100–249 employees will receive the indicators every three years;
- employers with fewer than 100 employees will be able to request the indicators on their own initiative.
The indicators will be provided for the first time:
- by 1 March 2028 for employers with 150 or more employees;
- by 1 March 2031 for employers with 100–149 employees.
Within one month of receiving the indicators, the employer will have to provide employees and their representatives with information on the gender pay gap in basic and additional pay by job category, where the category includes more than two employees of either gender.
Separate rules will apply to temporary work agencies
If a temporary work agency has 100–249 employees, it will have to calculate the pay indicators for temporary agency workers and submit them to Sodra every three years. For agencies with 250 or more employees, the indicators must be calculated and submitted annually.
The information must also be provided to employees and their representatives if the relevant job category includes more than two employees of either gender.
The indicators must be submitted for the first time:
- by 1 March 2028 for agencies with 150 or more employees;
- by 1 March 2031 for agencies with 100–149 employees.
Temporary agency workers will be able to request information on pay indicators and related explanations not only from the temporary work agency but also from the user undertaking.
Employees’ right to receive information
From 1 January 2027, employees will have the right to request information from their employer about their own pay and comparative pay indicators. However, the first monthly indicators will only be available from 15 March 2027. From this date, employees will be able to receive information about their average monthly hourly pay and the average monthly hourly pay of women and men in the same job category. Annual pay indicators will be available from 1 March 2028.
At an employee’s request, the employer must provide this information in writing within one month of receiving the request. If the information is inaccurate or incomplete, the employee may request additional explanations, which must be provided within two months of the initial request.
At the request of the State Labour Inspectorate or the Office of the Equal Opportunities Ombudsperson, the information must be provided within the deadline set by the relevant authority, but no later than 10 working days from receipt of the request.
Actions required when a gender pay gap is identified
If a gender pay gap of at least 5% is identified in a specific job category and cannot be justified by objective, gender-neutral criteria, the employer must take action to address the gap in cooperation with employee representatives. If the gap is not addressed within six months of receiving the indicators, the employer must carry out a joint pay assessment together with the employee representatives.
Employees or their representatives will also have the right to file a complaint with the State Labour Inspectorate. If a dispute arises over whether the gender pay gap has been properly addressed, or if the employer fails to initiate a joint pay assessment, the employee may refer the matter to the Labour
Disputes Commission regarding potential pay discrimination and compensation for any resulting damages.
Legal sources: