Lithuania
Is there any existing legal requirement to report on any gender pay gap?
There is an existing indirect requirement (see Q2 below).
Under the provisions transposing the EU Pay Transparency Directive (Law No. XV-969, which amends the Lithuanian Labour Code), employers will be required to submit certain employment and pay-related data to the State Social Insurance Fund Board (“Sodra”) from 1 January 2027. The first submission must be made by 28 February 2027 in respect of January 2027 data. Based on the data submitted by employers, Sodra will calculate a number of pay transparency indicators. Monthly indicators will first be provided to employers by 15 March 2027, while annual indicators will first be provided by 15 March 2028. In addition, Sodra must calculate the annual pay transparency reporting indicators (the overall gender pay gap, gender pay gap including additional remuneration, median gender pay gap etc.) and first provide them to employers with 150 or more insured persons by 1 March 2028, and to employers with 100–149 insured persons by 1 March 2031.
If so, what are the requirement triggers?
In their regular information and consultation reports, companies with a minimum of 20 employees must currently inform the works council about salary changes, both those changes which have already occurred and anticipated changes.
Although the law does not currently require companies to report on any gender pay gap, by law the works council is entitled to commence consultation within 5 working days of receipt of the information. During such consultation, the works council may potentially request specific information on any pay gap.
The gender pay gap can also be calculated based on information that can be obtained from a dedicated website of Sodra.
Under the new Law No. XV-969, from 1 January 2027 all employers (regardless of size) will be required to submit pay-related data to Sodra. There is no specific employee-number threshold or other trigger for this obligation – it applies universally. Sodra will then use this data to calculate and provide the relevant pay transparency indicators (see below for detail on what is reported and at what frequency).
What frequency of reporting is required?
The report must currently be provided to the works council annually, by no later than by 1 April of each year.
Under the new Law No. XV-969 and implementing legislation, from 1 January 2027 all employers will be required to submit the following data to Sodra for each of their employees:
- One-off (updated only upon changes): the employee’s agreed working time norm, working time regime and the number of the job group assigned to the employee’s position under the employer’s remuneration system;
- Monthly (by the last day of each month for the preceding month): the employee’s gross remuneration, gross additional remuneration and paid working time (in hours).
Based on these submissions, Sodra will calculate and provide pay transparency indicators to employers, which employers will in turn need to fulfil their own obligations, for example, responding to individual employees' requests for information on average pay levels by gender within their job group, providing data to employee representatives, or rectifying unjustified pay gaps.
Is the report required to be published externally?
Yes, under the new framework, Sodra is required to publicly publish:
- Monthly: the average hourly pay by gender for employers with at least 8 employees (more than 3 women and more than 3 men);
- Annually: the annual pay transparency reporting indicators (overall gender pay gap, gender pay gap including additional remuneration, median gender pay gap, median pay gap including additional remuneration, proportion of men and women receiving additional remuneration, and proportion of men and women in each pay quartile) for employers with 250+ employees;
- Every 3 years: the same indicators (as listed above) for employers with 100–249 employees.
The first publication for employers with 150+ employees is due by 1 April 2028, and for employers with 100–149 employees by 1 April 2031.
Is there a sanction for non-compliance with the duty to report?
Currently, there is no specific sanction for failure to submit remuneration-related data. However, general administrative fines may apply for breaches of labour law obligations (e.g. failure to inform or consult the works council) and for infringements of pay calculation, determination and payment rules under the Lithuanian Administrative Offences Code.
From 1 January 2027, a new specific offence will be introduced (by Law. No. XV-970, amending the Lithuanian Administrative Offences Code) for failure to provide remuneration-related information to employees, employee representatives, the State Labour Inspectorate, Sodra or the Equal Opportunities Ombudsperson as required under the Lithuanian Labour Code. This will carry a fine ranging from EUR 460 to EUR 700 for the employer or other responsible person (EUR 700 to EUR 1,400 for repeated offences).
Has Lithuania yet fully transposed the requirements of the Pay Transparency Directive? If yes, what was the implementation date and what is the name of the legislation?
Yes. On 21 May 2026, the Seimas (Lithuanian Parliament) adopted the transposition legislation (Law No. XV-969), which was then signed by the President and officially published in the Register of Legal Acts on 25 May 2026.
While the majority of the transposition measures entered into force on 7 June 2026, certain provisions will only become applicable from 31 December 2026 and 1 January 2027. These include, in particular, obligations related to job classification and the establishment of compliant remuneration systems, the submission of pay-related data to Sodra, as well as employees’ right to receive information on average pay by gender within their job group. Other provisions, such as the prohibition on requesting pay history during recruitment, entered into force on 7 June 2026.
In addition, the key implementing legislation has now also been adopted. On 17 July 2026, the Minister of Social Security and Labour adopted Order No. A1-433 (“Order”), which establishes the procedure for the collection, calculation, submission and publication of pay transparency data, as well as the procedure for conducting joint pay assessments. The Order entered into force on 31 July 2026.
If the Pay Transparency Directive has not yet been transposed, what steps have been taken towards implementation?
N/A – see above.
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