Lithuania
Amendments regarding calculation of average wage, duration of annual leave, working and rest time
Impact date: 30 October 2025 (provisions regarding calculation of annual leave enter into force on 1 January 2026) Government Resolution “On the Implementation of the Labor Code of the Republic of Lithuania” has been amended. The amendments cover updates to the procedure for calculating the average wage, the list and duration of extended annual leave for certain employee categories, and specific rules on working time and rest time in various economic sectors.
Employer implications/action needed Employers must:
- Review and, if necessary, adjust internal payroll policies to align with the revised average wage calculation procedure
- Verify employee categories entitled to extended annual leave and update internal HR documentation accordingly
- Ensure compliance with new working time and rest time provisions applicable to relevant economic sectors
- Communicate the updated rules to HR and payroll personnel responsible for employment administration
Employer risk
- Failure to apply the correct wage calculation methodology may result in overpayment or underpayment claims
- Misapplication of leave entitlements may lead to employee complaints and potential labor dispute
- Non-compliance with sector-specific working time provisions could trigger inspections by the State Labor Inspectorate and administrative penalties
Minimum wage for 2026 approved
Impact date: 1 January 2026
The Lithuanian Government has determined an increase to the gross monthly wage to €1,153 and the gross minimum hourly pay rate to €7.05.
Employer implications/action needed All employers must adhere to the minimum wage requirements when paying salary.
Employer risk If the employer remunerates for work at a rate below the minimum monthly wage/minimum hourly pay, the State Labor Inspectorate may impose an administrative fine between €240 and €880 (a repeated breach would be punished with a fine between €900 and €1,400). The employer would also be liable to pay the difference to the employee.
State language requirements for sellers of goods and services
Impact date: 1 January 2026
Legal and natural persons selling goods or providing services in Lithuania must ensure direct customer service in Lithuanian language at a level defined by the Lithuanian Government (some exemptions apply). This requirement will affect businesses with customer-facing roles, making Lithuanian language proficiency one of the criteria in the recruitment process.
Employer implications/action needed
Employers must assess whether employees who have direct contact with customers meet the required Lithuanian language proficiency level and plan for language training or recruitment of staff who meet the requirement.
Employer risk Non-compliance could lead to relatively small administrative fines (up to €300).
Proposed amendments to transpose the EU Pay Transparency Directive
Impact date: Not yet adopted; likely implementation by June 2026, aligning with the Directive’s transposition deadline.
A draft amendment to the Lithuanian Labor Code has been registered to transpose the EU Pay Transparency Directive into national law. The proposed changes mainly reflect the requirements of the Directive (e.g., enhanced pay gap reporting obligations, requirements for all employers to establish formal, gender neutral remuneration systems etc.).
Employer implications/action needed
Employers must:
- Familiarize themselves with the EU Pay Transparency Directive and its requirements, as well as the proposed implementation into Lithuanian law
- Monitor legislative progress in Lithuania, as the draft wording is not final and may change
- Plan ahead for compliance by reviewing current pay structures and identifying gaps early
- Prepare to update/adopt internal policies (e.g., remuneration systems, recruitment practices) once the law is adopted
Employer risk Failure to comply with the new proposed requirements could lead to disputes with employees and administrative fines. For example, failure to provide pay information to employees, their representatives or the State Labor Inspectorate could result in fines between €460 and €700 (a repeated breach could lead to fines between €700 and €1,400). These penalties may change as the transposition of the Directive is not yet finalized.
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