Lithuania
Amendments to the Law on the Legal Status of Aliens
Impact date: The majority of provisions enter into force on 22 May 2026. Certain provisions (relating to e-residency, data systems, and biometric data) enter into force on 1 November 2026 and 1 January 2027. Implementing legislation must be adopted by the respective deadlines.
Lithuania adopted amendments on the law on the Legal Status of Aliens, overhauling rules on foreigners residence and work permits.
Key changes include:
- “stricter employer liability” subsection: one‑year refusals on new/changed permits and potential revocation of existing permits counted from the date the administrative decision becomes final; clarified that these consequences are not expected to apply retroactively to pre‑effective cases
- elevated wage‑parity to an essential condition: pay must match comparable Lithuanian/EU employees or, absent comparators, meet Statistics Lithuania’s latest average for the relevant activity; non‑compliance can lead to denial/revocation
- clarified student work limits: 40 hours/week only in years three–four or during holidays; 20 hours/week cap for years one–two with limited exceptions
- added right‑to‑remain pending decision and procedure to change employer with timely notice
- introduced in‑country filing limits effective 1 November 2026, with many applicants needing to apply via VFS Global abroad
- streamlined employer actions and refreshed the risk statement to reflect the one‑year consequences
Employer implications/action needed Verify wage parity, document qualifications/full‑time work, monitor student hours, file employer‑change notices on time, and plan for out‑of‑country filings where required.
Employer risk Employers with recent illegal/undeclared work penalties may be barred from sponsoring for six–12 months; convictions for employing illegally present third‑country nationals within five years disqualify sponsorship.
Implementation of the EU Pay Transparency Directive
Impact date: Most provisions from 7 June 2026; enhanced reporting obligations from 1 January 2027; first pay‑gap data due by 1 March 2028 (150+ employees) and 1 March 2031 (100–149 employees); public publication by 1 April 2028 and 1 April 2031, respectively.
Lithuania has adopted pay transparency reforms, implementing the EU Pay Transparency directive (EU) 2023/970, requiring formal, gender‑neutral remuneration systems with objective job classifications, banning salary‑history questions, limiting pay‑confidentiality clauses (employees may disclose their own pay to enforce equal pay), granting employees the right to written pay information (including average pay by gender within the same job category with annual notice of this right), mandating gender pay gap reporting for employers with 100+ employees (annual for 250+, every three years for 100–249), triggering joint pay assessments where an unjustified ≥5% gap persists, strengthening equal‑pay enforcement (late/improper payment penalties apply mutatis mutandis and courts may award make‑whole compensation), adjusting litigation‑cost rules, and clarifying return‑from‑leave pay/position protections.
Employer implications/action needed
Establish or update gender‑neutral pay systems with objective job‑group criteria; cease requesting salary history; revise confidentiality terms; prepare to provide individual and average pay data on request; build reporting processes/classifications for 100+ workforces; and set procedures to investigate and rectify any ≥5% unjustified gaps within six months.
Employer risk Non‑compliance may lead to employee claims, administrative liability, and pay‑related penalties applied by analogy; unresolved gaps can trigger mandatory joint assessments and increased litigation exposure.
Amendments to the Law on the Fundamentals of Protection of the Rights of Persons with Disabilities
Impact date: 1 July 2026
Amendments to the Lithuanian Law on the Fundamentals of Protection of the Rights of Persons with Disabilities have been adopted. The Law was updated to expand Article 10, introducing a recommendation for private-sector employers with 25 or more employees to meet a certain criterion – namely, that employees with disabilities should make up at least 5% of the total workforce.
Employer implications/action needed
As it is only a recommendation, private-sector employers are free to decide whether to follow it. Employers may review their diversity and inclusion policies.
Employer risk There is no direct legal or administrative risk, as the requirement is non-binding.
Partial Work Benefits Regulations
Impact date: 1 July 2026
The Minister of Social Security and Labour has approved the Partial Work Benefits Regulations, establishing the procedure for calculating, granting, paying, suspending, resuming, and terminating partial work benefits. The benefit consists of a fixed part (equal to the basic social benefit amount) and a variable part (45% of the insured person's average monthly insurable income), proportionally adjusted based on reduced working time.
Employer implications/action needed
Employers must familiarize themselves with the application procedure for partial work benefits, ensure they can provide the required financial documentation (quarterly financial statements, evidence of reduced turnover), and note the obligation to adopt a decision on partial work establishment within two working days of receiving the Fund's approval.
Employer risk Financial and administrative risk, as applications will not be processed if required documents are not submitted within prescribed deadlines or are incomplete. Overpaid benefit amounts are recoverable, and benefits are terminated if insolvency proceedings are initiated.
Proposed amendments to the Equal Opportunities Law
Impact date: Not yet adopted; if adopted, the amendments will enter into force on 19 June 2026
A draft new Equal Opportunities Law would replace the current law and broaden protected grounds significantly (including age, ethnic origin, language, origin, gender identity and expression or other gender characteristics, disability, skin color, views, citizenship, race, religion/belief, sexual orientation, social status, nationality, and faith). It also defines new forms of discrimination, including multiple, intersectional, and discrimination by association.
Employer implications/action needed
Update equal‑opportunities policies to reflect expanded grounds/definitions; ensure equal selection criteria, working conditions, and equal pay for equal/equivalent work; prevent harassment/sexual harassment; provide reasonable accommodation for employees with disabilities; protect against discrimination related to pregnancy, maternity, paternity, and parental leave; and implement anti‑retaliation measures for reporters.
Employer risk Non‑compliance constitutes an equal‑opportunities violation and may result in administrative offence proceedings by the Equal Opportunities Ombudsperson.
Proposed amendments to the Lithuanian Labour Code
Impact date: Not yet adopted; if adopted, the amendments will enter into force on 1 November 2026.
A draft amendment to the Lithuanian Labour Code has been registered, proposing updates across several areas, including:
- allowing a probationary period of up to six months for employees whose monthly salary is at least two times the national average gross wage; for fixed-term employment contracts shorter than 12 months, the probationary period must be proportionate (i.e., shorter than six months)
- setting strict rules for the final wage settlement: the part not exceeding one month’s average wage must be paid no later than on the employment termination date, or, if agreed, within ten business days. The part exceeding one month’s average wage may be paid at another mutually agreed time, but no later than three months from the employment termination date
- Revising default interest for late payments during ongoing employment (due to the employer’s fault): default interest is payable for each delayed calendar day from the due date, with the rate approved annually by the Minister of Social Security and Labour by 1 February, and calculated using the Consumer Price Index (comparing last December with December of the previous year) multiplied by five
Employer implications/action needed
Employers must:
- review and, if necessary, adjust internal policies/template employment contracts to reflect the proposed changes (e.g., remuneration rules, settlement procedures)
- monitor the legislative process, as the draft is not yet adopted and further modifications may occur
Employer risk Failure to apply may result in employee claims and/or administrative liability for the employer.
Contact
© Eversheds Sutherland. All rights reserved. Eversheds Sutherland is a global provider of legal and other services operating through various separate and distinct legal entities. Eversheds Sutherland is the name and brand under which the members of Eversheds Sutherland Limited (Eversheds Sutherland (International) LLP and Eversheds Sutherland (US) LLP) and their respective controlled, managed and affiliated firms and the members of Eversheds Sutherland (Europe) Limited (each an "Eversheds Sutherland Entity" and together the "Eversheds Sutherland Entities") provide legal or other services to clients around the world. Eversheds Sutherland Entities are constituted and regulated in accordance with relevant local regulatory and legal requirements and operate in accordance with their locally registered names. The use of the name Eversheds Sutherland, is for description purposes only and does not imply that the Eversheds Sutherland Entities are in a partnership or are part of a global LLP. The responsibility for the provision of services to the client is defined in the terms of engagement between the instructed firm and the client.