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Lithuania – Current Laws and EU Pay Transparency Directive Transposition
With an eye to the 2026 deadline, Lithuania has drafted legislation that would partially transpose the EU Pay Transparency Directive into national law. The draft legislation was published on May 20th, 2025, which coincidentally was International HR Day.
Lithuania starts from an interesting position because it already has laws that meet some of the Directive’s requirements. The draft legislation amends the country’s Labour Code and Administrative Code.
In this article we’ll discuss both Lithuania’s existing pay transparency legislation, its current pay equity measures, and the legislation proposed to comply with the EU Directive.
Pay transparency laws in Lithuania
In 2019, Lithuania incorporated two pay transparency provisions into its Labour Code. First, pay information must be included in all job postings. (Specifically, listings must include a range or fixed amount of the salary or hourly rate for the position.) Second, employers cannot ask job applicants or current employees about their salary history.
Pay equity laws in Lithuania
The Labour Code also includes measures to support pay equity. First, employers with 20 or more employees must establish a formal pay system. Such a system must aim to deliver equal pay for equal work, and it also needs to stipulate pay ranges and establish variable pay principles and pay indexing procedures. This system is created with the active participation of employee representatives.
Companies of this size also need to measure their pay gap. Pay gap information should be reported to the works council or applicable trade union. Employers must provide:
- For each employee job group with more than two employees, average pay by group and gender.
- Any additional information required by the works council or applicable employee trade union.
In addition, if the gender pay gap is over 5%, the employer must take action to close it, covering one of the key requirements of the EU Pay Transparency Directive.
Lithuania has a fairly unique system for publicizing pay gap data. Based on data already available to the government, the State Social Insurance System (SoDRA) compiles and publishes information annually, including the average pay for women and for men at each company. Employers do not need to take any steps to report or provide data.
Draft legislation to transpose the EU Pay Transparency Directive
In the proposed legislation, lawmakers retained or modified many existing pay transparency and pay equity provisions in the Labour Code and added new measures to increase compliance with the Directive.
Pay transparency in the draft legislation
The draft law retains the current Labour Code provisions requiring pay information in all job postings and prohibiting employers from asking about salary history.
The draft law adds the following new provisions:
- On request, employers are obligated to provide employees with a written comparison of their pay to the average pay by gender for workers in comparable roles.
- If discrepancies are identified, employers must explain them and correct them in six months.
- Employees shall provide annual notification of these rights to information.
- Employees are allowed to discuss their pay.
Pay equity in the draft legislation
The draft law retains the current Labour Code provision requiring employers to have a formal pay system. However, it removes the size criterion (20+ employees) so the provision applies to all employers.
The draft law adds the following new provisions:
- It stipulates that the pay system needs to have work categories based on gender-neutral criteria, including skills (not omitting social-emotional skills), effort, responsibility and working conditions, and other applicable factors.
- It requires companies to have specific salary increase procedures (though this is optional for companies with 50 or more employees).
- It sets fines for non-compliance or non-reporting of pay information: €400 euro for an initial fine, with a maximum of €6.000.
Lithuania’s draft legislation goes a long way towards meeting all the requirements of the EU Directive. It leaves two of the Directive’s requirements—for reporting and for joint assessment—to be addressed separately at a later date. Keep an eye on our transposition tracker for updates on legislation in Lithuania and throughout the EU.
Overall, Lithuania’s approach to implementing the Directive stays close to the legislation’s basic requirements, building on a substantial body of existing law in order to do so. Lawmakers are planning to discuss the draft legislation with groups representing employers and employees. Changes may be made, but the draft law does have a scheduled implementation date of June 7th, 2026.
Further support with PayAnalytics by beqom
Current Lithuanian law requires even fairly small employers to have a clear pay structure that ensures equal pay for work, measure their pay gaps, and close any gaps larger than 5%. As the EU Directive comes into effect, these requirements will expand to affect more employers. Our pay equity analysis function gives organizations of any size the insights they need to create these clear pay structures and measure and close any pay gaps.
Under the EU Pay Transparency Directive, it’s essential not only to close the pay gap below the 5% threshold, but to keep it that way year over year. Our Compensation Assistant feature provides ongoing decision support that shows you what any potential pay decision, whether for a current employee or a new hire, would do to your pay gap.
With the draft legislation set to take effect in less than a year, this is a great time to get the tools you need. We recommend taking a look at our recently updated guide to the EU Pay Transparency Directive.
And to find out how we might help your organization prepare, please contact us to book a demo anytime.
