EU Pay Transparency Directive in Lithuania: What's Live, and What's Still Coming

Lithuania's Parliament, the Seimas, adopted Law No. XV-969 on May 21, 2026, transposing the EU Pay Transparency Directive into national law. Most of its provisions took effect on June 7, 2026, the same date the Directive itself set as the deadline for all 27 member states.

What makes Lithuania's approach worth a closer look isn't the timing. It's two design choices that set it apart from other early transposing states: there's no size exemption, so every employer is in scope regardless of headcount, and the actual gender pay gap calculation doesn't sit with the employer at all. It sits with a state institution.

What Law No. XV-969 actually is

Lithuania wasn't starting from zero. Salary ranges in job postings and a ban on salary history questions have both been required since 2019, well before this law. Employers with 20 or more employees were also already required to share gender-disaggregated pay data with works councils or trade unions annually, and to remediate any gap over 5% within six months.

What the new law adds is a formal, documented remuneration system, a specific job classification requirement, and a national data submission process. Most provisions took effect June 7, 2026, but Lithuania phased in the more demanding pieces. Employers have until December 31, 2026 to align their compensation systems with the new objective, gender-neutral pay criteria requirements. Reporting and data-submission obligations, along with the formal right-to-information process, don't take effect until January 1, 2027.

The obligation with no size exemption

This is the detail most likely to catch a mid-sized or smaller employer off guard. The Directive itself allows member states to phase in reporting by company size, and every other country covered in this series uses some version of a headcount threshold. Lithuania doesn't, at least not for the baseline obligation.

Every employer, regardless of how many people they employ, has to classify job positions into defined, gender-neutral categories and submit monthly pay data. A company that's used to treating pay transparency reporting as something that only applies once it crosses a certain size will find that assumption doesn't hold in Lithuania. The job classification work itself, defining categories, applying them consistently, and being able to explain the logic behind them, is the same regardless of company size. It's just that in Lithuania, there's no floor below which that work becomes optional.

Why Lithuania put a state institution in charge of the math

Under the Directive as written, and under every other transposing country's law covered in this series so far, employers calculate their own gender pay gap indicators and report the results. Lithuania does something different.

Employers submit raw monthly data, pay, working hours, and job category, to the State Social Insurance Fund Board, known as SoDRA. SoDRA then calculates a defined set of indicators itself: the overall gender pay gap, the median gap, a version of the gap that includes supplementary pay like bonuses, the share of men and women receiving supplementary pay, the distribution of men and women across pay quartiles, and the gap broken down by position group into basic and supplementary pay. SoDRA distributes those results to the employer, to worker representatives, to the State Labour Inspectorate, and to the Office of the Equal Opportunities Ombudsperson.

There's a public dimension too. SoDRA publishes average hourly pay by gender for any employer with at least 8 employees, as long as each gender has at least 4 people represented in that headcount. That's a level of public disclosure the Directive doesn't itself require, and it means the numbers aren't just an internal compliance artifact. They're visible.

The practical effect is that Lithuania has shifted a meaningful share of the calculation burden away from employers and onto a state institution. That's a genuine reduction in analytical work, but it comes with a new operational requirement in its place: monthly data submission has to be accurate and on time, since the employer no longer controls how the final numbers get produced.

What's coming in 2027

Reporting obligations phase in starting January 1, 2027:

Starting January 1, 2027, employers must submit monthly data to SoDRA showing employee pay, working hours, and job categories. SoDRA will analyze this data to calculate gender pay gaps within each organization.

Organizations with 100 or more employees will be required to report periodically on gender pay gaps by entity and by category of worker:

• Employers with 100 to 249 employees report every three years.
• Employers with 250 or more employees report annually.

Category of Worker Pay Gaps

What SoDRA does: Uses employer-provided data (pay, working time, job category) to calculate gender pay gaps for specific job groups.

Timeline:

• March 1, 2028 - SoDRA provides calculated data to employers with 150+ employees
• March 1, 2031 - SoDRA provides calculated data to employers with 100–149 employees. Employers then report this data internally.

Entity Pay Gaps

What SoDRA does: Calculates and publicly publishes overall gender pay gaps across the entity.

Timeline:

• April 1, 2028 - First published reporting for entities with 150+ employees
• April 1, 2031 - First published reporting for entities with 100–149 employees

Key Takeaway

SoDRA is the data processor for both metrics. Employers with 150+ employees face earlier deadlines (2028) than those with 100–149 employees (2031). The entity-wide gap is public; job-category gaps go to employers first.

Enforcement

Administrative fines for pay transparency or reporting violations range from €400 to €6,000 per violation, applied against the company. These aren't one-time penalties: fines can be applied repeatedly for persistent non-compliance, so an unresolved gap doesn't just cost once.

Enforcement bodies have a more direct line into the data than a complaints-only model would provide. Both the State Labour Inspectorate and the Office of the Equal Opportunities Ombudsperson receive the same data SoDRA calculates, which means gaps can surface to regulators without an employee having to file a complaint first. Employees retain their own path too, through the courts, and the Ombudsperson's office also receives and investigates complaints directly.

Getting ahead of it

Three things are worth starting now rather than waiting for the January 2027 deadlines to arrive.

Build the job classification system first, since it's the foundation everything else depends on, and remember it applies no matter how small your Lithuanian workforce is. Get the monthly SoDRA data submission process tested well before it becomes mandatory, since accuracy in that pipeline now determines the numbers a state institution calculates on your behalf later. And align compensation criteria documentation with the objective, gender-neutral standard before the December 31, 2026 deadline, rather than treating that date as distant.

Stay ahead of the next update, in Lithuania and everywhere else

Lithuania's model is a reminder that pay transparency compliance isn't just a policy question. It's a data pipeline question, and in Lithuania's case, a payroll data pipeline specifically. Deel Payroll keeps the monthly pay, working time, and job category data that SoDRA requires connected to the same system that runs the rest of compensation, and Deel HR keeps job classifications documented and consistent, whether your Lithuanian headcount is 5 or 500.

Book a demo to see how Deel helps you manage pay transparency obligations that don't wait for a headcount threshold to kick in.

This content is for informational purposes only and does not constitute legal advice. Compensation laws and regulations change frequently, and this article notes specific sections requiring legal confirmation before publication. Businesses should consult qualified legal counsel for jurisdiction-specific guidance.