Skip to content Lithuania is positioning itself among the most advanced EU Member States in implementing the EU Pay Transparency Directive (Directive 2023/970/EU). In March 2026, the Lithuanian government approved draft amendments to the Labour Code aimed at aligning national law with the Directive before the EU deadline of June 7, 2026. The proposal is now awaiting final approval by the Lithuanian Parliament (Seimas).
Recruitment Transparency and Salary Disclosure
One of the key elements of the Lithuanian reform concerns hiring practices. Under the amended Labour Code, employers cannot ask candidates about compensation received in current or previous employment relationships. Employers must also provide information regarding collective agreements applicable to the position before employment negotiations begin.
The legislation also strengthens employees’ rights to discuss and disclose their pay. Confidentiality clauses or internal policies cannot restrict workers from sharing salary information when exercising their equal pay rights. This reflects the Directive’s broader objective of increasing openness around compensation structures.
Gender-Neutral Pay Structures
A major innovation in the Lithuanian proposal is the requirement for employers to implement formal gender-neutral pay systems. Job positions must be evaluated according to objective criteria such as skills, qualifications, responsibility, effort, and working conditions.
The amendments also provide formal definitions of “same work” and “work of equal value,” two central concepts under the Directive. Lithuanian law would also allow comparisons across subsidiaries with centrally determined pay. In some cases, statistical evidence or hypothetical comparators may also be used to support discrimination claims.
Pay Gap Reporting and SoDRA’s Role
One of the most distinctive aspects of Lithuania’s approach is the role assigned to SoDRA, the national social insurance authority. Employers will submit payroll and working-time data, while SoDRA will calculate the gender pay gap indicators required under the Directive and publish them publicly. This centralized system could significantly reduce the administrative burden for employers.
The reporting obligations will follow a phased timeline. Employers with at least 150 employees must begin reporting by May 2027, while companies with 100–149 employees will follow in 2031. If an unjustified gender pay gap of 5% or more is not corrected within six months, employers must carry out a joint pay assessment with employee representatives.
Enforcement and Penalties
In other words, Lithuania has adopted a strong and forward-looking approach to pay transparency, introducing a centralised reporting system and setting clear expectations for employers to ensure that salary structures are transparent, fair and gender neutral.
The proposed legislation also introduces administrative penalties for non-compliance. According to the current draft, employers that fail to comply with pay transparency or reporting obligations may face fines starting from €400, with penalties reaching up to €6,000 for repeated or serious violations.
Employees affected by pay discrimination will also have the right to seek compensation, including unpaid wages, lost career opportunities, and damages for non-material harm. In discrimination proceedings, the burden of proof will shift to employers, who must demonstrate that pay differences are based on objective, non-discriminatory and gender-neutral criteria.