Implementation of the EU Pay Transparency Directive in Lithuania

Lithuania is taking concrete steps to implement the EU Pay Transparency Directive, which aims to strengthen the principle of equal pay and increase wage transparency in the labour market. The forthcoming legislative amendments will introduce new obligations for employers and expand employees’ rights to information and legal protection.

On January 20, 2026, the Ministry of Social Security and Labor of the Republic of Lithuania registered the updated Articles 23, 26, 39, 40, 41, 42, 48, 51, 52, 65, 71, 79, 131, 140, 147, 148, 197, 217, 219, 226 and the annex of the Labor code of the Republic of Lithuania.

The main objectives of the Directive are:

To ensure equal pay for women and men for the same work or work of equal value
To increase transparency in pay-setting mechanisms and pay levels
To provide effective remedies for employees who have experienced pay discrimination

The Pay Transparency Directive must be transposed into Lithuanian national law by 7 June 2026.

Below is an overview of the proposed substantive amendments based on the above-mentioned draft amendments to the Labour Code.

Transparency requirements in pre-contractual employment relationships

Employers will be prohibited from requesting information from employees about their current or previous employment income.
Prospective employers will also have to provide job applicants with the provisions of the collective agreement that would apply once the employment contract is signed. Such information shall be provided to the job applicant in such a way as to ensure reasonable and transparent negotiations on remuneration.

Remuneration system

All employers, regardless of the number of employees, will be required to have a remuneration system in place.
The remuneration system must be accessible to all employees.
Before approving or changing the remuneration system, information and consultation procedures must be carried out in accordance with the procedure laid down in the Labour Code.
In the remuneration system, the positions at the workplace or in the employer’s company, institution, or organization must be divided into groups according to objective and gender-neutral criteria, the forms of remuneration for each group of positions or position must be established, wage levels or limits (minimum and maximum), additional remuneration (bonuses and allowances), the basis, amounts, and procedure for awarding bonuses, wage indexation, and criteria and procedures for wage increases. However, employers with fewer than 50 employees will be exempt from the obligation to include criteria and procedures for wage increases in the remuneration system.
Positions classified as having the same or equal value work must be assigned to the same job group.
Men and women must be paid the same wages for the same or equivalent work of equal value.

Information about employees’ right to wages

Employees will have the right to receive written information from their employer about:
their pay (annual and hourly), including remuneration in kind,
average pay rates (annual and hourly), including remuneration in kind, by gender in the same job group to which their position belongs.
Employers will have the right to require that employees, having received the specified information, except for information about their own wages, do not use it for any other purpose than to exercise their right to equal pay for equal work or work of equal value.
Employers will be required to inform employees annually of their right to receive this information and of the steps they should take to exercise this right.
It should be noted that data on one’s salary cannot be considered confidential information if the employee discloses such data to ensure their right to equal pay for the same work or work of equal value.

Rights of employee representatives

Employee representatives will have the right to receive relevant information about wages.
Employers will have to provide regular reports on the gender pay gap.

Information on the gender pay gap

Employers will be required to submit data on their employees’ wages, working hours, and job categories as defined in the wage payment system to the State Social Insurance Fund Board monthly via the Electronic Insurer Service System.

The State Social Insurance Fund Board will publish monthly information on the average hourly wages of male and female employees of employers with at least 8 employees (including at least 3 women and at least 3 men).

The State Social Insurance Fund Board will publicly disclose information on the gender pay gap for the previous calendar year for employers with 100 to 249 insured persons every three years, and for employers with 250 or more insured persons annually.

Employers with 100 or more employees, upon receiving information on the gender pay gap, will be required — where an unjustified difference in pay between men and women is identified — to eliminate that unjustified pay disparity no later than six months from the date of receipt of such information.

Our recommendation:

Review the recruitment process to ensure transparency requirements are met;
Conduct an assessment of the gender pay gap;
Review the remuneration system or prepare it, if the employer does not yet have one, taking into account the anticipated new requirements.
Prepare clear information for employees on wage setting and remuneration procedures.
Review confidentiality procedures and agreements to ensure that they are consistent with transparency obligations.