RegRally Insights: Labour and Migration Law – June 2026

Welcome to this edition of RegRally Insights – Employment & Migration, where we bring you the latest EU and national developments shaping labour law, pay transparency, and mobility frameworks across the region.

This month’s edition is dominated by major structural shifts in employment regulation, including the CJEU’s confirmation of equal access to social benefits for beneficiaries of international protection, Lithuania’s implementation of the EU Pay Transparency Directive, and extensive new guidance from the Labour Inspectorate on remuneration systems and enforcement expectations. We also cover key updates on working conditions during emergencies, digitalisation of VDI reporting, and significant reforms to Lithuania’s rules on employing foreign nationals.

Together, these developments signal a clear policy direction: stronger transparency, increased employee rights, and tighter compliance expectations for employers operating in an increasingly regulated labour and migration environment.

CJEU Bars Long-Term Residence Requirements for Refugees Accessing Social Benefits

The Court of Justice of the European Union (CJEU) has ruled that EU Member States may not impose long-term residence requirements on beneficiaries of international protection as a condition for accessing certain social benefits.

The case concerned Italian legislation that made entitlement to the former “citizens’ income” benefit conditional on at least ten years of residence in Italy. The CJEU found that applying such a requirement to refugees and beneficiaries of subsidiary protection is incompatible with EU law.

According to the Court, the Qualification Directive guarantees beneficiaries of international protection equal treatment with nationals in relation to social assistance and integration-related support measures. Member States cannot introduce additional conditions that undermine this principle unless expressly permitted by EU legislation.

The Court also rejected arguments that the residence requirement was justified by administrative or financial considerations. It noted that the costs of administering social assistance do not depend on whether the recipient is a national or an international protection beneficiary.

The judgment reinforces the principle that refugees and beneficiaries of subsidiary protection must have effective access to social assistance on equal terms with nationals. It also confirms that Member States have limited scope to impose residence-based restrictions that could hinder the integration of persons granted international protection.

The decision may prompt Member States to review existing social assistance schemes and eligibility criteria to ensure compliance with EU law.

Source: CJEU | Read more

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Lithuania adopts EU Pay Transparency Directive: key changes to the Labour Code

Lithuania has adopted Law No. XV 969 amending the Labour Code, implementing Directive (EU) 2023/970 on pay transparency and equal pay. Most employer obligations take effect on 7 June 2026, while some requirements are postponed until 1 January 2027.

Key Changes

• Obligation to disclose salary or salary range in job advertisements;
• Prohibition to request candidates’ current or previous remuneration;
• Employees’ right to discuss and disclose remuneration for equal pay purposes;
• Obligation to establish or update remuneration systems by 31 December 2026;
• Introduction of employee rights to obtain pay information (from 1 January 2027);
• Introduction of pay data reporting obligations to Sodra (from 1 January 2027).

Scope & Thresholds

Employers in Scope: All Lithuanian employers fall within scope, regardless of:

• Size;
• Sector;
• Legal form.

Employees in Scope

All employees are covered, including:

• Full-time, part-time;
• Fixed-term;
• Temporary agency workers.

The Remuneration System Must Be Approved by 31 December 2026

A key task for employers in 2026 will be to prepare a compliant job evaluation and remuneration system.

Under the new rules, employers must formally approve a remuneration system by 31 December 2026. Where such a system already exists, it must be reviewed and updated in line with the amended Article 140 of the Labour Code.

Breaches of pay transparency requirements may lead to:

• Administrative fines ranging from EUR 460 to EUR 6,000 imposed on company managers or responsible persons;
• Significantly increased litigation risk due to the removal of limits on compensation in individual disputes related to equal pay violations.

Recommendations for Employers

• Review and update recruitment processes to ensure compliance with salary transparency and prohibition of salary history inquiries;
• Implement or revise remuneration systems based on objective, gender-neutral criteria;
• Prepare internal processes for handling employee requests for pay information;
• Assess readiness for monthly reporting to Sodra;
• Conduct a preliminary internal pay gap analysis (especially for employers with 100+ employees);
• Review and update confidentiality rules and internal policies to align with pay transparency requirements.

Source: LRS | Read more

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The Lithuanian State Labour Inspectorate (VDI) has issued detailed guidance on the EU Pay Transparency Directive

(EU) 2023/970, setting out how it expects employers to implement pay transparency, equal pay principles, and gender pay gap reporting ahead of national transposition. The FAQ signals a strict interpretation of upcoming obligations, with all employers required to prepare structured, objective, and gender-neutral remuneration systems regardless of size.

Key Points:

• Pay systems: mandatory objective job evaluation and grouping based on skills, responsibilities, effort, and working conditions (not employee characteristics).
• Equal pay principle: employees performing work of equal value should be placed in the same job group; pay differences allowed only if objectively justified (e.g. experience, performance, scarcity, market factors).
• Recruitment rules: salary history questions prohibited; applicants must receive salary range/remuneration information before hiring.
• Pay transparency rights: employees can request written information on their pay and average pay by gender within their job group (no disclosure of individual colleagues’ salaries).
• Reporting obligations: employers with ≥100 employees must report gender pay gap data via Sodra (annual or triennial, depending on size).
• Scope of “pay”: includes base salary plus benefits in kind (e.g. company cars, insurance) where part of remuneration.
• Enforcement direction: pay disparities without objective justification will carry discrimination risk exposure.

Recommendations (VDI-aligned compliance priorities)

• Redesign job architecture: update job descriptions and establish a formal job evaluation methodology.
• Build defensible pay structures: ensure salary bands and differentiation criteria are documented and consistent.
• Conduct pay equity analysis: identify and document any unexplained gender or role-based pay gaps.
• Adjust recruitment processes: remove salary history questions and implement pre-contract pay transparency.
• Integrate benefits into compensation mapping to ensure full remuneration visibility.
• Update internal policies and contracts to reflect employee information rights and transparency obligations.
• Establish operational workflows for handling employee pay information requests and future reporting duties.

The guidance confirms that preparatory work should begin immediately, as compliance readiness will depend on long-term restructuring of remuneration systems rather than late-stage formal adjustments.

https://ecovis.lt/lithuanian-labour-inspectorate-guidance-on-eu-pay-transparency-directive/

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Lithuanian Labour Inspectorate reminds employers of their obligations during air raid alerts and emergency warnings

The Lithuanian State Labour Inspectorate (VDI) has issued a reminder to employers regarding their responsibilities when official authorities issue air raid alerts or other emergency warnings requiring residents to seek shelter or move to designated safe locations.

The guidance follows reports and enquiries regarding situations in which employees were allegedly prevented from leaving their workplaces after receiving official emergency notifications. VDI has clarified that employee safety must take precedence over business continuity considerations in such circumstances.

According to the Inspectorate, employers cannot require employees to remain at work where competent authorities have instructed the public to seek shelter or take protective measures. Upon receiving an official warning, employers are expected to promptly inform employees, provide clear instructions regarding the actions to be taken and facilitate access to safe locations in accordance with public safety recommendations.

VDI also emphasises the importance of preparedness. Employers should have emergency response procedures in place before any incident occurs and ensure that all employees, regardless of their role or work location, are aware of the applicable safety arrangements. The guidance further notes that evacuation or movement to shelter locations should be organised in a manner that does not create additional health and safety risks.

The announcement serves as a reminder that occupational health and safety obligations extend beyond traditional workplace risks and include preparedness for emergency situations that may affect employees during working hours.

Our Recommendations

Employers should be prepared for emergency situations in advance by:

• Establishing and maintaining clear emergency response procedures;
• Ensuring that all employees are informed about the actions they should take in the event of an emergency;
• Organising evacuation and access to shelter locations in a safe and orderly manner, without creating additional health or safety risks.

Source: State Labour Inspectorate | Read more

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New Digital Reporting Process for Employers: VDI Expands EPDS Services from June 2026

Starting 1 June 2026, employers in Lithuania will be able to report the completion of violations identified by VDI through the Electronic Services for Employers System (EPDS). The new procedure is designed to simplify communication with VDI, reduce paperwork, and provide a more efficient and transparent reporting process.

Through EPDS, employers will be able to:

• Submit required information in just a few minutes.
• Track whether their submission has been received and is being processed;
• Store all information related to compliance requirements in one place.

After logging in to their EPDS account via the VDI website, employers can access the “Requirements to Eliminate Violations (R1)” section and submit information confirming that the identified violations have been addressed.

To ensure a smooth transition, a transitional period will be in place until 31 December 2026. During this time, employers may choose whether to submit information through EPDS or continue using existing channels such as post or email.

From 1 January 2027, reporting on the fulfilment of VDI requirements will be available exclusively through EPDS, creating a unified and streamlined process for all employers.

EPDS enables employers and employees to communicate with VDI remotely, monitor the status of submitted information, receive responses, and access various electronic services. The system can be accessed through Lithuania’s e-Government Gateway using online banking, an electronic signature, or a national identity card.

According to VDI, this change represents another step in the digitalisation of public services. Support and guidance will be available throughout the transition period to help employers adapt to the new process.

It is important to note that the new procedure applies only to R1 requirements issued on or after 1 June 2026. If an R1 requirement was issued before that date, employers must continue to report its fulfilment using the previously established methods.

Source: State Labour Inspectorate | Read more

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Lithuania tightens foreign employment rules and restructures immigration compliance framework (Law on Legal Status of Foreigners amendments, effective 22 May 2026)

Lithuania has introduced substantial amendments to its immigration regime, combining stricter employer accountability with more flexible hiring pathways for foreign nationals. The reform links employer compliance directly to foreign workers’ residence status, while simplifying qualification requirements and expanding mobility rights for skilled professionals, students, and researchers.

Key Points:

• Employer liability link: sanctions for illegal or undeclared work may trigger a 1-year restriction on issuing or renewing residence permits for affected foreign employees.
• Flexible hiring criteria: employers may rely on one of three grounds—qualification, relevant experience, or salary at or above the national average wage.
• Post-employment mobility: foreign nationals may change employers after termination and remain in Lithuania for 3–6 months while seeking new employment (subject to notification rules).
• Continued stay during renewal: applicants for permit renewal or change may remain and work lawfully while awaiting decisions (with a digital MIGRIS certificate).
• Student employment limits: 20 hours/week for early-stage bachelor students; up to 40 hours/week for senior students, postgraduates, and medical residents; study-based permits generally capped at 8 years.
• Blue Card flexibility: employer change allowed after 12 months; temporary disruptions (e.g. illness, parental leave) tolerated up to 12 months.
• Researchers: permitted to start work upon submission of residence permit application.
• Reduced admin burden: fewer documentary requirements and extended notification deadlines (10 working days).
• Quota exemptions: graduates, humanitarian status holders, temporary protection beneficiaries, and family reunification categories are excluded from annual quotas.
• Expanded family reunification: earlier access for highly skilled workers and certain students/researchers.

Recommendations (employer compliance priorities)

• Strengthen immigration compliance governance: align HR processes with increased employer liability exposure for permit-related consequences.
• Audit recruitment criteria: ensure qualification, experience, and salary thresholds are consistently applied and documented.
• Implement robust notification controls: track all employment changes requiring Migration Department reporting within deadlines.
• Review student workforce planning: adjust scheduling and contracts to comply with new hourly limits.
• Update onboarding and HR policies: integrate new residence continuity and permit processing rules.
• Train HR and recruitment teams: ensure awareness of compliance risks affecting foreign employees’ legal status.
• Monitor permit lifecycle management: especially renewal timelines and transition periods for terminated employees.

https://ecovis.lt/employing-foreign-nationals-new-rules-2026/