Yes, No, or partially transposed.

Yes. Lithuania adopted transposing legislation.

Part i.

a. The Directive has mainly been transposed through the law amending the Lithuanian Labour Code. The Lithuanian text is available here. There is no official English translation, so a separate machine translation is provided separately (attached in the email).

As of 7 June 2026, most of the amendments entered into force. From this date, employers may no longer ask candidates about their current or previous remuneration, and candidates must be provided with the applicable collective agreement provisions related to pay before employment. In addition, the previous 6-month cap on penalties for late settlement with an employee no longer applies.

By 31 December 2026, employers will have to approve remuneration systems or amend them in line with the new legal requirements.

As of 1 January 2027, employers will be required to submit information to the State Social Insurance Fund Board (Sodra) on employees’ pay, working time and job category. The obligation to provide pay-related information to employees and, depending on the situation, to employee representatives, the State Labour Inspectorate and/or the Office of the Equal Opportunities Ombudsperson will also apply from this date. Accordingly, other obligations, including the obligation to justify pay differences by objective and gender-neutral criteria, to eliminate such unjustified differences, as well as to carry out a joint pay review, will also start to apply.

a. The legislation generally follows the Directive but introduces certain additional measures, notably a centralised wage reporting and calculation system administered by the Social Insurance Fund Board (Sodra).

b. The new introduced rules generally supplement existing obligations rather than creating a separate compliance regime. Employers will continue to comply with existing obligations, while the new requirements will apply from their respective effective dates.

The law authorises the Minister of Social Security and Labour to adopt implementing legislation setting out the procedures for data collection, calculation, reporting, publication and joint pay assessments. These implementing acts are expected to be adopted by 31 July 2026.

Workers are individuals who have entered into an employment contract under Lithuanian law and are therefore generally insured under the Lithuanian social security system.

Yes. Lithuanian law addresses this through the concept of a remuneration system which is based on objective and gender-neutral criteria, including job classification, pay ranges (minimum and maximum), bonus rules, and salary increase criteria and procedures

Yes. The legislation provides that jobs must be grouped and assessed using objective and gender-neutral criteria, including skills, qualifications, effort, responsibility, working conditions and other. Jobs assessed as being of the same value must be placed in the same job category.

Employer must provide information on the amount and/or the range of the offered basic salary (hourly rate or monthly salary, or the fixed part of the salary). No specific obligation applies to bonuses or other benefits.

The pay information must be included in the job advertisement. In addition, before the employment contract is concluded, the future employer must provide the applicant with the pay information and, where a collective agreement applies, the relevant collective agreement provisions.

Lithuanian law does not expressly state whether the prohibition on salary history enquiries applies equally to internal candidates.

The legislation does not expressly address salary information already known to the employer. 

Yes. Under existing law, job vacancy notices and job titles must be gender-neutral.

Upon written request, an employee is entitled to receive information on their annual pay, average hourly pay for the month and average hourly pay for the year, as well as the employer’s average annual pay, average monthly hourly pay and average yearly hourly pay for employees of each sex within the same job category to which the employee’s position is assigned.

Employers must provide employees and employee representatives with the gender pay indicators received from Sodra within one month of receiving such information.

Additionally, employers must also make their remuneration system available.

Individual pay information must be provided in writing.

The Lithuanian Labour Code expressly provides that objective and gender-neutral criteria include skills (including communication, cooperation, conflict-resolution and interpersonal skills relevant to the performance of the job), qualifications, effort (the amount of physical, mental and emotional resources required to perform the tasks set out in the job description), responsibility, working conditions (working environment, intensity, risks, and physical and psychological factors), and, where appropriate, other relevant criteria.

Yes. Gender pay gap reporting applies to employers with at least 100 employees, although smaller employers may opt in voluntarily. Employers with fewer than 50 employees are exempt from certain remuneration system requirements.

For the purposes of this provision, “pay” means salary or any other remuneration, including remuneration in cash or in kind, received directly or indirectly from the employer in respect of employment. Under Lithuanian law, remuneration consists of: (i) basic salary, (ii) additional pay components, (iii) qualification-related allowances, (iv) supplements for additional work or duties, and (v) performance-based and discretionary bonuses.

Benefits / payments that are granted equally to all employees in the same job group and are not linked to individual work value, e.g. Christmas gift cards, collective training or discount cards available to all, should generally not be included. Work tools, work clothing and mandatory training are also excluded. However, when submitting the relevant data, the employer must include and assign a monetary value to benefits provided to the employee in kind, where such benefits are considered part of remuneration for work. Where a benefit, such as a car or phone, is used partly privately, only the private-use value should be included if it qualifies as remuneration.

The employer must provide the requested information in writing within 1 month from receiving the employee’s request. If the information is inaccurate or incomplete, additional explanations and a reasoned answer must be provided within a maximum of 2 months from receipt of the original request.

The request and response are in writing. Written form may include electronic means if the content, sender, fact and time of submission can be identified and the information can be saved or printed.

There is no express headcount exemption for the individual worker information right.

Yes. The worker may request the information directly from the employer and may also obtain it through workers’ representatives, the State Labour Inspectorate or the Equal Opportunities Ombudsperson.

Worker may request additional explanations, clarifications and a reasoned response from the employer. The employer must provide such a response within 2 months from receipt of the original request.

Yes, employers must annually inform employees of their right to obtain this pay information.

Lithuanian law does not set a separate language rule for this specific information. However, a general rule is that employment-related information must be provided in Lithuanian, and if needed, also in another language understood by that employee.

Employers cannot prohibit workers from disclosing their own pay where this is done for the purpose of exercising or enforcing the right to equal pay for the same work or work of equal value. However, employers may require that information obtained under the pay transparency rules, other than information about the worker’s own pay or pay level, is not used for any purpose other than exercising the right to equal pay.

Any clause treating an employee’s own pay as confidential should either be removed or amended to state that the employee’s own pay is not treated as confidential where the employee discloses it in order to exercise or enforce the right to equal pay for the same work or work of equal value.

For employers with 150+ insured persons, the first data must be provided by Sodra to employers by 1 March 2028 and publicly published by 1 April 2028; for employers with 100–149 insured persons, first provision is by 1 March 2031 and publication by 1 April 2031. Thereafter, Sodra calculates and provides the relevant gender pay gap information: annually for employers with 250+ insured persons, and every three years for employers with 100–249 insured persons, for the previous calendar year

All employers, regardless of headcount, must submit monthly data to Sodra on each employee’s pay, working time and job group under the employer’s remuneration system. Sodra calculates the gender pay gap indicators. For employers with 100 or more insured persons, the following indicators are calculated:

• overall gender pay gap; 

• gender pay gap in additional remuneration; 

• median gender pay gap; 

• median gender pay gap including additional remuneration; 

• proportion of male and female employees receiving additional remuneration; 

• distribution of male and female employees across pay quartiles; and 

• gender pay gap by job group, separately for basic / tariff pay and additional remuneration. 

The reporting thresholds correspond to those in the Directive – 250+ insured      persons (annual reporting) and 100-249 insured persons (reporting every three years). Employers with fewer than 100 insured persons may participate voluntarily. 

For temporary agency workers, the position is different: temporary work agencies must calculate the relevant previous calendar year indicators themselves and submit them to Sodra.

No.

No direct publication obligation applies to employers. The relevant data are published by Sodra

Yes. Employers must provide pay data to Sodra, which calculates the relevant gender pay gap indicators and shares them with the Labour Inspectorate and the Equal Opportunities Ombudsperson. Sodra also publishes the relevant indicators. The legislation provides for publication of employer-specific data rather than anonymised or sector-level information.

INSERT ANSWER

No.

The thresholds are the same as in the Directive: 100/150/250 employees.

There are no sector-specific exemptions. Employers with less than 100 employees are not subject to mandatory gender pay gap reporting, but they may participate voluntarily.

Employer must remedy the situation no later than 6 months from receiving the relevant Sodra pay gap data. For temporary agency workers, the 6-month period runs from the date the relevant data is submitted to Sodra.

The employer must first be able to explain and justify any gender pay difference by objective, gender-neutral criteria. If employees or workers’ representatives request explanations after receiving the pay gap data, the employer must provide them within a reasonable period, but no later than 1 month. If the State Labour Inspectorate or the Equal Opportunities Ombudsperson requests explanations, they must be provided within the deadline set by the authority, but no later than 10 working days. If the pay gap is not objectively justified, the employer must take active steps to correct the unjustified difference within the statutory 6-month period. Where the relevant conditions are met, the employer must also carry out a joint pay assessment in cooperation with workers’ representatives.

The employer must remedy unjustified pay differences in cooperation with workers’ representatives. This includes sharing relevant information, providing explanations, consulting on corrective measures and involving them in any required joint pay assessment. 

Lithuanian law does not define “close cooperation” in detail and does not expressly require formal agreement with workers’ representatives.  

A joint pay assessment is required where all of the following apply: the reported data shows at least a 5% average pay gap between women and men in any job group; the employer cannot justify it by objective, gender-neutral criteria; and the employer has not remedied it within 6 months.

The detailed procedure for data handling and joint pay assessments is to be set by the Minister of Social Security and Labour. 

Employer must make the joint assessment available to employees, workers’ representatives and the State Labour Inspectorate.

Where providing relevant information would reveal another employee’s specific pay, the information may, upon the employee’s request, be provided only to workers’ representatives, the State Labour Inspectorate or the Office of the Equal Opportunities Ombudsperson.

Lithuanian law provides for administrative liability for breaches of pay transparency / pay-related requirements, with fines ranging from EUR 460 to EUR 6,000 depending on the nature of the breach. These fines are imposed on company managers or other responsible persons. In practice, the greater risk may arise from individual employee claims. If an employee succeeds in an equal pay claim, the employer may be ordered to pay unpaid remuneration, benefits in kind, compensation for lost opportunities, material and non-material damage, discrimination-related damage and late-payment interest. 

A worker who alleges a breach of the right to equal pay may bring an individual labour dispute before the Labour Disputes Commission and, if necessary, the courts. They may seek unpaid remuneration, benefits in kind, compensation for lost opportunities, material and non-material damage, discrimination-related damage and late-payment interest. Where the issue may amount to sex-based pay discrimination, the worker may also submit a complaint to the Equal Opportunities Ombudsperson

As of now, public authorities have so far provided guidance materials (these materials are not official binding guidance, they are mainly intended to help employers understand the new requirements in practice).

The publicly available guidance is available to all employers.

Explanatory materials and practical guidance published by institutions:

• FAQ - National Labour Inspectorate; 

• Transparent remuneration directive: what data will employers provide and what will be made public – Sodra

• 2026-02-02 Rekomendacijos dėl paygap.pdf (contains practical guidance on the implementation of the new requirements; however, it is currently available only in Lithuanian)

Some notable features of the Lithuanian implementation: 

• As noted before, it adopts a centralised Sodra-based reporting model. Rather than requiring employers to calculate and submit gender pay gap indicators themselves, Sodra will calculate the relevant indicators based on data submitted by employers and will provide the results to employers, employees and workers’ representatives.

• Unlike other employers, temporary work agencies are required to calculate certain pay transparency indicators themselves in accordance with the specific rules applicable to temporary agency workers.

• Previously, the Lithuanian Labour Code provided that where, upon termination of employment, the employer delayed the final settlement with the employee for reasons not attributable to the employee, the employer was required to pay a penalty equal to the employee’s average monthly salary multiplied by the number of months of delay, subject to a maximum of six months’ salary.

This six-month cap has now been removed.