Lithuania has taken the next concrete step in operationalizing its EU Pay Transparency Directive transposition. The Ministry of Social Security and Labour’s order “On the Approval of the Procedure for Collecting and Publishing Information about Employees to Implement Their Right to Fair Remuneration and the General Wage Assessment Procedure” entered into effect on 31 July 2026 (Official Gazette, 17 July 2026, No. 12037).
Where Lithuania’s transposition legislation (Law No. XV-969) established the two-track compliance timeline back in May, this implementing order fills in the operational detail:
- the exact data points employers must submit,
- the calculations Sodra (the Board of the State Social Insurance Fund) will perform,
- and the precise dates on which reporting, Right to Information (RTI), and publication obligations activate.
What Does Lithuania’s New Implementing Order Establish?
The order sets out the procedure for collecting, calculating, submitting, and publishing employee remuneration data under Lithuania’s pay transparency framework. It confirms that monthly employer data submissions will begin on 28 February 2027, covering January 2027 data, and will continue monthly thereafter.
Under the order, that data is submitted through a dedicated pay transparency report — the Skaidraus darbo užmokesčio pranešimas (SDUP) — filed with the State Labour Inspectorate and the Office of the Equal Opportunities Ombudsperson. The order also confirms that Sodra will perform the underlying wage-assessment calculations, with the detailed procedure for completing and adjusting SDUP data to be established separately by Sodra’s Director.
What Baseline Worker Data Must Employers Provide?
Employers must submit certain classification data once, then update it only as changes occur:
- Worker category: the employee’s job group, established under the employer’s remuneration system, grouping employees performing the same work or work of equal value according to non-discriminatory, gender-neutral criteria under Article 140(3) of the Labour Code. Employees holding multiple positions in different job groups must have each group reported separately.
- Working time norm: the average weekly hours an employee is contractually required to work, excluding additional work and overtime, recalculated proportionally where a non-calendar-week schedule applies.
- Working time regime: how working time is distributed across a working day, week, month, or other accounting period (not exceeding three consecutive months), corresponding to the five regime types defined in Article 113(2) of the Labour Code — fixed schedule, cumulative accounting, flexible schedule, split-shift, or individual regime.
What Data Must Employers Report Monthly?
Beyond the baseline classification data, the order defines three recurring monthly data points:
- Gross (accrued) monthly wages: base salary plus most cash and in-kind components, including pay for non-worked but compensated time (leave, downtime not caused by the employee, suspension pay). Certain items are excluded — sickness benefits, severance, and income exempt from state social insurance and health insurance contributions. In-kind benefits applied uniformly across an entire job group (for example, a flat meal voucher or holiday gift card given to every employee in the group) may also be excluded.
- Gross (accrued) additional monthly wages: variable pay components — qualification allowances, bonuses for additional duties or substitution, performance-based variable pay, length-of-service bonuses in the civil service, and premiums for holiday, night, overtime, or non-standard work. The same exclusions for tax-exempt income and uniformly applied in-kind benefits apply here as well.
- Paid monthly working time: actual hours worked, including holiday, night, and overtime work, plus non-worked but compensated time tied to salary continuation. Days of illness compensated by sickness benefit (rather than salary) are excluded from this figure.
When Do Reporting and RTI Obligations Take Effect?
The order confirms a layered activation schedule:
- 28 February 2027: first employer submission deadline, covering January 2027 data.
- 1 March 2027: employees may begin requesting their own monthly average hourly pay, and the monthly average hourly pay broken down by sex within their job group, from their employer, employee representatives, the Labour Inspectorate, or the Office of the Equal Opportunities Ombudsperson
- 15 March 2027: Sodra begins providing employers monthly average pay data by worker category (continuing on the 15th of each month thereafter). Employer must respond within one month..
- 1 March 2028: employees become entitled to annual figures — their own annual pay and average annual hourly pay, plus employer-wide annual averages by sex within their job group.
- 15 March 2028: Sodra provides employers with annual pay indicators for the first time (continuing annually thereafter).
This confirms the structural point made in Trusaic’s earlier coverage: Lithuania’s RTI rights are only as current as the Sodra data feeding them, and that data doesn’t begin flowing to employers until March 2027 at the earliest.
When Will Aggregate Pay Data Be Published?
The order also sets the publication runway for Article 9-style reporting indicators:
- 1 April 2028: Indicators 1–6 (all pay-gap indicators other than the by-worker-category breakdown) published for employers with 150 or more insured persons.
- 1 April 2031: the same indicators published for employers with 100–149 insured persons.
What This Means for Employers
With the implementing order now in force, Lithuanian employers have a firmer basis to start reconciling their payroll and HR systems against the specific SDUP data points — particularly the working time regime classifications and the split between base and additional monthly wages, which will require more granular payroll tagging than many systems currently support.
Employers should also watch for the Sodra Director’s forthcoming procedure on completing and correcting SDUP submissions, since that will determine the practical mechanics of monthly filing.
How Trusaic Can Help
At Trusaic, we provide employers across the EU with solutions to comply confidently with the Directive.
Our Complete EU Pay Transparency Solution enables compliant pay systems, ensures gender-neutral job evaluations, and automates complex reporting obligations to keep you one step ahead of EU pay transparency enforcement.
- PayParity® analyzes your rewards data (compensation/benefits in kind) and quickly identifies any potential unjustified inequities. It enables you to more easily comply with Article 7 (right to information) and Article 6 requirements (pay setting and progression policy).
- Our Remediation Optimization Spend Analysis (R.O.S.A.) works as PayParity’s remediation engine to find the most cost-effective way to close nominal pay gaps to ensure compliance.
- Automated RTI workflows: Our bi-directional integrations with global HCM platforms allow pay equity data to flow securely from the Trusaic platform back into the HCM. Employees can then access their RTI reports directly within their existing HR systems. This eliminates manual report generation and reduces compliance risk.
- For organizations that prefer platform-based access, RTI reports can also be generated and delivered securely through the PayParity platform, with role-based permissions and full auditability.
- Salary Range Finder® ensures equitable pay at the point of hire to prevent any increases in pay gap and enables you to easily comply with the Directive’s salary range disclosure and salary history ban requirements.
- Pay Decisions: Generate fair, competitive offers instantly from Workday.
- Regulatory and Pay Transparency Reporting™ captures your pay equity findings and generates compliant reports.
Trusaic is GDPR compliant and can assist any organization in any EU state in meeting its obligations under both the EU Corporate Sustainability Reporting Directive and the EU Pay Transparency Directive.
Visit our always updated Member State Transposition Monitor to stay on top of the latest EU Pay Transparency Directive developments.