On May 27, 2025, draft proposals for transposing the EU Pay Transparency Directive were officially presented to the Tripartite Council of Lithuania’s Ministry of Social Security.
Lithuania is the most recent among a growing list of EU member states — including Sweden, Ireland, Poland, The French Community of Belgium, the Netherlands, and Finland, — that have shared their proposed transpositions.
While the current draft addresses core transparency obligations, further details related to periodic government reporting and joint pay assessments will be handled separately by Social Insurance and Labour Inspection institutions.
Employers should nonetheless begin preparing now, as the proposed law is slated for implementation on June 7, 2026.
Key Highlights of Lithuania’s Draft Proposal
1. Before Employment
Existing Requirements:
- Employers must include base salary or salary ranges in job advertisements.
New Obligations:
- Employers must provide applicable collective agreements before contract discussions or signing.
- Asking candidates about current or past salary history is prohibited.
2. Pay Gap Reporting
Existing Framework:
- Lithuania’s Social Security institution already publishes raw pay gap data monthly.
New Requirements:
- Employees or their representatives can request annual pay gap data by job category.
- Employers must provide explanations and resolve unjustified pay disparities within six months.
- This individual-level transparency is distinct from broader institutional reporting, which may trigger joint pay assessments through a separate forthcoming procedure.
3. Pay Structures and Systems
Existing Requirements:
- Employers with 20+ employees must collaborate with worker representatives to establish formal pay systems, including:
- Base pay bands
- Variable compensation principles
- Pay indexation procedures
New Requirements:
- All employers, regardless of size, must have formal pay systems.
- Pay structures must include:
- Gender-neutral job categorization criteria such as skills (including social-emotional), effort, responsibility, and working conditions.
- Defined salary increase procedures (optional for companies with <50 employees).
4. Right to Information
New Rights for Workers:
- Employees can request written data on:
- Their individual pay
- Average pay, by gender, for comparable roles or roles of equal value
- Workers can also request clarifications or substantiations if the initial information is incomplete.
- Employers must annually notify workers of these rights and the steps to exercise them.
- Employees cannot be prohibited from disclosing their pay for the purpose of enforcing equal pay rights.
- Employers may restrict broader use of pay data obtained, with exceptions for enforcing equality.
5. Data Protection and Disclosure Rules
- Employees or their representatives may request pay gap data for job categories with more than two individuals.
- If data protection concerns arise, disclosures may route through worker representatives or external authorities.
6. Fines and Enforcement
New Measures:
- The previous cap on pay-related compensation (six months’ wages) is removed.
- Non-compliance penalties range from €400 to €6,000.
- Violations include failure to disclose required pay information or maintain compliant pay systems.
7. Support for Small Employers
- Existing job evaluation and pay system guides remain available but are not widely utilized.
- No updates or new tools have been announced to assist smaller companies.
What This Means for Employers
Lithuania’s proposal is a clear and direct application of the EU Pay Transparency Directive, with minimal deviations or discretionary adaptations. Employers — regardless of size — must proactively:
- Audit and formalize pay systems
- Eliminate use of salary history in hiring
- Disclose salary information when required
- Prepare to respond to worker pay data requests
The upcoming June 2026 implementation gives organizations time to prepare, but the changes are substantial and will require careful planning, documentation, and transparency throughout the employee lifecycle.
How Trusaic Can Help
At Trusaic, our solutions help global organizations navigate the evolving regulatory landscape.
Our Pay Equity Software Suite 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® helps you understand, explain, and resolve pay inequities across gender, race, age, and more. Conduct proactive or compliance-driven analyses to pinpoint disparities, reduce legal risk, and build trust by ensuring fair, transparent pay practices across your workforce.
- Our Remediation Optimization Spend Agent (R.O.S.A.) works as PayParity’s AI remediation partner to maximize the ROI of your remediation budget.
- Salary Range Finder® helps you prevent pay inequities before they start with data-driven pay range guidance. This enables you to easily comply with the Directive’s salary range disclosure and employee right to information requirements.
- Regulatory Pay Transparency Reporting™ helps you confidently report and comply with pay transparency requirements across EU member states.
- Our Pay Transparency Agent answers all your pay transparency reporting questions instantly
- Our Communications Agent crafts perfect contextual narratives in any language to support your annual pay 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.