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LithuaniaVDI

Every employer must approve a gender-neutral pay system by year end

No 20-employee threshold; gender-neutral groups, pay bands, bonus rules, indexation criteria; existing systems reviewed and every employer compliant by 31 December 2026.

By Taxxa AI OyPublished 25 September 2026

Payroll & Labour

Every Lithuanian employer needs a compliant pay system by 31 December 2026.E TAR Under the amended Article 140(3) of the Darbo kodeksas, the remuneration system at a workplace or in an employer's company, agency or organisation is set by collective agreementE TAR and applies to all employees thereE TAR. Where no collective agreement sets one, the employer approves the systemLRV and makes it available to all employees for reviewE TAR — with no 20-employee thresholdLRV. Before adopting or changing the system, the information and consultation procedures with employee representatives are completed.LRV

The mandatory content is substantially expanded. Positions are grouped by objective and gender-neutral criteriaLRV covering skills (including communication, cooperation, conflict-resolution and teamwork skills relevant to the function)E TAR, qualificationsLRV, effort (the physical, mental and emotional resources needed)E TAR, responsibilityLRV, working conditions (environment, intensity, risk, physical and mental factors) and, where relevant, other material criteriaE TAR. Positions carrying the same or equal-value work fall in the same group.LRV For each group or position the system sets the pay forms, the pay amounts or bands (minimum and maximum)E TAR, the grounds, amounts and procedure for supplementary pay (priedai and priemokos) and bonusesE TAR, and the criteria and procedure for pay indexation and increases (better results, growing competences, longer experience)E TAR. Employers with fewer than 50 employees are exempt only from stating the pay-increase criteria and procedure.E TAR

The equal-pay rule in Article 140(5) now turns on the same criteria: men and women receive equal pay for the same or equal-value work, where equal-value work is assessed against the Article 140(3) criteriaE TAR. Complementary transparency duties phase in through Article 23: the Valstybinio socialinio draudimo fondo valdyba computes gender pay-gap indicators per position group and first supplies them to employers with 150 or more insured persons by 1 March 2028 (100–149 by 1 March 2031), and employers share the gap indicator with representatives and staff, correct an unjustified gap within six months, and conduct a joint pay assessment where a gap of at least 5 per cent in any group is not objectively justified.

The VDI employer-duties page reflects the change in two places: the information-to-VDI item now carries the Article 140(3) pay-system content instead of the old Article 109(1) posting-notification duty of foreign employers, and the internal-procedures item still carries the old 20-employee rule — practitioners follow the amended Article 140(3) text and the 31 December 2026 approval deadline.

Legal basis: Law No XV-969 of 21 May 2026 amending Articles 23, 140 and others of the Darbo kodeksasE TAR (in force 7 June 2026E TAR; Article 23 pay-transparency data duties from 1 January 2027), transposing Directive (EU) 2023/970; employers approve or review the pay system by 31 December 2026 under Article 23 of the amending lawE TAR.

Approve an Article 140(3)-compliant remuneration system, or review the existing one, by 31 December 2026.

Sources