The amendments to the Labour Code of the Republic of Lithuania (hereinafter – the Labour Code), implementing the EU Directive on pay transparency and the principle of equal pay for men and women, established that:
- employers must approve or review the employee remuneration system by 31 December 2026;
- from 1 January 2027, the obligation to provide information on remuneration to the State Social Insurance Fund Board under the Ministry of Social Security and Labour (hereinafter – Sodra) and to provide data to employees enters into force.
As the above deadlines approach, Sodra adopted the order “On the Approval of the Rules for Completing the Transparent Pay Report and Correcting the Data Submitted Therein” (hereinafter – the Order), which establishes the procedure for completing, submitting and correcting the transparent pay report form.
The Order was prepared in accordance with the Labour Code and the order of the Ministry of Social Security and Labour “On the Approval of the Description of the Procedure for Collecting and Publishing Information on Employees for the Purpose of Implementing Their Right to Fair Remuneration and for the Joint Pay Assessment” (hereinafter – the Description).
The procedure established in the Order is consistent with the Description. However, the Order additionally specifies what data must be submitted to Sodra and how.
Entry into Force
The Order entered into force on 7 October 2026
1. One of the most important changes – clarification on how the job classification group number may be indicated
The amendments to the Labour Code established that employee positions must be classified into groups based on objective and gender-neutral criteria. The Description provides that when submitting the Transparent Pay Report (hereinafter – SDUP), the job classification group number must be indicated.
The Order clarifies that the employee job classification group is indicated by the corresponding number (which may consist of digits, Latin letters (without diacritical marks), as well as dot and hyphen characters) specified in the remuneration system. This indicates that Sodra is seeking ways to adapt to employers’ needs and to facilitate the grouping of positions and the provision of information.
2. SDUP Submission Procedure
Employers submit the SDUP for the preceding calendar month on a monthly basis, no later than the last calendar day of the current month.
Data is submitted for all employees, including employees who are not subject to Lithuanian social insurance law, as well as employees on paternity or childcare leave (9-SD report), in non-insured periods (unauthorized absence, unpaid leave) (12-SD report) and/or employees for whom NP-SD2 reports have been submitted (for the granting of benefits, e.g., during periods of sickness, maternity and childbirth leave).
The SDUP is not completed for: (i) officials, professional military service members, statutory civil servants and other persons whose data constitutes a state or official secret; and (ii) employees working under temporary employment contracts.
3. Option for employers with fewer than 100 employees to apply the rules established for larger employers
Article 23(4) of the Labour Code provides that Sodra submits data on the gender pay gap (basic pay, supplementary pay, medians, etc.) every 3 years (for employers with 100–249 employees) and every year (for employers with 250 or more employees).
Employers with fewer than 100 employees, who wish to have the rules applicable to employers with 100–249 employees applied to their data, may submit their consent for the use of such data for the calculation of statistical indicators by marking the relevant field in the Electronic Insurer Service System (hereinafter – EDAS).
4. How to submit the SDUP?
The SDUP data may be submitted, corrected and reviewed by the employer or a person authorised by the employer.
When completing the SDUP form in EDAS, the reporting period (year and month) for which the data is submitted is selected. If an employee’s employment relationship ends, the data is submitted for the calendar month in which the employment relationship has ended.
5. What data must be indicated in the SDUP form?
The SDUP form reflects the employer’s data and the employee’s personal information (the data of each employee for whom the employer has submitted a 1-SD report may be pre-filled with data from the Sodra register).
Additionally, the SDUP form includes:
- the accrued (gross) remuneration amount in euros (determined in accordance with the Description). All components of remuneration are included, except for compensatory payments;
- the accrued (gross) supplementary remuneration (supplements, surcharges, bonuses and other supplementary remuneration components) amount in euros;
- paid working time in hours, including paid non-working time.
When submitting the SDUP for an employee for the first time or when the employee’s data has changed, the following data is indicated:
- job classification group number. If an employee holds several positions assigned to different job classification groups, the data for each job classification group is presented in separate lines in the SDUP form. If an employee’s job classification group changes during a calendar month, the data for each job classification group is presented in separate lines in the SDUP form;
- working time norm, in hours;
- working time regime.
6. Correction of the SDUP Form
If the employer determines that the submitted SDUP data is incorrect or incomplete, the employer must submit a corrected SDUP. The data must be corrected without delay, but no later than within 2 working days from the identification of the error or discrepancy.
SDUP data may be corrected on the employer’s initiative upon identifying discrepancies or errors in the current year’s data, or at the request of Sodra or another state institution.
Once the employer corrects the SDUP data, the monthly indicators calculated by Sodra are automatically recalculated and updated on the 5th day of each month, but no later than by 5 February of the following calendar year.
IMPORTANT
We would like to remind you that the deadline for the approval or review of the employee remuneration system is fast approaching, and therefore we encourage you to take action as soon as possible – to group positions based on objective and gender-neutral criteria, to review the existing or approve a new remuneration system, and to prepare for the provision of information to Sodra and employees.
If you have any questions or need consultation and assistance in preparing or reviewing the remuneration system and implementing the changes, please contact the TEGOS Lithuania employment law team.
