Monthly SDUP report to Sodra from 2027: what to prepare with your accountant

From 1 January 2027 every employer reports to Sodra each month on employees’ pay, working time and job group under the pay system. The tool is a new report, form SDUP. The first report is due by 28 February 2027, for January 2027. Your accountant will file it, but the job groups, working-time data and list of benefits must come from you. This article covers what to hand over, by when, and how to check that the data matches your approved pay system. For an overview of all the duties, see “Pay transparency in Lithuania: what employers must do, and by when”.

What the rules say

The law: employers must report to Sodra every month on employees’ pay, working time and the job group set in the pay system (DK Article 23(3), edition from 1 January 2027). Exceptions: officers, statutory civil servants and persons whose data are a state or service secret (DK Article 23(3), edition from 1 January 2027). The Order also exempts professional military servicemen and temporary agency workers (Order A1-433, Description point 9). Data on temporary agency workers is reported by the agency, not the user company (VDI FAQ, question 4.5).

In our view, DK Article 23(3) (edition from 1 January 2027) applies the temporary-worker exception only to workers whose indicators are reported under Article 23(8), which covers employers with 100 or more insured persons. A temporary work agency with fewer insured persons should therefore check with Sodra.

The details are set by Order No. A1-433 of the Minister of Social Security and Labour of 17 July 2026:

• When: every month, by the last day of the month, for the previous month, through Sodra’s EDAS system (Description point 6).
• First time: by 28 February 2027, for 1–31 January 2027 (Order point 2.1).
• Every month: gross monthly pay, gross additional monthly pay, and paid working time in hours (Description point 6).
• First report only, in addition: the employee’s working-time norm, working-time regime and job group number under the pay system (Description point 7).
• Afterwards: these three items are updated only when they change (Description point 8).

The duty applies to every employer, whatever its size. Headcount matters in two cases. First, if you have at least 8 employees (more than 3 women and more than 3 men), Sodra will publish your company’s average pay per hour for men and for women every month (DK Article 23(6), edition from 1 January 2027; Order A1-433, Description point 16). Second, the gender pay gap indicators: Sodra calculates them for employers with 100 or more insured persons, and for smaller employers that opt in (DK Article 23(4), edition from 1 January 2027). First time: by 1 March 2028 (150 or more) or by 1 March 2031 (100–149) (Article 23(5) of Law No. XV-969).

The rules for filling in form SDUP are set by the Director of Sodra (Description point 3.1). They are not yet in our sources. When Sodra publishes them, read them together with your accountant.

Five items only the employer can provide

Your accountant knows salaries and hours. These items it cannot work out alone:

1. Job group number for each employee. The group is expressed by the number given in your pay system (Description point 4.3). VDI says the number may contain digits, letters, a dot and a dash, and recommends asking Sodra about the field format (VDI FAQ, question 4.6).
2. Two jobs, two entries. If an employee holds jobs in different groups, each is reported separately (Description point 7).
3. Working-time norm: the average weekly hours under the employment contract. A norm set for another period is converted to an average weekly norm (Description point 4.1; VDI FAQ, question 4.7).
4. Working-time regime: one of five: fixed working day, aggregated working time, flexible schedule, split working day, or individual regime (Description point 4.2).
5. Benefits in kind. Gross pay includes pay in money and in kind (Description point 4.4). Additional pay in kind may be left out when all employees of the same job group, without any exception, receive the same benefit, such as a meal voucher or a Christmas gift card, with no possibility of different terms (Description point 4.4; see also VDI FAQ, question 5.1). Daily travel allowances that only compensate expenses are left out (VDI FAQ, question 4.2). Compensation for on-call time at home is included (VDI FAQ, question 4.4). Income on which no state social insurance and compulsory health insurance contributions are paid is left out (Description points 4.4 and 4.5). Check each benefit’s contribution status with your accountant.

What Sodra sends back

From your data Sodra will calculate, every month, each employee’s average pay per hour and the average pay per hour of men and of women in each of your job groups (Description point 10). First by 15 March 2027, then by the 15th of each month for the month before last (Order point 3.1.3). Employees can ask for these figures from 1 March 2027. A wrong group in the SDUP report therefore means a wrong answer to an employee.

Handover table for the accountant

| What the employer hands over | By | Who | |—|—|—| | Approved pay system with group numbers | 2026-12-31 | Manager | | List: employee – job – group number | 2027-01-15 | Manager or HR person | | Working-time norm and regime per employee | 2027-01-15 | HR person | | List of benefits in kind, marked whether equal for the whole group | 2027-01-15 | Manager | | Employees with two jobs and their groups | 2027-01-15 | HR person | | Test check: group numbers match the system | 2027-02-19 | Manager and accountant | | First SDUP filed in EDAS | 2027-02-26 (deadline 2027-02-28) | Accountant | | Changes (new job, group, norm) | Same month as the change | Manager tells the accountant |

Our recommendation: we chose 15 January 2027 so the accountant has time to set up the payroll software. The law does not set that date. The only legal deadline is 28 February 2027. That is a Sunday, so we recommend filing by Friday, 26 February 2027.

Worked example: a 12-person and a 45-person company

A 12-person services company, 4 groups. Group 1: cleaner. Group 2: two customer service specialists and a storekeeper. Group 3: five project managers and an accountant. Group 4: the managing director and the sales manager. Everyone works 40 hours a week on a fixed working day. Only the managing director gets extra health insurance; the sales manager in the same group does not. The benefit is not equal for the whole group, so, if social and health insurance contributions are paid on it, its value is included in the director’s pay. The accountant checks the contribution status. Meal vouchers are equal for everyone, so they may be left out.

A 45-person manufacturer, 6 groups. Production uses aggregated working time; the office works a fixed day. Six employees work part time, 20 or 30 hours a week, and their norm is stated exactly. One employee is both warehouse head (group 4) and, under a separate agreement, occupational safety specialist (group 3). He gets two entries, each with its own group, pay and hours. Group 5 has two sub-levels, 5.1 and 5.2. If you report the sub-levels, Sodra will calculate averages only within each sub-level (VDI FAQ, question 2.8). Decide this in advance and write it into the system.

Email to the accountant (copy it)

> Hello, > > from January 2027 we must file form SDUP with Sodra every month (Order No. A1-433 of 17 July 2026). The first report, for January 2027, is due by 28 February 2027. > > Attached: (1) the approved pay system; (2) a table “employee – job – group number”; (3) each employee’s working-time norm and regime; (4) a list of benefits in kind, marked whether equal for the whole group; (5) employees who hold two jobs. > > Please: check that the payroll software can record a group number and two entries for one employee; send us a draft report by 19 February 2027; let us know when Sodra publishes the SDUP filling rules. > > We will tell you about any change of job, group or working time in the same month.

Checklist before the first report

• Every employee has a group, and the group is in the approved system.
• Group numbers in the SDUP report are written exactly as in the system.
• Employees with two jobs have two entries.
• Part-timers’ norms match their employment contracts.
• Benefits in kind are valued in money, or marked as equal for the whole group.
• Temporary agency workers and other excluded persons are left out (a temporary work agency with fewer than 100 insured persons checks this with Sodra first).
• You know who tells the accountant about changes.

Mistakes to avoid

• Group numbers do not match the system. The system says “Group III”, the software says “3”. Use one label everywhere.
• Group changed, Sodra not told. An employee is promoted but the SDUP report keeps the old group. Sodra’s averages and the answers to employees will then be wrong.
• Benefits in kind forgotten. A car for private use, insurance or a gym membership for only some employees is pay (VDI FAQ, question 5.1). You leave it out of the Sodra data only where no social and health insurance contributions are due on it (Description points 4.4 and 4.5).
• System rewritten, numbering changed. If you change the system, update every group number in the report at the same time.

What to do if…

…the pay system is not approved by 31 December 2026. There will be no group numbers to report, but the report is still due. The system had to be approved by 31 December 2026 (Article 23(4) of Law No. XV-969). Approve it as soon as you can, after the information and consultation procedure (DK Article 140(3)). By mid-January 2027 at the latest, have a draft with final group numbers.

…an employee changes job mid-month. The job group is one of the items updated when it changes (Description point 8). How to report a mid-month change will be set by Sodra’s filling rules. Until then, record the date of the change and pass it to the accountant the same day.

…your accountant is an outside firm. If its contract predates this duty, SDUP filing may not be covered. Agree in writing who files SDUP, when you hand over the data, and who is responsible if data is missing. Towards Sodra, the employer remains responsible.

…the report is not filed. From 1 January 2027, failing to give Sodra the pay information required by the Labour Code carries a fine for employers or other responsible persons of four hundred and sixty to seven hundred euros, and for a repeat breach seven hundred to one thousand four hundred euros (ANK Article 99(1) and (2), edition from 1 January 2027).

Related articles

• Employee requests for pay data from 1 March 2027: how to reply
• Small employers: a minimum pay system by 31 December 2026
• Job evaluation and grouping for a pay system: a practical guide
• Bonuses and variable pay in a Lithuanian pay system: how to write them
• Pay transparency in Lithuania: what employers must do, and by when

How to start

Send us your pay system (or its draft) and your list of jobs. We will check whether the groups and their numbers work for the SDUP report, and prepare the table and the letter for your accountant.

Linden’s full solution, from the pay system to informing employees, is at atlygis.linden.lt. Check which requirements apply to you: atlygis.linden.lt/en/self-check.

Phone +370 5 212 1506, email info@linden.lt

More about this service: drafting labour law documents.