{"id":2989,"date":"2026-10-07T22:19:33","date_gmt":"2026-10-07T19:19:33","guid":{"rendered":"https:\/\/linden.lt\/tinklarastis\/pay-system-self-check-20-questions-lithuania\/"},"modified":"2026-10-07T22:19:33","modified_gmt":"2026-10-07T19:19:33","slug":"pay-system-self-check-20-questions-lithuania","status":"publish","type":"irasas","link":"https:\/\/linden.lt\/en\/blog\/pay-system-self-check-20-questions-lithuania\/","title":{"rendered":"Pay system self-check: 20 questions for a small company"},"template":"","kategorija":[],"class_list":["post-2989","irasas","type-irasas","status-publish","hentry"],"acf":{"visi_puslapiai_cta_statusas":false,"visi_puslapiai_cta_antraste":"","visi_puslapiai_cta_formos_id":"","visi_puslapiai_cta_papildomas_tekstas":"","visi_puslapiai_cta_nuotrauka":null,"tinklarastis_1_autorius":null,"tinklarastis_1_iraso_tipas":false,"dinamiski_blokai":[{"acf_fc_layout":"tekstas","tekstas":"

By 31 December 2026 every employer must approve a pay system<\/a> or review its existing one (Article 23(4) of Law No. XV-969). Below are 20 questions a manager or office manager can answer in an hour. Each says whether it is a legal requirement or our recommendation, and what to do this week if the answer is no. At the end you will find a scoring key and two filled examples. For an overview of all the duties, see \"Pay transparency in Lithuania: what employers must do, and by when\"<\/a>.<\/p>\r\n

Write your answers down. A dated, completed checklist is already your first proof that you reviewed the system.<\/p>\r\n

A. The document<\/h2>\r\n

1. Do you have an approved pay system (or a collective agreement setting one)?<\/strong> The law: DK Article 140(3). If no: this week list the jobs and current pay, appoint a responsible person and set an approval date before mid-December.<\/p>\r\n

2. Can every employee access the system?<\/strong> The law: DK Article 140(3). If no: put it in a shared folder or intranet and collect acknowledgements.<\/p>\r\n

3. Does the system say how pay is set: a monthly salary or pay per hour?<\/strong> The law: DK Article 140(3). If no: add the pay form for each group.<\/p>\r\n

B. Job groups<\/h2>\r\n

4. Is every job placed in a group based on skills, qualification, effort, responsibility and working conditions?<\/strong> The law: DK Article 140(3). If no: score each job on these five criteria from 1 to 5.<\/p>\r\n

5. Do the groups list real job titles, as used in employment contracts?<\/strong> Recommendation (VDI FAQ, question 1.3). If no: align the titles in the system, contracts and job descriptions.<\/p>\r\n

6. Is the evaluation written in a table, with jobs assessed as vacant rather than by the people holding them?<\/strong> Recommendation (VDI FAQ, question 2.1). If no: build a table with scores and a short reason for each score.<\/p>\r\n

C. Pay ranges<\/h2>\r\n

7. Does each group have a gross amount or a minimum and maximum?<\/strong> The law: DK Article 140(3); gross figures are a VDI recommendation (VDI FAQ, question 1.8). If no: set a range, for example from 85% to 115% of the group midpoint. Percentages help with the calculation, but the system itself must state actual amounts or the minimum and maximum limits.<\/p>\r\n

8. Does every current salary fall within its group's range?<\/strong> The law (below the minimum): pay may not be lower than the pay system sets (DK Article 140(2)). Recommendation (above the maximum): in VDI's view, the group maximum may be exceeded only in exceptional cases, for example where the supply of workers with exceptional skills is very limited, and such cases and the rules for the higher pay must be clearly set out in the system (VDI FAQ, question 3.11). If no: list the deviations. Raise any pay below the minimum, or change the limit before the system is approved. For pay above the maximum, describe an exception in the system if such an exceptional reason exists; otherwise widen the range.<\/p>\r\n

D. Place in the range and changes<\/h2>\r\n

9. Are there written criteria that place an employee at the bottom or top of the range (experience, competences, results)?<\/strong> Recommendation (VDI FAQ, question 3.12). If no: write 3\u20134 criteria and one sentence of reasons per employee.<\/p>\r\n

10. Is there an indexation procedure (frequency, reference indicator, who decides, when indexation may be skipped)?<\/strong> The law: DK Article 140(3); VDI says this applies to all employers (VDI FAQ, question 1.7); VDI recommends the elements listed in brackets. Pay-increase criteria and procedure are mandatory only with 50 or more employees. If no: add one paragraph.<\/p>\r\n

E. Bonuses and benefits<\/h2>\r\n

11. Are the grounds, amounts and procedure for allowances, supplements and bonuses set out in the system?<\/strong> The law: DK Article 140(3). If no: list every extra payment you make now and write who gets it, when and for what.<\/p>\r\n

12. Are benefits in kind (car, insurance, gym membership) granted under written rules?<\/strong> The law (definition): pay includes additional earnings in kind (DK Article 140(6)). Written rules are our recommendation. VDI says that benefits in kind which count as pay for work are valued in money and included in the data sent to Sodra (VDI FAQ, question 5.1). If no: list who receives which benefit and why.<\/p>\r\n

F. Consulting staff<\/h2>\r\n

13. Were employees informed and consulted before the system was approved?<\/strong> The law: DK Article 140(3). Where the average headcount is 20 or more, a works council is mandatory (DK Article 169(1)) and must be consulted on the system (DK Article 206(1)). No works council is formed if more than 1\/3 of the staff belong to an employer-level trade union (DK Article 169(4)). In a smaller company an elected trustee has the works council's rights (DK Article 177(2)). If no: plan consultation before approval: at least two weeks, or about a month if you have a works council (DK Article 206(2)\u2013(5)). If the council makes a reasoned written request, you cannot approve the system for 15 working days from the first day of consultation, unless another period is agreed (DK Article 204(4)).<\/p>\r\n

14. Have you kept the employees' comments and your reasoned answers on why each was accepted or rejected?<\/strong> The law (where there is a works council or trustee): results of consultation are recorded in a protocol, an agreement or local regulations (DK Article 204(4)); answers must be reasoned (DK Article 204(6)). In other cases this is our recommendation. If no: prepare a protocol form with columns \"comment \u2013 decision \u2013 reason\".<\/p>\r\n

G. Hiring and confidentiality<\/h2>\r\n

15. Does every job ad state the base pay amount or range, matching the group?<\/strong> The law: DK Article 25(6) (except where laws provide otherwise); matching the group is our recommendation. If no: fix the ad template and the instructions to your recruitment agency.<\/p>\r\n

16. Have you removed the question about current or previous pay from interviews and forms, and fixed confidentiality clauses?<\/strong> The law: DK Article 41(1) and DK Article 39(1). If no: delete the question and add an equal-pay carve-out to the confidentiality agreement.<\/p>\r\n

H. Duties from 2027<\/h2>\r\n

17. Does your accountant know each employee's group number for the first report to Sodra?<\/strong> The law: the first report is due by 28 February 2027 (Order No. A1-433, point 2.1; this is a Sunday, so our recommendation is to file by 26 February) and includes the job group number (Description point 7). If no: give the accountant a table \"employee \u2013 job \u2013 group number\".<\/p>\r\n

18. Have you prepared the yearly notice to employees about their right to pay data, and a reply template?<\/strong> The law: notify yearly (DK Article 148(4), edition from 2027-01-01) and reply within one month (DK Article 148(5), edition from 2027-01-01). Employees may request monthly data from 1 March 2027 and annual data from 1 March 2028 (Order No. A1-433, point 2.3). If no: put a responsible person and a date in the annual calendar.<\/p>\r\n

I. The evidence file<\/h2>\r\n

19. Is there a written objective reason for every pay difference within the same group?<\/strong> The law: once an employee states facts from which discrimination may be presumed, the employer must prove there was none (DK Article 26(5)). If no: list the gaps and write a reason or a correction plan for each.<\/p>\r\n

20. Are the system, the evaluation table, the consultation protocol and the reasons for pay decisions kept in one folder?<\/strong> Recommendation. If no: create the folder and name who updates it after every pay decision.<\/p>\r\n

Scoring key<\/h2>\r\n