From 1 March 2027 any employee may ask in writing for three figures: their own average pay per hour, and the average pay per hour in their job group, separately for men and women. Sodra calculates the figures; you pass them to the employee in writing within one month. When replying to the employee, you do not disclose a named colleague's pay. If a group is so small that an average would reveal one person's pay, the figures go, at the employee's request, only to employee representatives, the State Labour Inspectorate (VDI) or the Equal Opportunities Ombudsperson. Below: deadlines, a sample notice and reply, what not to disclose, and what to do in less common cases.<\/p>\r\n
The full list of duties is in \"Pay transparency in Lithuania: what employers must do, and by when\"<\/a>.<\/p>\r\n The law:<\/strong> from 1 January 2027 an employee has the right to receive in writing data on their annual pay and their average pay per hour per month and per year. Also on the average pay by sex of employees in the same job group as their own position (DK Article 148(4), edition from 2027-01-01).<\/p>\r\n The first dates are set by the minister's order (point 2.3 of Order No. A1-433):<\/p>\r\n What the employee will not<\/strong> get: another group's average or a named colleague's pay. VDI says so plainly (VDI FAQ, question 6.1). Data on an individual employee's pay are given only where the law provides or with the employee's consent (DK Article 148(2)).<\/p>\r\n You do not calculate them. Every month, by the 15th, Sodra calculates and sends employers each employee's and each group's averages by sex for the month before last (Description point 10 of Order No. A1-433). An employee's average is their gross monthly pay, including allowances and bonuses, divided by paid hours (Description point 5.6). Sodra sends the first monthly figures by 15 March 2027 (point 3.1.3 of the order). Employers start giving these data to employees only after Sodra has provided them (Article 23(9) of Law No. XV-969).<\/p>\r\n Sodra calculates from your monthly reports (form SDUP; see \"Monthly SDUP report to Sodra from 2027\"<\/a>). If you did not file the report or gave the wrong group, there will be no figures or wrong ones. That is your problem, not Sodra's.<\/p>\r\n | What | Deadline | Basis | |---|---|---| | Written reply to the employee | Within 1 month of receiving the request | DK Article 148(5) | | Further explanations if the data are inaccurate or incomplete | No longer than 2 months from receiving the original request | DK Article 148(5) | | Data to VDI or the Equal Opportunities Ombudsperson | Within the deadline they set, but no later than 10 working days | DK Article 148(6) |<\/p>\r\n Example.<\/strong> A request arrives on 2027-03-05. Send the reply by 2027-04-05. If the employee asks for explanations, finish them by 2027-05-05.<\/p>\r\n From 2027, failing to give the information to employees carries a fine from four hundred and sixty to seven hundred euros, and a higher one for a repeat breach (ANK Article 99(1) and (2), edition from 2027-01-01).<\/p>\r\n The law:<\/strong> employers must inform employees every year of their right to receive these data and of how they are provided (DK Article 148(4), edition from 2027-01-01). The duty applies whatever the size of the company.<\/p>\r\n Our recommendation:<\/strong> send the first notice in February 2027, before 1 March 2027, the date from which employees may submit requests (Order No. A1-433, point 2.3). Put the same procedure in your work rules. Keep proof that everyone received it.<\/p>\r\n > Notice of the right to receive pay data<\/strong> > > Under Article 148 of the Labour Code every employee has the right to receive in writing their own average pay per hour and the average pay per hour in their job group, separately for men and women. From 1 March 2028 you will also be able to receive annual data. > > You may make a request at any time by email to [address] or in writing to [manager \/ responsible person]. We will reply in writing within one month. If the data look inaccurate, you may ask for explanations. > > You can also receive the data through employee representatives, the State Labour Inspectorate or the Equal Opportunities Ombudsperson. If the data would reveal another employee's pay, at your request we will give them only to employee representatives, the State Labour Inspectorate or the Equal Opportunities Ombudsperson.<\/p>\r\n > Pay data<\/strong> > > Dear [employee], we received your request on 2027-03-05. Here are the figures calculated by Sodra for January 2027: > > - your average pay per hour: [amount]; > - average pay per hour of women in job group [N]: [amount]; > - average pay per hour of men in job group [N]: [amount]. > > The averages are calculated from total gross pay, including allowances and bonuses, divided by paid hours. Your place within the group range was set under the criteria in point [X] of the pay system. > > Under Article 148(8) of the Labour Code, we require you not to use these data, other than the data on your own pay, for any purpose other than exercising the right to equal pay for the same work or work of equal value. Failure to comply may be treated as a breach of work duties. > > If the data seem inaccurate or incomplete to you, you may ask for further explanations. > > [manager, date]<\/p>\r\n The paragraph on use of the data has a legal basis. The law:<\/strong> the employer may require the employee not to use the data received, other than data on their own pay, for any other purpose. Breaching this may be treated as a breach of work duties (DK Article 148(8), edition from 2027-01-01). The data are provided in line with the GDPR (DK Article 148(9), edition from 2027-01-01).<\/p>\r\n The law:<\/strong> if the data would directly or indirectly reveal the pay of another identifiable employee, they are given, at the employee's request, only to employee representatives, VDI or the Equal Opportunities Ombudsperson. If these find a gap of at least 5 percent in the group, they tell the employee without revealing colleagues' pay (DK Article 148(7), edition from 2027-01-01).<\/p>\r\n Check every group in advance. Ask: could any average, alone or together with the requester's own pay, reveal or let them work out a colleague's pay? Most often this happens when the other-sex subgroup has 1 person or the requester's own-sex subgroup has 2.<\/p>\r\n Example: a 45-person company.<\/strong> Group III has 5 women and 1 man. One of the women asks. You give her own figure and the women's average to her. The men's average equals one man's pay. At her request you give it only to employee representatives, VDI or the Ombudsperson. Say why in the reply.<\/p>\r\n Example: a 12-person company.<\/strong> A group has two people, a man and a woman. The average for the requester's own sex is their own pay, and the average for the other sex is the colleague's pay. There are no employee representatives, so VDI or the Ombudsperson remain. VDI recommends that the employer justify such a gap on request (VDI FAQ, question 6.5). So have a short explanation ready of what each of the two salaries rests on.<\/p>\r\n Our recommendation:<\/strong> keep a simple table. It helps you meet deadlines and prove that you replied.<\/p>\r\n | Received | Employee | Request | Reply by | Replied | Explanations asked | Explained by | Notes | |---|---|---|---|---|---|---|---| | 2027-03-05 | [position] | Monthly data | 2027-04-05 | 2027-03-18 | \u2013 | \u2013 | Small group: men's average withheld |<\/p>\r\n ...a request comes before 1 March 2027?<\/strong> The right exists in the Code from 1 January 2027, but you give the data only once Sodra has sent them. Our recommendation:<\/strong> register the request and reply in writing that Sodra sends employers the first data, for January 2027, by 15 March 2027. Pass them on as soon as you receive them.<\/p>\r\n ...Sodra's data are missing or late?<\/strong> Reply to the employee in writing within the month that you have not yet received the data, and say when you will provide them. Check whether you filed the SDUP report and gave the right group. If not, correct it. Keep all correspondence.<\/p>\r\n ...the employee asks for a named colleague's pay?<\/strong> Reply that you cannot give it and offer the group averages. A colleague may disclose their own pay when doing so to enforce their own right to equal pay, but the employer does not disclose it without the colleague's consent (DK Article 148(2); the colleague's right: DK Article 39(1)).<\/p>\r\n ...the employee says the data are wrong?<\/strong> Check your SDUP data for that month. If the mistake is yours, correct it and tell the employee. If the data are right, explain what the average consists of and the criteria for their place in the range. You have 2 months from the original request.<\/p>\r\n ...men's and women's averages in a group differ?<\/strong> That is not yet a breach, but the next question is likely to be why. Have an explanation ready from your pay system<\/a> criteria: experience, competence, results. If there is no reason, the gap must be fixed.<\/p>\r\n ...the request comes through VDI?<\/strong> Give the data within the deadline VDI sets, no later than 10 working days (DK Article 148(6), edition from 2027-01-01).<\/p>\r\n Send us your pay system and a list of job groups with headcount by sex (no names). We will prepare the yearly notice, the reply template, the request procedure for your work rules and explanations for small groups.<\/p>\r\n Linden's full solution, from the pay system to informing employees, is at atlygis.linden.lt<\/a>. Check which requirements apply to you: atlygis.linden.lt\/en\/self-check<\/a>.<\/p>\r\n Phone +370 5 212 1506, email info@linden.lt<\/p>\r\nWhat the employee can ask for<\/h2>\r\n
Where the figures come from<\/h2>\r\n
Deadlines<\/h2>\r\n
The yearly notice to employees<\/h2>\r\n
Sample reply to the employee<\/h2>\r\n
What not to disclose: small groups<\/h2>\r\n
Request register<\/h2>\r\n
What to do if...<\/h2>\r\n
Mistakes to avoid<\/h2>\r\n
Checklist before 1 March 2027<\/h2>\r\n
Related articles<\/h2>\r\n
How to start<\/h2>\r\n