The EU Pay Transparency Directive at Full Throttle

Under the EU Pay Transparency Directive, employers with 100 or more staff must disclose their pay gaps by fixed deadlines: every year for employees of 250 or more, and every three years for 100 to 249 headcount. For those in scope, the run-up to each deadline means compiling the figures, reviewing them, investigating anything unexpected, then submitting.

While most pay transparency plans depend on that long pause between calculating and disclosing, but we're now starting to see a shift, with some countries reducing the length of time between pauses.

For example, Lithuania, one of the few member states to have transposed the directive through Labour Code amendments that took effect on 7 June 2026, has shrunk this timeframe to weeks. Even if you have no employees there, it is worth paying attention, because the directive allows every member state to go further than its minimum and follow the same route. Lithuania is simply the first country to show what the EU Pay Transparency Directive looks like at full speed. 

Lithuania Has Moved the Calculation to the State 

From 1 January 2027, all employers, including those too small for the directive’s reporting duty, must submit monthly pay and working time data to Sodra, the social insurance fund, along with each employee’s job group. Sodra calculates each employee’s average hourly pay and the averages for men and women in each job group. Every month, it sends those figures to the employer, the State Labour Inspectorate and the Office of the Equal Opportunities Ombudsperson. 

Employers can still run the same calculation before they submit. But the data is due by the end of each following month, and Sodra sends its figures to the regulator as well as the employer. The review window is a few weeks, every month. 

Employees Have a Route That Goes Around You 

The EU Pay Transparency Directive gives every employee, regardless of employer size, the right to ask about their own pay and the average pay, by gender, for workers doing the same work or work of equal value. Those requests can also go through workers’ representatives or an equality body. 

Lithuania brings that into force from March 2027 and tightens this process. Employers have one month to respond, which is half the EU Pay Transparency Directive’s maximum. Where an answer would reveal a colleague’s pay, as in a very small job group, the request goes instead to employee representatives, the Labour Inspectorate or the Ombudsperson. They review the figures and tell the employee whether there is a gap of 5% or more, without disclosing anyone’s salary. 

Job Groupings Now Decide What Everyone Sees 

Every figure Sodra produces depends on the job group the employer assigns. The state doesn’t decide which roles are comparable; the employer does. 

That raises the stakes on job evaluation. Lithuania requires every employer to have a formal, gender-neutral pay system by the end of 2026, so any group with a Lithuanian entity needs one, whatever its other countries are doing. A scheme built for Lithuania alone solves this year’s problem and creates the next one as other member states finalise their rules. 

Under Article 4 of the EU Pay Transparency Directive, pay structures must allow the value of work to be compared using objective, gender-neutral criteria, agreed with workers’ representatives where they exist. Those criteria must include skills, effort, responsibility and working conditions. 

For employers with 100 or more staff, a gap of 5% or more in any job group that can’t be objectively justified and isn’t corrected within six months triggers a joint pay assessment, submitted to the Labour Inspectorate. 

A weak grouping doesn’t only fail in a dispute. It produces the wrong number, every month, in front of the regulator. 

Delay Elsewhere Is Not a Reprieve 

It would be easy to treat Lithuania as an outlier. The transposition deadline passed on 7 June 2026, and most member states, including Germany and France, are still behind. That can look like breathing space. 

It isn’t. Legal commentators point out that a missed deadline doesn’t make the directive go away: courts may interpret national law in line with it, and employers should expect more pay questions regardless. Lithuania isn’t so much an outlier as an early look at how quickly the balance can shift once a national system is built. 

The Employers in Control Will Be the Ones Who Looked First 

When the state calculates your pay gaps every month, the only part of the figure you control is the job grouping underneath it. That makes job evaluation the point where pay transparency is won or lost. If your groupings rest on a defensible assessment of value, every official figure is one you can explain. If they don’t, each one is a question you’ll answer after the regulator has seen it. Groupings you trust also make your own gap analysis worth running, before the regulator’s numbers arrive. 

This is the problem RoleEvaluate is built to solve. It evaluates roles against the directive’s four criteria with one consistent scheme, so job groupings reflect the value of the work rather than legacy titles or local habit. The same scheme holds across every country you operate in, so you aren’t rebuilding your approach each time a national law lands. 

Lithuania won’t be the last country to shorten the distance between payroll and the regulator. The employers who stay in control will be the ones whose job groupings were ready before the data started moving. 

To see how RoleEvaluate helps employers build defensible job groupings for pay transparency, watch our defensible pay webinar and our RoleEvaluate demo.