The new Labour Code rules apply to every employer, whatever its size. Pay systems must be ready by 31 December, monthly reporting to Sodra starts in February, and from March employees can ask for the average pay of women and men in their job group.
Key dates
The March 2027 publication is expected; the first release covers January 2027 data.
Every employer needs an approved pay system with job groups, pay ranges and rules for allowances and bonuses. From 50 employees, it must also set criteria for pay rises.
Positions are grouped by skills, qualification, effort, responsibility and working conditions. The same work, or work of equal value, goes into the same group.
Before the pay system is adopted or changed, employees are informed and consulted, and the system is made available to all of them.
In pay discrimination cases, pay includes any reward in cash or in kind, so benefits and gift cards count too.
From January 2027, every employer files a monthly SDUP report to Sodra with each employee's pay, including pay in kind, paid hours and job group. The first report is due by 28 February 2027.
From 1 March 2027, any employee can ask for their own pay and the average pay of women and men in their job group. You reply in writing within one month and tell all employees about this right every year.
You may not ask candidates about their current or previous pay.
Employees may disclose their own pay to claim equal pay, and a contract cannot forbid it.
With more than 20 employees, the works council or trade union can ask for yearly anonymised average pay by job group and gender.
If unequal pay is found, the employee recovers the unpaid pay and payments in kind, plus damages and lost opportunities.
Sodra calculates the pay gap indicators for you: mean and median gaps, quartiles and gaps by job group. Employers with 150 or more employees receive the first indicators by 1 March 2028, those with 100 to 149 by 1 March 2031.
If a job group shows a gap of 5% or more that you cannot justify and do not correct within six months, you carry out a joint pay assessment with employee representatives.
By number of employees
In 100 planned inspections at companies with the largest pay gaps, the State Labour Inspectorate found no direct discrimination. The same weak spots kept coming up:
Most companies had no written criteria for hiring or for evaluating work, which leaves room for subjective decisions.
Some pay systems did not set minimum and maximum pay per position and qualification.
Allowances, bonuses and pay indexation were granted without written rules.
Many companies had no procedure for improving employees' qualifications.
Source: State Labour Inspectorate, equal opportunities supervision results for January to October 2025.
Read the inspectorate's summaryOur partner Amber Axis helps you build or review your pay system, group positions and justify existing pay differences before employees start asking.
MELP is building a module that publishes your pay and benefit rules, sends the yearly notice of rights, handles employee requests on time and keeps a dated record. Developed in cooperation with Eligijus Kajieta.
Yes. Every employer needs an approved pay system, whatever its size. Employers with fewer than 50 employees do not have to set criteria for pay rises, but everything else applies, including monthly reporting to Sodra from 2027.
A group of positions doing the same work or work of equal value, judged by skills, qualification, effort, responsibility and working conditions. Each employee's job group number is reported to Sodra every month.
Yes. In pay discrimination cases, pay includes rewards in kind. In the monthly SDUP report, pay in kind can be left out only when every employee in the job group receives the identical benefit, such as the same meal voucher or Christmas gift card. Income that is not subject to social and health insurance contributions is not reported.
From 1 March 2027, you reply in writing within one month with the employee's own pay and the average pay of women and men in their job group, using the figures Sodra sends you. If the answer would reveal an identifiable colleague's pay, the figures go to employee representatives, the State Labour Inspectorate or the Equal Opportunities Ombudsperson instead.
Employers that receive Sodra's gap indicators must correct unjustified differences within six months. If a gap of 5% or more remains in any job group, a joint pay assessment with employee representatives is required. In a dispute, an employee can recover unpaid pay, payments in kind, damages and lost opportunities.
Not yet. Since 13 July 2026, Estonia applies only the recruitment rules: pay information before the interview, no pay-history questions and no pay secrecy. Latvia has a draft law. This page covers Lithuania.
Sources: Labour Code amending law No. XV-969 (in force since 7 June 2026) and order No. A1-433 of the Minister of Social Security and Labour (in force since 31 July 2026). Checked on 21 October 2026.
Law No. XV-969 on e-TAROrder No. A1-433 on e-TARTalk to an expert from our partner Amber Axis. The first call is free.
