Sodra Clarifies Pay Transparency Reporting and New SDUP Submission Rules

The State Social Insurance Fund Board (Sodra) has published official guidelines regarding the implementation of the European Union Pay Transparency Directive (EU) 2023/970 in Lithuania. While initial draft proposals considered an earlier timeline, the adopted legal framework establishes that the reporting obligation enters into force on January 1, 2027. Consequently, employers will be required to submit their first monthly report for January 2027 by February 28, 2027.

By Order No. V-500 of October 5, 2026, the Director of Sodra approved the formal rules for completing and amending the Transparent Wage Report (SDUP). Reports will be submitted via the Electronic Insurer Service System (EDAS). SDUP forms will not require a qualified electronic signature and will be partially pre-filled using data from existing SAM and 2-SD notifications.

Employers will provide data in SDUP at two distinct levels: one-off parameters and recurring monthly figures. One-off information—updated only when changes occur—includes the job position group code or identifier pursuant to the internal remuneration system, the working time regime, and standard working hours. On a monthly basis, employers must declare each employee's actually paid working hours, accrued base gross salary, and additional gross remuneration, including bonuses, allowances, and premiums.

The regulatory framework explicitly excludes specific disbursements from the SDUP reportable wage base. Employers must not include material hardship allowances, sickness benefits (both employer-paid initial days and statutory social insurance benefits), compensation for unused annual leave, or severance payments upon contract termination.

Public disclosure of indicators on the Sodra portal will apply only to entities employing at least 8 individuals, with a minimum of 4 men and 4 women. For qualifying entities, Sodra will publish the average hourly remuneration for men and women, the overall pay gap, median pay gaps, the proportion of employees receiving supplementary compensation, and distribution across wage quartiles. Individual employee metrics and gender pay gap figures segmented by internal job groups will remain strictly confidential, accessible solely to the employer within its EDAS account.

Pursuant to Order No. V-500, if discrepancies or errors are detected in a submitted SDUP form, the employer must rectify them immediately and no later than within 2 business days by resubmitting a corrected report for the entire reporting period. In addition, starting March 1, 2027, employers must respond within one month to any formal employee request concerning gender-disaggregated average pay within their corresponding job category.