Slovakia vs. Lithuania: Early EU Pay Transparency Transpositions Compared

The EU Pay Transparency Directive (Directive (EU) 2023/970) is reshaping how employers across Europe approach compensation. While the directive's transposition deadline was June 7, 2026, a handful of member states moved early. Among them, Slovakia and Lithuania stand out as first movers—each adopting its own national legislation with distinct features. For multinational companies operating in both countries, understanding these differences is not optional; it's a compliance imperative.

This article provides a detailed comparison of Slovakia's Equal Pay Act and Lithuania's Law No. XV-969, highlighting key obligations, penalties, and practical steps to ensure compliance. We'll also explore how HR teams can leverage technology to manage these requirements across jurisdictions.

The EU Pay Transparency Directive: A Quick Recap

Adopted in May 2023, the directive aims to close the gender pay gap by mandating pay transparency and strengthening enforcement mechanisms. Key requirements include:

• Pay transparency in job postings: Employers must disclose the initial salary or pay range in vacancy notices.
• Right to information: Workers can request information on their individual pay levels and average pay by gender for comparable roles.
• Reporting obligations: Employers with at least 100 employees must report gender pay gap data to national authorities.
• Joint pay assessment: If the pay gap exceeds 5% in any category of workers, employers must conduct a joint pay assessment with worker representatives.
• Remedies and enforcement: Workers can claim compensation, and penalties for non-compliance must be effective and dissuasive.

While the directive sets minimum standards, member states can go further. Slovakia and Lithuania have done exactly that, each in its own way.

Slovakia: First to Full Transposition

Slovakia became the first EU member state to fully transpose the directive with its Equal Pay Act, adopted on April 15, 2026, and effective June 7, 2026. The Act goes beyond the directive's minimums in several notable ways.

Key Provisions of the Slovak Equal Pay Act

• Same-sex equal pay protections: The Act explicitly prohibits pay discrimination based on sexual orientation, a broader protection than the directive requires.
• 30-day response window: Employers must respond to pay clarification requests within 30 days—a tighter timeline than the directive's 2-month default.
• Expanded requester base: Not only employees but also employee representatives, the Labour Inspectorate, and the National Center for Human Rights can request pay information.
• Salary history ban: Employers cannot ask about candidates' previous salaries.
• Pay ranges in job postings: All vacancy announcements must include the pay range.
• Objective, gender-neutral criteria: Pay structures must be based on objective criteria, with explicit inclusion of soft skills in job evaluation.

Compliance Timeline

Employers must have compliant pay structures by July 31, 2026—just six weeks after the Act's entry into force. This tight deadline underscores the need for immediate action.

Enforcement and Penalties

While headline fines may seem moderate, the Act's enforcement mechanisms can result in penalties significantly higher than they appear. The Labour Inspectorate and the National Center for Human Rights play active roles in monitoring compliance. Non-compliant employers risk fines that escalate with repeated violations.

Lithuania: A State-Centric Approach

Lithuania adopted Law No. XV-969 on May 21, 2026, with most provisions effective June 7, 2026. Lithuania's approach is unique in several respects, particularly its reliance on state infrastructure to calculate and publish pay gaps.

Key Provisions of Lithuania's Law

• No size exemption: Unlike many member states that exempt small employers, Lithuania applies obligations to all employers, regardless of headcount.
• Monthly data submission: Employers must submit pay data monthly to the State Social Insurance Fund Board (SoDRA).
• Centralized calculation: SoDRA calculates gender pay gap indicators centrally, shifting the burden from employers to the state.
• Public disclosure: SoDRA publishes average hourly pay by gender for employers with at least 8 employees—a transparency measure exceeding the directive's requirements.
• Salary range and history ban: Already in place since 2019, Lithuania required salary ranges in job postings and banned salary history inquiries.

Compliance Timeline

Employers must align their compensation systems by December 31, 2026, with reporting and data-submission obligations beginning January 1, 2027. This gives employers more runway than Slovakia's July 2026 deadline but imposes a heavier ongoing administrative load.

Comparison Table: Slovakia vs. Lithuania

Note: For details not specified in the sources, organizations should verify current regulations.

Practical Compliance Steps for Multinational Employers

Operating in both Slovakia and Lithuania requires a coordinated approach. Here are actionable steps to ensure compliance:

1. Conduct a pay audit: Review your compensation structures to identify and rectify any gender-based disparities. Use objective, gender-neutral criteria, including soft skills, as required by Slovak law.
2. Implement a gender-neutral job classification system: Ensure job roles are categorized consistently, as Lithuania mandates, to facilitate accurate pay gap calculations.
3. Update job postings: Include pay ranges in all vacancy announcements in both countries.
4. Train HR and hiring managers: Educate teams on the new requirements, including the ban on salary history questions and the need for transparent pay communication.
5. Prepare for data submission: In Lithuania, set up systems to submit monthly pay data to SoDRA. In Slovakia, ensure you can respond to pay clarification requests within 30 days.
6. Leverage technology: Use compliance platforms like AIGovHub to track regulatory changes, automate reporting, and manage obligations across jurisdictions.

Key Takeaways

• Slovakia and Lithuania are first movers in implementing the EU Pay Transparency Directive, each with unique provisions.
• Slovakia's Equal Pay Act offers extra protections (same-sex, 30-day response) and a tight July 31, 2026 compliance deadline.
• Lithuania applies obligations to all employers, with state-centralized pay gap calculation and public disclosure.
• Multinationals must adapt quickly, conducting pay audits and updating job postings to avoid penalties.

How AIGovHub Can Help

Managing pay transparency compliance across multiple jurisdictions is complex. AIGovHub's HR compliance tools can help you track regulatory changes, automate reporting, and ensure your compensation practices meet both Slovak and Lithuanian requirements. Our platform provides a centralized hub for all your compliance needs, including interactive checklists and vendor assessments.

Don't wait until the deadlines hit. Start your compliance journey today with AIGovHub.

This content is for informational purposes only and does not constitute legal advice.