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Lithuanian legal update: pay transparency, workplace risks and contracts

Original review: 14 October 2026. Source and editorial check: 3 November 2026.

This review is for employers, HR teams and businesses working in Lithuania. It covers five topics from official announcements published on 8–14 October 2026, separating implementation guidance, case law and awareness campaigns. Use the practical questions below to prepare a focused review of your own documents.

1. Pay transparency: prepare payroll data for SDUP

Source and status: Sodra’s 13 October Q&A and the State Labour Inspectorate’s (VDI) 8 October explanation describe implementation of reporting rules. The announcements are not themselves new legislation.

The first SDUP pay-transparency report covers January 2027 and is submitted in February. Subsequent monthly reports are due by the last calendar day of the following month. Monthly fields include gross pay, additional gross pay and paid hours. Job group, normal weekly hours and working-time arrangement are supplied initially and updated when changed; direct system submissions must include those fields in each report.

Reports can be entered in the employer account, uploaded as JSON or sent through direct integration. Do not assume existing payroll totals transfer unchanged: sickness benefits, severance and compensation for unused annual leave are excluded from SDUP earnings. Annual or three-year publication of additional pay-gap indicators is separate from monthly SDUP reporting.

Practical review: Ask payroll and HR to map each reporting field to its source record and identify who checks adjustments. Read the official scope and exemptions, including the separate arrangements for temporary-agency workers.

Official sources (Lithuanian): Sodra — pay-transparency implementation Q&A, 13 October; State Labour Inspectorate — SDUP reporting, 8 October.

Related service: Employment law.

2. Late final settlement: a reduced award is not a general cap

Source and status: VDI’s 13 October notice discusses existing law and a Kaunas Regional Court ruling of 19 May 2026, case e2A-1169-638/2026.

VDI explains that payments connected with employment are normally settled by the end of employment, subject to permitted arrangements for later settlement. Delay not attributable to the employee can trigger the payment required by Article 147(2) of the Labour Code.

In the reported case, EUR 3,945 in daily allowances remained unpaid. An award of EUR 11,813.76 for delayed settlement was reduced to EUR 3,945 on proportionality grounds. That result is specific to the case: it does not establish an automatic ceiling equal to the debt or permission to delay payment.

Practical review: Put the termination date, agreed settlement terms, outstanding pay and allowances, and actual payment dates on one timeline. Preserve the payment records before seeking advice about the amount claimed.

Official source (Lithuanian): State Labour Inspectorate — payments for delayed settlement and proportionality, 13 October.

Related service: Employment disputes.

3. Psychosocial risks: turn an assessment into action

Source and status: VDI’s 13 October notice presents the EU-OSHA 2026–2028 mental-health-at-work campaign. A campaign announcement does not itself introduce a new statutory duty.

The campaign focuses on recognising and managing psychosocial risks, including harassment, violence and work organisation. It encourages cooperation between employers, managers, workers and their representatives.

Practical review: For each risk recorded in your assessment, identify the preventive measure, responsible person and review date. Check whether employees know how to report a concern and how the organisation will respond. A document without an implementation plan gives the review little practical value.

Official source (Lithuanian): State Labour Inspectorate — psychosocial-risk prevention campaign, 13 October.

Related service: Occupational health and safety.

4. Smart glasses: identify who records and why

Source and status: The European Data Protection Board (EDPB) published its announcement on 13 October; Lithuania’s State Data Protection Inspectorate (VDAI) explained it on 14 October. The EDPB statement provides preliminary guidance, not a new regulation.

Professional use of smart glasses can make the user a data controller. Cameras and microphones may record people who do not realise recording is taking place. The EDPB stresses visible, understandable recording signals; those signals alone do not establish that the recording is lawful. Manufacturers and linked-service providers retain their own data-protection responsibilities.

Practical review: Before workplace use, document the purpose, people likely to be recorded, where recordings go, who can access them and how long they are needed. Assess the legal basis and how affected people will be informed.

Official sources: EDPB — smart-glasses statement announcement, 13 October (English); State Data Protection Inspectorate — explanation, 14 October (Lithuanian).

Related service: GDPR and data protection.

5. Creditor claims and construction payment retention

Source and status: The Supreme Court of Lithuania’s announcements of 8 October summarise two rulings of 7 October. These are case-law developments, not new statutes. The announcements are summaries, not the full judgments.

Creditor claims after divorce proceedings

In case e3K-3-121-943/2026, non-participation in divorce proceedings did not by itself prevent a creditor from bringing a separate claim where the divorce judgment had not decided that creditor’s rights and obligations. Admitting a claim is not the same as deciding that the debt is owed.

Practical review: Obtain the earlier judgment and identify exactly which obligations it decided before choosing a procedural route.

Official source (Lithuanian): Supreme Court — separate creditor claims, case e3K-3-121-943/2026.

Payment retention after a construction contract ends

In case e3K-3-120-1075/2026, early termination did not automatically extinguish a contractual right to retain payments as security for warranty obligations. The contractual terms and handover date mattered. However, the applicable retention period had already expired in this particular case. The ruling therefore does not justify indefinite withholding or create a retention right where none was agreed.

Practical review: Read the retention clause alongside the termination agreement, handover documents and warranty evidence. Separate whether a right exists from whether its time limit is still running.

Official source (Lithuanian): Supreme Court — construction payment retention, case e3K-3-120-1075/2026.

Related service: Civil law and commercial contracts.

Documents to prepare for a consultation

Choose the topic relevant to your situation and prepare a short chronology, the main agreement or policy, its amendments and the records showing what actually happened. State the decision you need to make and any known deadline. These are preparation suggestions, not a substitute for assessing the applicable law and your specific facts.

Contact Opus Justitia about your question. Describe the issue briefly; do not put confidential documents or sensitive details in the enquiry form.

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