Pay Transparency System (DAS)

A Pay Transparency System (DAS) is an internal document that defines how salaries are set within a company: job position groups, pay ranges, and the criteria for allowances and bonuses. Under the EU Pay Transparency Directive (2023/970) and the updated Lithuanian Labour Code, a DAS becomes mandatory for all employers in Lithuania, regardless of the number of employees.

By when does the DAS need to be prepared?
The Labour Code amendments take effect on 30 April 2026, and the pay transparency system itself must be prepared or reviewed by 31 December 2026.

What penalties apply if a DAS is not prepared?
Violations related to setting, calculating, or paying wages can result in an administrative fine of EUR 300–1,450 for the company's manager or responsible person (up to EUR 3,000 for a repeat violation).

Can I rely on a template, or do I need a customized document?
We recommend a fully customized document — your DAS should reflect your company's actual job structure and pay practices. A generic template often fails to match the real situation and does not provide adequate protection in the event of an inspection.