November 6, 2025
Regarding the Draft Law on Amendments to the Law on Excise Duty No. XVP-855
November 4, 2025
November 3, 2025
Regarding the Draft Law on the Amendment to the Law on the Legal Status of Foreigners
October 8, 2025
October 7, 2025
Regarding Draft amendment to the Government’s opinion on the Law on Competition
October 7, 2025
Regarding Reorganization of the Commission on Energy and Sustainable Development into a Committee
29 September 2025
Regarding the ex post evaluation report of PVK and APVK measures
Investors’ Forum proposed to the Ministry of Social Security and Labour to review the Employment Law measures, especially those aimed at acquiring high value-added qualifications (PVK) and support for starting a business (APVK).
Our proposals:
Assess the effectiveness of the measure by participants’ actual career progression (whether after the programme they move to higher value-added jobs), rather than by the formal “employed / unemployed” status.
Maintain eligibility for employed persons as well, since this promotes upskilling and labour-market mobility.
Simplify application and focus on actual labour-market outcomes, not formal categories.
29 September 2025
Approval of part of the proposed amendments
Investors’ Forum submitted proposals to the Ministry of Energy regarding several legislative amendments to increase Lithuania’s competitiveness and attract more investors.
We supported amendments to the Law on Electricity to reduce investors’ grid-connection costs. The investor would cover only 10%, and the remainder would be spread over 10 years. We also proposed creating a reserve of grid equipment to shorten connection times from years to months, and applying a fast-track principle for works. In our view, these changes would help attract high value-added manufacturing, data-centre, and battery projects.
We supported amendments to the Energy Law to simplify requirements for foreign contractors and workers so that Lithuanian certificates would no longer be required and civil-liability insurance would suffice. This would enable faster project delivery and reduce administrative burden.
We cautioned that the costs of the grid-equipment reserve should not be passed on to businesses or consumers through electricity tariffs, to avoid harming competitiveness.
We proposed not applying the capacity component to balancing storage facilities and public EV charging stations so these sectors can develop faster and more efficiently.
29 September 2025
Regarding the Carbon Border Adjustment Mechanism
Investors’ Forum, together with Lithuanian business and industry confederations, addressed the Ministry of Environment to stress the need for caution when considering an expansion of the EU Carbon Border Adjustment Mechanism (CBAM):
We emphasised that any expansion should be based on a thorough impact assessment and coordinated with industrial sectors. A rushed expansion could raise costs and harm the competitiveness of European industry.
We proposed maintaining existing carbon-leakage protection measures such as free emission allowances and financial compensation for energy-intensive sectors. In our view, CBAM should complement rather than replace these measures.
We urged detailed sectoral analysis and the provision of financial support for industrial decarbonisation and innovation to preserve competitiveness and ensure a just transition to a green economy.
We warned about growing CBAM circumvention risks when third-country producers change product classifications to avoid charges, and proposed proportionate, risk-based preventive measures that do not increase administrative burden for EU companies.
September 22, 2025
Open Letter from Associations to the President
Investors’ Forum addressed the President of the Republic of Lithuania, Gitanas Nausėda, inviting him to support Žygimantas Vaičiūnas for the position of Minister of Energy.
We stressed that critical processes are under way in the energy sector that require continuity: implementation of EU-funded energy-infrastructure protection projects, continuation of renewable-energy programmes, and preservation of investor confidence.
We highlighted that a change of minister would stall ongoing work, especially discussions on market regulation and new mechanisms such as Contracts for Difference that are needed for investment in electricity generation.
We noted that in the coming years Lithuania must transpose the EU electricity-market reform decisions that ensure price stability and investment attractiveness, therefore the Ministry of Energy needs stability.
We called for the continuation without disruption of the reforms already started: prosumer expansion, transport electrification, the DAEI system, and the debureaucratisation programme in the energy sector.
We underlined that Žygimantas Vaičiūnas’ work is positively assessed by the energy community; given the continuity of the Government’s programme, we proposed entrusting him with its implementation.
September 12, 2025
Regarding the procedure for concluding contracts with the NHIF
Investors’ Forum submitted comments to the Ministry of Health and the National Health Insurance Fund on the draft description of the new procedure for concluding contracts with healthcare providers.
We emphasised that the proposed deadline for new providers to submit applications is too short and depends on NHIF actions, which complicates planning. We proposed keeping the previous deadline of 1 November.
We expressed concern that the draft sets entry requirements for new providers that are too high. Such restrictions would in practice block new entrants, reduce competition, and limit patients’ options to receive services close to home. We proposed keeping the current thresholds.
We stressed that the draft does not explain how the NHIF would assess existing and new providers or decide whose service volumes to increase. Such uncertainty creates a risk of subjectivity, so we proposed setting clear and uniform evaluation criteria for all providers.
We underlined that the goal should be a competitive and sustainable healthcare system in which public and private sectors operate under the same conditions, ensuring quality, accessible, and timely services for patients.
September 8, 2025
Regarding PSPĮ project No. 25-13142
Investors’ Forum submitted comments to the Ministry of Social Security and Labour on the draft amendments to the Law on Cash Social Assistance for Low-Income Residents (PSPĮ).
We proposed that unused municipal assistance funds be directed first to increasing employment — training, reskilling, and labour-market integration. This would encourage people to return to work and reduce dependency on benefits.
We urged stronger control of undeclared work, mandatory municipal cooperation with competent authorities, and a clear rule that assistance to persons working illegally is discontinued.
We proposed supplementing the explanatory note with factual data on how many persons lost assistance due to undeclared work in order to assess the effectiveness of control.
We requested data on how much state and EU funding is allocated to benefits versus active labour-market measures to ensure a balance between passive benefits and active engagement in the labour market.
September 3, 2025
Regarding the Representation of Lithuania’s Interests at the Tobacco Conference
Investors’ Forum addressed members of the Government of the Republic of Lithuania regarding Lithuania’s positions and representation of interests at the 11th World Health Organization Tobacco Control Conference.
We emphasised that Lithuania’s position should be coordinated with all stakeholders, including business organisations, to ensure transparent and comprehensive interest representation.
We highlighted that drastic regulatory restrictions, including bans on new products and additional fiscal obligations, may negatively affect Lithuania’s economy, industry, and competitiveness. We proposed conducting comprehensive economic and social impact assessments before taking such decisions.
We stressed that decisions and commitments adopted at the conference cannot exceed the limits of EU law and must be coordinated with all Member States.
We warned that Lithuania should maintain a principled position and not yield to the influence of authoritarian states that may arise at international events such as the WHO conference.
September 1, 2025
To the Ministry of Economy and Innovation of the Republic of Lithuania
Regarding the package of draft laws (amendments to the Investment Law and the Land Law)
Investors’ Forum expressed support for the draft amendments to the Investment Law and the Land Law, as they improve the investment environment in Lithuania.
Proposed measures such as a simpler procedure for land lease and acquisition and preferential conditions for large-scale projects will increase Lithuania’s attractiveness to investors.
We believe these changes will contribute to regional development, job creation in high value-added sectors, and will strengthen Lithuania’s international competitiveness.
Once adopted, the amendments will create more favourable conditions for both foreign and domestic investors, generating benefits for the state.
August 1, 2025
Investors’ Forum expressed support for the draft amendment to the Government resolution, as it improves the export-control system in Lithuania and ensures more effective enforcement of sanctions.
Proposed measures such as the exporter’s declaration and a goods identification system will reduce administrative burden and make control mechanisms more effective.
We believe these changes will contribute to a more transparent and flexible export process, increase Lithuania’s competitiveness in international markets, and foster the growth of responsible businesses.
Once adopted, the amendments will create more favourable conditions for both foreign and domestic exporters, benefiting Lithuania and ensuring a more sustainable control system.
July 30, 2025
Regarding the Public Procurement Law
Investors’ Forum expressed support for the draft amendments to the Public Procurement Law, as they would reduce administrative burden and improve public-procurement processes in Lithuania.
Proposed measures such as removing the national-security compliance declaration will reduce the burden on contracting authorities and ensure a more efficient process.
We believe these changes will make public procurement simpler and more transparent, reduce cases and disputes, and improve court efficiency.
Once adopted, the amendments will create more favourable conditions for both foreign and domestic suppliers and enable more efficient use of public resources.
July 29, 2025
Regarding the Review of the Tobacco Excise Duty Directive and the General Excise Duty Directive
Investors’ Forum submitted its position and proposals on the review of EU excise duties for tobacco and nicotine products.
Limits of delegated commitments
Investors’ Forum did not support pre-aligning taxes for all tobacco and nicotine products, as this is not the purpose of the directive and does not fit the logic of the internal market.
– We propose limiting the scope to internal-market arguments.
– Set a stable review periodicity.
– Apply indexation only for inflation.
Sudden tariff increases
We warned that very rapid and large increases of minimum taxes would trigger price shocks and encourage the shadow economy.
– We propose a gradual approach with transitional periods.
– Apply differentiated, well-founded taxation to different product groups.
– The goal is to protect budget revenues and limit inflation.
Application of the PPP principle
Investors’ Forum supports the purchasing power parity (PPP) principle, because the same euro tax implies different burdens across countries.
– PPP reduces market distortions and shadow-economy risk.
– It ensures fairer convergence and a lower financial burden for EU contributions.
– We propose a stronger PPP correction.
Indexation based on core inflation
Investors’ Forum proposes indexation based on core, not headline, inflation.
– This is a more stable base because it removes temporary energy and food shocks.
– Economic “ceilings” are needed to avoid extreme spikes.
– This principle is already applied in other EU tax projects.
Transfer of national revenues to the EU budget
Investors’ Forum did not support the idea of transferring part of tobacco revenues to the EU multiannual programme.
– It would reduce funds for public services and for combating smuggling.
– It would weaken border control and competitiveness.
– It would contradict the logic of cohesion and solidarity.
June 19, 2025
Investors’ Forum proposed not to require re-notification of residents for wind-farm projects that have already started.
If, prior to the law’s entry into force, notification steps have been taken, permits obtained, or applications submitted, re-notification is unnecessary.
This would protect legitimate expectations and investments and ensure legal certainty and continuity.
Otherwise there would be legal uncertainty and restrictions on freedom of economic
June 16, 2025
Cover Letter; Proposals regarding te Draft Law No. XVP-436 amending the Law on Personal Income Tax of the Republic of Lithuania
Our goal is a simpler and predictable PIT (Personal Income Tax) system that encourages work, philanthropy, and investment.
Labour income rates
We proposed not introducing a new additional rate for the middle income bracket.
– Such a rate would disproportionately raise the cost of labour and reduce competitiveness.
– The impact would be especially negative for high value-added sectors.
Inherited shares
We proposed that income from selling inherited shares should not be deemed “speculation” solely due to the holding period.
– We propose removing a mandatory holding period in inheritance cases.
– This would ensure business continuity in families and avoid discrimination.
Philanthropy (donation relief)
We proposed a clear PIT relief for individuals’ donations to NGOs.
– This encourages civic engagement and NGOs’ financial independence.
– The relief would be capped to remain targeted and transparent.
Supplementary health insurance
We proposed raising the non-taxable ceiling for employer-paid voluntary health insurance and broadening covered services.
– Include non-reimbursed services such as dentistry and vision.
– This would shorten queues and speed up return to work.
Investments in start-ups: profit exemption
We proposed exempting profits when an individual sells, after a longer holding period, shares of an early-stage innovative company, provided the individual had no control.
– Clear conditions should apply regarding company size, activity, and holding period.
– The aim is to attract private capital to technology growth.
Carry-forward of investment losses
We proposed allowing financial-instrument losses to be carried forward to future years and offset against future income.
– This is fair to taxpayers and aligns with general tax principles.
– Separate limits would apply to the start-up relief to prevent abuse.
Investment deduction from income
We proposed allowing individuals to deduct from taxable income direct investments in new shares of young innovative companies.
– A longer holding period would be required and the investor must not be a dominant shareholder.
– This would replicate successful international practice and broaden the pool of private investors.
June 10, 2025
Request for the formation of a Working Group and a meeting to discuss draft legislation
Investors’ Forum addressed the Prime Minister regarding the health-care reform process and requested a transparent and inclusive process.
We asked to postpone submission of the draft until the working group prepares recommendations.
We proposed forming a broad working group: patients, medical professionals, academia, state institutions, and public and private health-care providers.
We requested a meeting to present compromise proposals and discuss implementation.
June 10, 2025
Investors’ Forum expressed disagreement with the proposal that would require employers to inform “Sodra” about an employee’s illness and submit data via the “Sodra” information system.
The additional requirement for employers to inform “Sodra” about an employee’s illness will create extra administrative burden, since employers can currently grant paid sick days without a medical certificate.
Although the goal was to reduce administrative burden for health-care professionals, this change simply shifts the burden to employers.
We propose first piloting these changes in the public sector and only after impact evaluation consider applying them in the private sector.
June 9, 2025
At the 9 June meeting, decisions were taken only on proposals by Members of the Seimas, while proposals from civil-society groups were ignored.
This violates principles of openness and transparency, as civil-society groups did not have a genuine opportunity to participate in decision-making.
We proposed that the Commission investigate whether law-making procedures were violated and oblige the committee to provide a response regarding the ignoring of proposals.
June 3, 2025
Regarding the draft order HN33 2025
Investors’ Forum submitted comments on amendments to HN 33 (Lithuanian hygiene norm “Noise limit values in residential and public buildings and their surroundings”).
Our proposals:
Application and transitional periods: apply stricter limits only to new objects from 2028; apply more lenient limits to existing ones; set a transitional period for transport noise until 2040.
Proportionality and alignment: before entry into force, conduct an independent economic impact assessment; align limits with the EU average to avoid excessive requirements.
Methodology and clarity: adopt practical noise-assessment guidelines, especially for mixed sources, to reduce interpretive differences.
Governance and review: clearly allocate institutional responsibilities for monitoring and control; set a three-year review of the norm.
Space and planning: clarify whether limits apply only to public or also to private children’s playgrounds; expand “quiet zones” to include wellness and rehabilitation facilities; include recommendations for real-estate developers at the design stage.
June 3, 2025
Appeal to the Members of the Seimas (Submission of SSI)
Investors’ Forum expressed its view on the planned amendments to the Law on Environmental Impact Assessment of Proposed Economic Activity of the Republic of Lithuania and related legal acts.
Elimination of patient will autonomy:
We consider that the drafts violate patient rights because they propose that a patient would have to pay the full treatment price rather than only the difference from average service-provision costs, which is incompatible with patient rights.
Lack of consultation with social partners:
We observed that the drafts were not properly coordinated with social partners, especially patient organisations, which were invited not to discuss their comments but only to express an opinion on service remuneration.
Lack of impact assessment:
We also consider that the drafts lack a comprehensive impact assessment, particularly regarding how the changes will affect patients, service accessibility, and working conditions of specialists.
Missing anti-corruption assessment:
We emphasise that the drafts were not submitted with the mandatory anti-corruption assessment required by law, which is a serious gap that cannot be ignored.
May 29, 2025
Investors’ Forum submitted comments to the Ministry of Environment on amendments to the EIA law and related acts.
Our proposals:
Competence and deadlines: comments should be submitted only within clearly defined competences; set uniform strict deadlines for all participants; “no response = approval”.
National security: municipalities should not have the power to block projects important to the state or region, strategic infrastructure, or defence.
Legal protection: enshrine the right to challenge in court institutional actions or inaction.
May 9, 2025
Regarding Employer Organizations’ Proposals for the Labor Code. List of prepared proposals
Investors’ Forum addressed members of the Government of the Republic of Lithuania regarding Labour Code amendments to ensure greater flexibility and simplify labour-relations management.
Our proposals:
Extend the probationary period up to 6 months through a collective agreement, providing more flexibility and scope to adapt to labour-market needs.
Notify “Sodra” of an employee’s hiring one hour before the start of work, allowing quick response to unexpected changes and ensuring continuity.
Allow the employer to raise an employee’s salary without written consent if provided for in a collective agreement, simplifying pay-rise processes.
Allow an employee to refuse changed working conditions or working time without fear of dismissal, except in certain exceptional circumstances.
Grant the employer the right to dismiss an employee for important reasons not related to the employee’s fault, with compensation as provided by law.
April 30, 2025
Proposals for the review of the Civil Service Law of the Republic of Lithuania
April 17, 2025
Regarding the Draft Laws on the Elimination of Additional Payments
April 17, 2025
April 2, 2025
April 2, 2025
Regarding Proposed Restrictions on Belarusian Citizens
March 24, 2025
Regarding the Amendment of the Education Law
March 20, 2025
Regarding the Draft Law No. XVP-48 on Amending Article 67 of the Law on Education No. I-1489
March 17, 2025
March 14, 2025
Regarding the amendments to the Forest Law submitted to the Parliament
March 13, 2025
Regarding the planned tax reform
March 3, 2025
Regarding the Law on Amendments to the Law No. 2680 on Ensuring the Minimum Taxation Level of Groups of Entities in the Republic of Lithuania No. XIV-2680 and the Draft Laws Amending Accompanying Laws. Attachment No. 2 Attachment No. 3 Attachment No. 4 Attachment No. 5
February 25, 2025
Regarding the current tax change proposals being prepared by the Ministry of Finance
February 25, 2025
Regarding the draft orders submitted for coordination
February 10, 2025
Regarding the Government Commission
January 21, 2025
Regarding Business Issues Related to Competition Law and Its Implementation
January 14, 2025
