What Employers Should Know About Reasonable Accommodations

As the EEOC regains its ability to vote on key policies, one area employers should keep a close eye on is reasonable accommodations - especially when it comes to religion and pregnancy.

Although some federal interpretations may shift, employers still have a legal duty to accommodate qualified needs under the law. And with new regulations like the Pregnant Workers Fairness Act (PWFA) now in play, there’s more complexity, not less.

Here’s what you need to know to keep your accommodation processes clear, compliant, and defensible.

Two Key Areas of Focus

1. Religious Accommodations

• In light of recent Supreme Court decisions and rising scrutiny, employers may face more requests - and more legal challenges - related to religious accommodations.

• These requests can cover everything from schedule changes to exemptions from certain training (including DEI-related content).

• Employers must evaluate requests carefully and cannot deny them unless they can show “undue hardship” - a standard that’s been redefined to be more favorable to employees.

2. Pregnancy and Reproductive Health

• The PWFA, effective since mid-2023, expanded employer responsibilities to accommodate conditions related to pregnancy, childbirth, and related medical conditions.

• New EEOC rules interpreting the PWFA are now under review and may narrow or redefine what employers must offer, but state and local laws may still impose broader requirements.

• Employers should continue to provide reasonable accommodations for pregnant workers unless doing so would cause undue hardship, and ensure managers understand how to respond to requests without delay or bias.

Tips for Staying Compliant (and Compassionate)

Even in an evolving legal landscape, these best practices still apply:

• Refresh your accommodation policies and toolkits - make sure they reflect the latest federal, state, and local guidance.

• Train managers and HR teams on how to recognize accommodation requests, respond promptly, and engage in an interactive process.

• Maintain documentation throughout the request and review process, including reasons for any denials.

• Avoid blanket denials or assumptions - each request should be evaluated individually.

• Be mindful of retaliation risks - ensure employees feel safe when requesting accommodations.

Accommodations Aren’t Just Compliance - They’re Culture

Being responsive to employee needs is a signal that your workplace is inclusive, supportive, and respectful. Whether it’s a request for schedule flexibility due to religious observance, or lighter duties during pregnancy, a thoughtful approach builds trust and reduces legal risk.

While the EEOC’s stance on some accommodation-related rules may evolve, your core responsibilities remain unchanged. Employers should stay agile, update internal processes, and prepare for a potentially higher volume of accommodation requests - especially in sensitive areas.