Particularly since pandemic-era vaccination requirements, American employers have faced increasing enforcement actions and litigation regarding religious accommodation requests. Additionally, in 2023, the U.S. Supreme Court in Groff v. DeJoy heightened the burden on an employer to show that an accommodation would constitute an undue hardship—clarifying that the employer must show a “substantial” detriment to its overall business. Now, the Trump Administration, through the EEOC’s Acting Chair, Andrea Lucas, has emphasized its priority of “restoring evenhanded enforcement of Title VII—ensuring that workers are not forced to choose between their paycheck and their faith.” In a News Release issued August 22, 2025, the EEOC touted its recent enforcement actions to uphold “religious liberty protections for workers,” including:
Takeaways for Employers
With the EEOC’s increased focus on preventing and remedying religious discrimination at work, employers need to carefully consider their policies and practices for responding to an employee’s sincere request for religious accommodation and/or expression. An employer must not discriminate or take adverse action against an employee because of their religious beliefs or practices; and employers must reasonably accommodate an employee’s religious practice unless doing so imposes an undue hardship—a fact-specific inquiry. When evaluating hardship, an employer must consider, among other things, the cost of the accommodation, any compromises of workplace safety, and the effect of the accommodation on other employees. As demonstrated by the COVID-19 vaccine mandate lawsuits, an overemphasis or incorrect analysis of these factors can result in costly legal consequences. Employers should consult with their legal counsel concerning compliance with evolving standards.
