As a reminder for all employers with 15 or more employees, on August 13, 2025, the U.S. Equal Employment Opportunity Commission’s Office of Federal Operations (EEOC/OFO) issued a key decision reinforcing federal obligations to accommodate employees’ religious practices under Title VII of the Civil Rights Act.

This follows the Supreme Court’s 2023 ruling in Groff v. DeJoy, which raised the standard for denying religious accommodations. “Undue hardship” now means a substantial burden, replacing the previous minimal threshold.

Employers must now:

• Conduct a thorough, documented interactive process.
• Justify accommodation decisions with evidence.
• Avoid speculative or generalized hardship claims.

Source References

• Groff v. DeJoy (No. 22-174 (June 29, 2023)
• EEOC – 200 Days of EEOC Action to Protect Religious Freedom at Work (Protecting Federal Employees’ Religious Rights)
• EEOC Issues Three Significant Federal Sector Appellate Decisions

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