How a written policy and defined request process help employees practice their faith without having to guess where to begin.
WHY IT MATTERSA legal right is difficult to use when employees do not know that accommodation is available, what kinds of requests may qualify, or whom to contact. A written policy gives employees a clear path for raising religious needs and gives managers a consistent framework for responding fairly. |
The Core Principle
Employees should not have to choose between their jobs and sincerely held religious beliefs when a reasonable workplace adjustment is available. A strong policy states the company’s commitment, explains the governing standard, provides examples, and identifies a practical request and review process.
This resource focuses on disclosure and process. Because the benchmark is survey-only, the Index evaluates the information a company provides through the survey rather than attempting to infer the contents of internal accommodation procedures from scattered public statements.
What the Score Evaluates
The Viewpoint Diversity Score asks whether the company has a written religious accommodation policy for its workforce and whether that policy explains how employees can request an accommodation. The strongest disclosure addresses five elements:
- A stated commitment to religious diversity and reasonable accommodation;
- A current definition of undue hardship;
- The factors considered when evaluating whether a request creates an undue hardship;
- General examples of accommodations employees may request; and
- A clear process for submitting, reviewing, and responding to requests.
A policy may exist without being sufficiently usable. Employees need both the substantive commitment and a defined route for making a request.
What Strong Policy Language Includes
CLEAR COMMITMENTThe company respects sincerely held religious beliefs and provides reasonable accommodations unless doing so would create an undue hardship. | PRACTICAL GUIDANCEThe policy identifies common accommodation types and explains what information may be needed to evaluate a request. | DEFINED PROCESSEmployees know where to submit a request, what happens next, and how the company will communicate its decision. |
Understanding Religious Accommodation
A religious accommodation is an adjustment to a workplace rule, schedule, practice, or job requirement that allows an applicant or employee to observe or practice a sincerely held religious belief. Religion is not limited to traditional or organized faiths and may include sincerely held religious, ethical, or moral beliefs that occupy a place in the individual’s life comparable to that filled by traditional religious beliefs.
Common accommodations may include:
- Schedule changes, shift swaps, flexible arrival or departure times, or leave for religious observance;
- Exceptions to dress, grooming, or uniform requirements;
- Time or space for prayer or religious practice;
- Adjustments involving food, workplace events, training, or other activities that conflict with a sincerely held belief; and
- Other reasonable changes developed through an individualized discussion.
The appropriate response depends on the employee’s request, the job, and the practical effect of the accommodation. The process should be individualized rather than based on assumptions about a particular religion or practice.
What “Undue Hardship” Means
Under Title VII, an employer may deny a religious accommodation when granting it would create an undue hardship on the conduct of the employer’s business. In Groff v. DeJoy, the U.S. Supreme Court clarified that a minor inconvenience or more-than-minimal cost is not enough. An employer must show that the burden of granting the accommodation would result in substantial increased costs in relation to the conduct of its particular business, taking into account all relevant factors in the particular case.
That assessment should consider the specific request, the nature and size of the employer, its operating costs, and the practical effect of the accommodation. Coworker preferences or objections, standing alone, do not establish undue hardship; effects on coworkers are relevant to the extent they affect the conduct of the employer’s business. Hostility toward an employee’s religious practice or toward religious accommodation is not a legitimate basis for establishing undue hardship.
Relevant considerations may include substantial costs associated with the accommodation, effects on business operations or workplace safety, applicable legal obligations, bona fide seniority rights, and whether another reasonable accommodation could avoid the identified hardship.
IMPORTANT DISTINCTION
An employer generally need not provide the employee’s preferred accommodation if another reasonable accommodation effectively resolves the conflict between the employee’s religious practice and the work requirement.
Model Religious Accommodation Policy
The model below combines the elements employees and managers need in one place. It is intended as a general framework and should be adapted to applicable law, the employer’s operations, and existing accommodation procedures.
MODEL RELIGIOUS ACCOMMODATION POLICY1. Commitment [Company] respects the sincerely held religious beliefs, observances, and practices of applicants and employees. We provide reasonable religious accommodations unless doing so would impose an undue hardship. 2. Undue hardship An undue hardship exists when a proposed accommodation would impose substantial increased costs in relation to the conduct of [Company]’s particular business. The determination will consider all relevant factors in the particular circumstances, including the nature and cost of the accommodation and the employer’s operations. 3. Individual assessment Requests will be considered based on their particular facts and circumstances. Relevant factors may include cost, safety, operational requirements, applicable legal obligations, and available alternative accommodations. Before denying a request, [Company] will ordinarily discuss the request with the employee and consider whether another reasonable accommodation could resolve the conflict without imposing an undue hardship. 4. Examples Accommodations may include schedule adjustments, leave, shift swaps, prayer time or space, dress or grooming exceptions, dietary adjustments, or other reasonable changes related to a sincerely held religious belief. 5. Request and review process Employees may submit a request to [Human Resources, manager, or designated office] verbally or in writing. The company will discuss the request with the employee, seek only information reasonably needed to evaluate it, consider effective alternatives, and prohibit retaliation for requesting an accommodation. The company will communicate its decision in a timely manner and, where appropriate, in writing. |
A Five-Step Policy Review
1. Confirm the policy is written and accessible. Employees and managers should be able to locate the policy without relying on informal knowledge or discretionary practice.
2. Update the legal standard. Replace outdated undue-hardship language and ensure decision-makers understand the current substantial-burden standard.
3. Make the process concrete. Identify who receives requests, how they may be submitted, what information may be requested, and when employees should expect a response.
4. Train managers and reviewers. Front-line managers should know how to recognize a possible request, avoid dismissing it prematurely, and refer it to the appropriate decision-maker.
5. Review outcomes for consistency. Track requests and decisions to identify unnecessary delays, inconsistent treatment, or recurring barriers that could be resolved through better policy design.
Frequently Asked Questions
Why is this benchmark survey-only? |
Many companies keep detailed accommodation procedures in internal handbooks or HR systems that are not publicly available. The survey gives companies a direct way to disclose whether a written policy and request process exist without requiring confidential personnel materials to be published. |
Must an employee use special legal language to request an accommodation? |
No. An employee generally need not use particular legal terminology, but should provide enough information to make the employer aware that a work requirement conflicts with a religious belief, practice, or observance. |
May a company ask for supporting information? |
Sometimes. When an employer has an objective basis for questioning either the religious nature or sincerity of the asserted belief, practice, or observance, it may seek information reasonably needed to evaluate the request. |
Does the company have to grant every requested accommodation? |
No. The company may consider effective alternatives and may deny an accommodation that would impose an undue hardship under the applicable legal standard. The decision should be based on the actual circumstances rather than speculation or generalized objections. |
What should happen if the initial request cannot be granted? |
The company should discuss alternatives with the employee, explain the basis for its decision, and consider whether another reasonable adjustment would resolve the conflict. |
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Source note: This resource reflects the 2026 survey-only benchmark for a written religious accommodation policy and process and current federal guidance concerning religious accommodation and undue hardship.
Disclaimer: The information contained in this document is general in nature and is not intended to provide, or be a substitute for, legal analysis, legal advice, or consultation with appropriate legal counsel. You should not act or rely on information contained in this document without seeking appropriate professional advice. By printing and distributing this document, Alliance Defending Freedom is not providing legal advice, and the use of this document is not intended to constitute advertising or solicitation and does not create an attorney-client relationship between you and Alliance Defending Freedom or between you and any Alliance Defending Freedom employee.
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