When an employee asks for time off to observe their Sabbath, wear religious clothing, maintain certain grooming practices, or modify their work schedule because of their faith, many small business owners and HR professionals ask the same question: Do I have to approve the request?
Although the short answer is "not always," you cannot simply say "no" just because the request is based on religion. Religious accommodation typically means a covered employer must reasonably accommodate an employee's sincerely held religious beliefs, practices, or observances unless doing so would impose an undue hardship on the business.
A recent lawsuit filed by the U.S. Equal Employment Opportunity Commission (EEOC) highlights why employers should approach these requests carefully. While not every accommodation must be approved, employers who fail to evaluate requests appropriately may expose themselves to costly employment disputes, win or lose.
Title VII of the Civil Rights Act of 1964 prohibits covered employers from discriminating against applicants or employees because of religion.
It also requires employers to provide a reasonable accommodation for an employee's sincerely held religious beliefs or practices unless doing so would create an undue hardship on the operation of the business.
This does not mean employers must approve every request exactly as submitted.
Instead, employers should determine:
Per federal law, Title VII typically covers private-sector employers that have at least 15 employees, along with state and local government entities, employment agencies, and labor organizations.
However, even if your business has fewer than 15 employees, state or local laws may impose similar or broader religious accommodation obligations. Some states apply anti-discrimination laws to smaller employers or provide additional protections beyond federal law.
Because these requirements vary, small business owners should understand both federal and applicable state laws before responding to a request.
A religious accommodation is a change to a workplace rule, policy, or practice that allows an employee to observe a sincere religious belief without creating an undue hardship for the employer.
Examples of common religious accommodations include:
The accommodation does not have to be the employee's preferred solution if another effective accommodation is available.
A recently filed EEOC lawsuit demonstrates why employers should carefully evaluate accommodation requests before making employment decisions.
According to the lawsuit, an assistant store manager had successfully worked under a schedule that accommodated his Jewish Sabbath observance of not working Saturdays for several months. When a newly assigned store manager took over, the employee was told assistant managers had to work Saturdays.
The EEOC alleges that this violated Title VII because the employee was penalized for observing his religion.
Although no final determination has been made yet (Dollar General still has the opportunity to respond to allegations in court), the lawsuit serves as an important reminder that employers should not assume operational preferences automatically outweigh religious accommodation obligations.
While the law requires employers to provide a reasonable accommodation, it does not necessarily mean the employee's preferred accommodation for religious observances must be granted.
If multiple effective solutions exist, the employer may choose the option that best fits the business. And, as stated above, employers are not required to provide an accommodation that creates an undue hardship.
The key is that the decision should be based on an objective evaluation rather than assumptions, stereotypes, or personal opinions about the specific religion or religion in general.
In 2023, the U.S. Supreme Court clarified the standard for undue hardship in Groff v. DeJoy. In this case, the Court held that an employer may deny a requested workplace religious accommodation only if granting it would impose substantial increased costs in relation to the conduct of its particular business. In other words, employers must be able to demonstrate more than minor inconvenience or administrative difficulty before determining that an accommodation creates an undue hardship.
Examples of how to establish undue hardship might include:
Minor inconveniences, coworker dissatisfaction, or a manager's personal preference are generally insufficient on their own.
Even though Title VII does not require the same formal interactive process required under the Americans with Disabilities Act (ADA), following a collaborative approach is a best practice.
When an employee requests a religious accommodation:
Taking time to evaluate the request demonstrates good faith and can help reduce legal risk.
Many religious discrimination claims arise because a request was handled too quickly or inconsistently. To avoid the appearance of discrimination, avoid:
Consistency is one of the strongest protections against discrimination claims.
Employees don't always use legal terms when asking for an accommodation. A statement such as, "I can't work Saturdays because of my faith," or "I need time to pray during the day," may be enough to trigger the employer's obligation to consider an accommodation.
Managers should know when to elevate these requests to HR or business leadership rather than making an immediate decision on their own.
Although not all employers have to honor religious accommodation requests, most covered employers do have a legal obligation to at least consider them.
While Title VII requires employers to make reasonable efforts to accommodate an employee’s sincerely held religious beliefs or practices, they are not required to provide an accommodation that would create an undue hardship for the business. This means employers should evaluate each request individually, explore reasonable solutions, and base decisions on legitimate business needs rather than assumptions about an employee's religious practices or faith.
The EEOC's 2026 lawsuit against Dollar General is a timely reminder that religious accommodation remains an active area of enforcement. Whether or not the employer ultimately prevails, the allegations underscore the importance of treating accommodation requests seriously, documenting the decision-making process, and training managers on their responsibilities. Simply avoiding the required preparation for time in court should be incentive enough to consider reasonable religious accommodations.
For small business owners, taking a thoughtful, consistent approach to religious accommodation requests isn't just about complying with the law; it also helps build a respectful workplace, strengthen employee trust, and reduce the risk of costly employment disputes.
Need help with your situation? Contact your certified Stratus HR expert or book a free consultation today.