EEOC Revises Compliance Manual Section on Religious Discrimination

January 21, 2021

On January 15, 2021, the Equal Employment Opportunity Commission (EEOC) voted to approve revisions to EEOC’s Compliance Manual Section on Religious Discrimination.  The Commission had not updated the Compliance Manual since 2008. 

Some noteworthy issues addressed in the Compliance Manual include:

  • A discussion of the religious organization exemption in Title VII and the ministerial exception;
  • A discussion of reasonable accommodations, including a section on common methods of accommodation in the workplace;
  • A discussion regarding the cooperative information-sharing process between employer and employee for religious accommodation requests similar to the “interactive process” used for disability accommodation requests under the Americans with Disabilities Act; and
  • Special considerations for employers when balancing anti-harassment and accommodation obligations with respect to religious expression, including employer and employee best practices.

The Compliance Manual is designed to be a practical resource for employers, employees, practitioners, and EEOC enforcement staff on Title VII of the Civil Rights Act of 1964’s (Title VII) prohibition against religious discrimination.  The guidance explains the variety of issues applicable to religious discrimination claims, discusses typical scenarios in which religious discrimination may arise, and provides guidance to employers on how to balance the needs of individuals in a diverse workplace.

For additional resources on the EEOC requirements, visit AGC Labor & HR Topical Resources webpage. The primary category is “EEO” and the secondary category is “Affirmative Action/EEO.” Please remember to sign in with your AGC credentials to access all the resources available.

For more information, contact Claiborne Guy at or 703-837-5382.

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