CLIENT ALERT: EEOC Updates Guidance on Religious Objections to COVID-19 Vaccine Mandates

By , | Published On: October 26, 2021

On October 25, 2021, the U.S. Equal Employment Opportunity Commission (EEOC) updated its technical assistance document, What You Should Know About COVID-19 and the ADA, the Rehabilitation Act, and Other EEO Laws, to provide additional guidance to employers on responding to requests for religious accommodations under Title VII of the Civil Rights Act of 1964 (Title VII).  Specifically, the EEOC included responses to the following questions:

  • Do employees who have a religious objection to receiving a COVID-19 vaccination need to tell their employer? If so, is there specific language that must be used under Title VII?
  • Does an employer have to accept an employee’s assertion of a religious objection to a COVID-19 vaccination at face value? May the employer ask for additional information?
  • How does an employer show that it would be an “undue hardship” to accommodate an employee’s request for religious accommodation?
  • If an employer grants some employees a religious accommodation from a COVID-19 vaccination requirement because of sincerely held religious beliefs, does it have to grant the requests of all employees who seek an accommodation because of sincerely held religious beliefs?
  • Must an employer provide the religious accommodation preferred by an employee if there are other possible accommodations that also are effective in eliminating the religious conflict and do not cause an undue hardship under Title VII?
  • If an employer grants a religious accommodation to an employee, can the employer later reconsider it?

The EEOC’s responses can be found in Section L of the document, which is titled “Vaccinations – Title VII and Religious Objections to the COVID-19 Vaccine Mandates.”

For support in responding to requests for religious accommodations from your employees, please email either Molly Evans ( or Dianne Pledgie (  The previously recorded FTLF webinar series, Navigating Medical and Religious Exemptions from a COVID-19 Vaccine Mandate, is also available for purchase.

Ms. Pledgie is a member of the New York and Massachusetts Bars and is not licensed in Washington, DC. Her practice is limited to federal health care matters.