California’s reasonable-accommodation requirements apply to most employers with five or more employees, including out-of-state workers if the employer has operations in California. These rules are set by the California Fair Employment & Housing Act (FEHA), found at Gov. Code §12900 et seq. Key terms include:
The statute covers full-time, part-time, seasonal, and temporary employees. It also protects applicants during the hiring process.
Employers must provide reasonable accommodations to qualified individuals with disabilities unless doing so would cause an undue hardship for the business under FEHA (Gov. Code §12900 et seq.). Examples of reasonable adjustments include modified work schedules, unpaid leave, ergonomic workstations, screen readers, and job restructuring. Employers should explore options that empower the employee to perform essential job functions, not just those that are most convenient.
Employers are obligated to engage with employees or applicants proactively once they become aware of the need for accommodation, whether through a direct request or observable need.
California requires a timely, good faith interactive process between employer and employee. This is a collaborative conversation to identify the right accommodation based on an employee's needs. Requests can be made verbally or in writing, and employers can only ask for limited medical documentation if the disability or need for accommodation is not obvious.
While FEHA does not set exact response timelines, courts and the California Civil Rights Department expect prompt action, typically within a few business days. Delays in responding or starting the process can lead to liability, so documentation and timely follow-ups are critical. Employers must notify employees of decisions in writing and document all steps in the process.
Employees who believe their accommodation rights have been violated can file a complaint with the California Civil Rights Department (formerly the Department of Fair Employment and Housing, or DFEH). Complaints must usually be filed within three years of the alleged violation. The agency has authority to investigate and order remedies, such as job reinstatement, policy changes, back pay, or damages for emotional distress. Civil penalties may also be imposed for noncompliance.
Managing accommodation requests under California Fair Employment & Housing Act (Gov. Code §12900 et seq.) can be tedious—multiple forms, interactive‑process deadlines, and cross‑department coordination all add complexity.
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Maintain up-to-date accommodation policies and train HR staff and supervisors to recognize requests, whether explicit or implied. Foster a culture where employees feel comfortable discussing their needs. Keep written records of every step of the interactive process to protect against future disputes. Avoid delaying your response—timeliness is often a source of liability. Review medical documentation requests; ask only what is necessary to address the accommodation, not unrelated health information. Partner with legal counsel or use technology solutions when handling complex or high-volume requests to prevent inconsistencies or missed deadlines.
