Minnesota Reasonable Accommodation Law Guide

Minnesota Disability Inclusion & Workplace Adjustment Law

Updated on
September 14, 2026
AT-A-GLANCE
Who: Employers with 1 or more employees
Relevant regulation: Minnesota Human Rights Act (Minn. Stat. ch. 363A, as amended Aug. 1, 2024) and Pregnancy Accommodations statute (§ 181.939)
Enforcement body: Minnesota Department of Human Rights; Department of Labor and Industry (§ 181.939)

Looking for the overarching federal rules?  Here’s our U.S. federal reasonable-accommodation guide.
Who: 15 + employees (ADA & PWFA) • Nearly all employers for PUMP Act (undue-hardship defence if < 50) • All federal agencies and federal contractors (§501/§503)
Relevant regulation: Minnesota Human Rights Act (Minn. Stat. ch. 363A, as amended Aug. 1, 2024) and Pregnancy Accommodations statute (§ 181.939)
Enforcement body: Minnesota Department of Human Rights; Department of Labor and Industry (§ 181.939)
Who:
Relevant regulation: Minnesota Human Rights Act (Minn. Stat. ch. 363A, as amended Aug. 1, 2024) and Pregnancy Accommodations statute (§ 181.939)
Enforcement body: Minnesota Department of Human Rights; Department of Labor and Industry (§ 181.939)
Minnesota

Table of contents

Minnesota reasonable‑accommodation requirements

Coverage & definitions

Minnesota’s obligations sit in two statutes with different coverage rules, and confusing them is a common error. The Minnesota Human Rights Act (Minn. Stat. ch. 363A) prohibits disability discrimination by employers of every size, but its express reasonable-accommodation duty in § 363A.08, subd. 6 applies to employers with 15 or more employees.

The pregnancy accommodation statute, Minn. Stat. § 181.939, applies to employers with one or more employees with no tenure or hours requirement.

Amendments effective August 1, 2024 (HF 4109) expanded the MHRA’s definition of disability to expressly cover impairments that are episodic or in remission, broadened “familial status” to include caring for an adult family member, and increased available damages.

Reasonable‑accommodation duties

Covered employers must provide reasonable accommodations to qualified employees and applicants with disabilities unless doing so would impose an undue hardship. Examples include modified schedules, assistive technology, job restructuring, accessible facilities, and leave.

For pregnancy and childbirth-related conditions, every Minnesota employer must provide reasonable accommodations on request unless it demonstrates undue hardship. Three accommodations are mandatory regardless of hardship and require no medical documentation:

  • More frequent or longer restroom, food and water breaks.
  • Seating.
  • Limits on lifting over 20 pounds.

Other listed accommodations include temporary transfer to a less strenuous or hazardous position, temporary leave, modified schedules or assignments, and limits on heavy lifting. An employer is not required to create a new position, discharge or transfer another employee with greater seniority, or promote anyone. Employers of every size must also provide reasonable break time and a private non-bathroom space for expressing milk, and may not reduce pay for that time.

Notice, documentation & the interactive process

Minnesota requires employers to give employees written notice of their rights under § 181.939 at hire and to include those rights in any handbook; the Department of Labor and Industry publishes the required employee notice. For pregnancy accommodations beyond the three mandatory ones, an employer may ask that the request come with the advice of a licensed health care provider or certified doula. For the three mandatory accommodations, no note may be requested.

The pregnancy statute expressly requires an interactive process. Under the MHRA, employers may request documentation limited to confirming the disability and the need, and must keep it confidential. Minnesota’s Earned Sick and Safe Time law (since January 1, 2024) and Paid Leave program (benefits since January 1, 2026) run alongside, not instead of, accommodation duties.

Enforcement & penalties

MHRA charges are filed with the Minnesota Department of Human Rights within one year; a civil action is also available. Since August 1, 2024, compensatory damages may be up to three times actual damages and include mental anguish, and punitive damages and attorney fees are available. Claims under § 181.939 are enforced by the Department of Labor and Industry and through a private civil action.

How Disclo simplifies Minnesota accommodation compliance

Managing accommodation requests under the Minnesota Human Rights Act can be tedious—multiple forms, interactive‑process deadlines, and cross‑department coordination all add complexity.

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Practical tips for employers

  • Do not screen pregnancy requests by headcount — § 181.939 reaches every employer, even where the MHRA accommodation duty does not.
  • Build the three no-documentation accommodations into intake so no one asks for a doctor’s note for a chair or a water break.
  • Update disability policies for the 2024 change covering episodic and in-remission conditions.
  • Put the DLI employee notice in your onboarding packet and handbook.
  • Coordinate ESST and Paid Leave with the accommodation process; they stack.

This guide is provided for general informational purposes only and does not constitute legal advice. Employment laws change frequently and vary by jurisdiction. Consult qualified employment counsel before acting on any information here. Last reviewed: September 2026.

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