Tennessee reasonable‑accommodation requirements

Coverage & definitions

The Tennessee Human Rights Act (T.C.A. § 4-21-401) applies to employers with eight or more employees, below the federal ADA’s 15. The separate Tennessee Disability Act (T.C.A. § 8-50-103) addresses disability discrimination specifically but, unlike the ADA, contains no express accommodation duty.

Since October 1, 2020, the Tennessee Pregnant Workers Fairness Act (2020 SB 2520, T.C.A. § 50-10-101 et seq.) has required employers with 15 or more employees to accommodate medical needs arising from pregnancy, childbirth or related conditions.

Reasonable‑accommodation duties

Under the ADA, and for disability discrimination purposes under state law, Tennessee employers must provide reasonable accommodations to qualified employees with disabilities unless doing so would pose an undue hardship. Typical adjustments include accessible facilities, job restructuring, modified schedules, leave, and modified equipment.

For pregnancy, the state Act lists accommodations including:

• More frequent or longer breaks.
• Time off to recover from childbirth.
• Acquisition or modification of equipment or seating.
• Temporary transfer to a less strenuous or hazardous position.
• Job restructuring.
• Light duty.
• A private non-bathroom space for expressing breast milk.
• Assistance with manual labor.
• A modified work schedule.

An employer may not require an employee to take leave if another reasonable accommodation can be provided, may not deny employment opportunities because of the need for one, and may not require an employee to accept an unnecessary accommodation.

Notice, documentation & the interactive process

Tennessee’s documentation rules are among the most specific in the country. An employer may require medical certification for a pregnancy accommodation only if it requires the same of other employees, and only for four types of accommodation:

• A temporary transfer.
• Job restructuring.
• Light duty.
• Time away from work.

Critically, the employer must begin the interactive process while the certification is pending — it may not wait for the note before engaging.

The statute expressly requires a timely, good-faith interactive process. For disability accommodations, documentation should be limited to confirming the condition and the need, and kept confidential.

Enforcement & penalties

Complaints are filed with the Tennessee Human Rights Commission within 180 days, or with the federal Equal Employment Opportunity Commission. Because the THRA attaches at eight employees, claims can proceed under state law against employers the ADA does not reach. Remedies include back pay, reinstatement, and compensatory damages capped by employer size; the pregnancy Act also provides for attorney fees and a private civil action.

How Disclo simplifies Tennessee accommodation compliance

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Practical tips for employers

• Track two thresholds: eight for the THRA, 15 for the pregnancy Act and the ADA.
• Never hold an accommodation request while waiting for a doctor’s note — the interactive process must start immediately.
• Request pregnancy certification only for the four permitted accommodation types, and only if you require it of others.
• Never push a pregnant employee onto leave when another accommodation would work.
• Note the 180-day filing window, which is shorter than in most states.

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.