Texas Reasonable Accommodation Law Guide

Texas Disability Inclusion & Workplace Adjustment Law

Updated on
May 11, 2025
AT-A-GLANCE
Who: Employers with 15 or more employees
Relevant regulation: ADA baseline – no broader state-specific requirement
Enforcement body: State human rights / civil rights agency

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: ADA baseline – no broader state-specific requirement
Enforcement body: State human rights / civil rights agency
Who:
Relevant regulation: ADA baseline – no broader state-specific requirement
Enforcement body: State human rights / civil rights agency
Texas

Table of contents

Texas reasonable‑accommodation requirements

Coverage & definitions

In Texas, reasonable-accommodation requirements for disabilities stem from the federal Americans with Disabilities Act (ADA), not a broader state-specific law. The ADA applies to private employers with 15 or more employees. Public employers, employment agencies, and labor organizations also fall under ADA coverage. A “qualified individual with a disability” is someone who can perform a job’s essential functions, with or without accommodation (ADA, 42 U.S.C. §12111). Texas law does not expand the employee threshold or provide broader accommodation definitions beyond the ADA baseline.

Reasonable‑accommodation duties

Texas employers must follow the ADA’s reasonable-accommodation standards—no state statute adds additional obligations. Under the ADA, employers are required to provide adjustments or modifications that enable a qualified individual with a disability to apply for a job, perform essential job duties, or enjoy equal access to workplace benefits. Typical examples include job restructuring, modified work schedules, acquisition of adaptive equipment, physical changes to the workspace, or providing interpreters. Accommodations are not required if they would impose an undue hardship on business operations.

Interactive process & timelines

Accommodation requests typically start with an employee’s notification, either verbally or in writing, that an adjustment is needed because of a disability. Employers may ask for reasonable documentation if the disability or need for accommodation is not obvious. While the ADA does not set strict deadlines, best practice is to engage in the interactive process—and respond to the request—as promptly as possible. Delays or failures to communicate can increase legal risk. Texas has no unique forms or state-mandated timelines; federal guidance via the EEOC shapes expectations (eeoc.gov).

Enforcement & penalties

In Texas, disability-accommodation complaints are filed with the Texas Workforce Commission Civil Rights Division (TWC-CRD), which acts as the state’s human rights agency. Complaints may also be filed with the federal Equal Employment Opportunity Commission (EEOC). Common penalties for noncompliance may include back pay, reinstatement, compensatory damages, and payment of legal fees if a finding of discrimination occurs. State agency investigations may result in mandated corrective action and, in rare cases, civil penalties (twc.texas.gov).

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Practical tips for employers

  • Train supervisors and HR staff to recognize accommodation requests, even informal ones.
  • Communicate proactively—keep employees updated throughout the interactive process.
  • Document every step: requests, discussions, decisions, and implementation details.
  • Beware of unnecessary medical documentation—request only what’s needed to evaluate the disability and accommodation.
  • Respond promptly; avoid letting requests stall, which can lead to legal risk.
  • Stay current on federal guidance via the EEOC, especially since Texas relies on ADA standards for accommodations.
Common pitfalls include missing informal requests, demanding excessive documentation, or failing to engage in timely communication with employees.

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