How Employers Can Document Religious Accommodation Requests After Groff v. DeJoy

After Groff v. DeJoy (2023), employers must show written evidence if they deny a religious accommodation request. Courts will expect documentation of what was requested, how it was evaluated, and why it was denied—if it was. Vague concerns or undocumented conversations won’t satisfy the legal standard. Employers should adopt clear procedures, keep detailed records, and handle all requests through a consistent, transparent process. This isn’t just about compliance. It’s about creating a system that treats belief with the seriousness the law now requires.

In Groff v. DeJoy, 600 U.S. 447 (2023), the Supreme Court unanimously held that employers cannot deny an employee’s request for religious accommodation unless they can prove that granting the request would impose a substantial burden on the business. The burden of proof is now squarely on the employer—and it is a burden that must be documented.

Verbal explanations and general concerns no longer meet the legal standard. If an employer denies an accommodation, they need to show why, in detail. Courts will ask: What were the costs? Who was affected? What alternatives were considered? If those answers are not in writing, they may not hold up.

This shift in law has transformed religious accommodation from a discretionary management decision into a regulated compliance issue. And compliance always starts with documentation.

When a religious accommodation request is granted, documentation creates a clear record of what was agreed upon and when. If the accommodation later becomes unworkable, that history helps explain the employer’s reasoning. If the request is denied, documentation is not just helpful—it is essential.