Is mandatory AI use itself an essential job function?
Sometimes, but only when the record shows the job is genuinely built around using the AI workflow. The safer analysis separates the essential work output from the employer's preferred tool or interface.
The law is mostly old. A mandatory AI-use rule is usually not a new legal category; it is a work rule, interface choice, performance metric, or testing method that sits inside existing accommodation law. Under the ADA, the hard question is whether use of a specific AI tool is actually an essential function or only the employer's preferred method of performing an essential function, and whether another effective path exists without “significant difficulty or expense”. Under Title VII after Groff v. DeJoy, the question is whether a sincere religious objection can be accommodated without substantial increased costs in relation to the conduct of [the employer's] particular business. State regimes like FEHA, NYSHRL, NYCHRL, and New Jersey's 2025 guidance make the same point in a more operational way: once AI use becomes mandatory, rigid enforcement becomes harder to defend if the tool itself blocks accommodation or if the same output can be reached through another workflow.
The ADA fits the problem without much doctrinal stretching. Discrimination includes “not making reasonable accommodations to the known physical or mental limitations” of an otherwise qualified applicant or employee, unless the employer can show undue hardship. The statute also says reasonable accommodation may include modified schedules, reassignment, equipment or device modification, and modifications of examinations, training materials, or policies. The implementing regulation adds that it may be necessary to begin an “informal, interactive process” to identify the limitation and a workable accommodation. That matters because the employer can insist on the essential function of the job, but it does not automatically get to freeze the current vendor, interface, or workflow if another effective means exists.
Current federal AI materials already assume the accommodation framework applies. The EEOC's 2024 handout for workers says existing employment laws may require reasonable accommodation even when the employer uses AI, and it describes AI use across recruiting, video interviews, pay, promotion, productivity monitoring, layoffs, and termination. The EEOC's 2022 AI-and-ADA technical assistance and its 2023 visual-disabilities guidance point the same way, and DOJ's 2022 hiring guidance treats automated tools as fully inside disability-discrimination law rather than outside it. The immediate consequence is that a company cannot rely on the novelty of the tool to argue that accommodation rules have not caught up.
The state analogues make the procedural layer more explicit. FEHA separately prohibits failure to provide reasonable accommodation and failure to engage in a “timely, good faith, interactive process”. Its religious-accommodation section asks whether the employer explored any available reasonable alternative means of accommodating and uses a significant difficulty or expense hardship concept. New York State bars employers from imposing terms that require a person to “violate or forego” a sincerely held religious practice. New York City goes further, requiring a “cooperative dialogue” and a written final determination for disability and religion requests.
New Jersey's January 2025 guidance is the most AI-specific state source in the set. The Division on Civil Rights says algorithmic discrimination can violate the LAD when it “precludes or impedes” reasonable accommodations for disability or religion. Its examples are concrete: a typing-speed tool that cannot read input from a nontraditional keyboard, or a productivity tool that flags accommodated breaks because the system was never configured for them. That is perhaps the clearest existing public statement that AI accommodation risk may appear in the measurement layer, not just in the chatbot interface.
The employment bar is unusually aligned on the disability side. Littler's 2022 ADA memo reads the EEOC position straightforwardly: when disability makes an AI tool hard to use or drags down the result, the accommodation duty stays with the employer, even if the practical problem began with a vendor product. Jackson Lewis took the same event and emphasized accessible design, accessible instructions, and clear accommodation channels rather than any special AI exception. The non-obvious point is how little space the firms give to the idea that vendor failure somehow interrupts the employer's own obligations.
More recent commentary extends that logic from hiring tools to ordinary workplace AI mandates. Ogletree's June 2025 overview treats reasonable accommodation as a core employment-law issue for workplace AI, not a narrow recruiting issue. Its April 2026 piece on religious objections is even more revealing because it treats the issue as current workplace fact: some employers are already receiving accommodation requests from workers who say AI use conflicts with religious belief. That does not mean every objection qualifies as religious. It means the employer bar no longer sees the question as hypothetical.
The California and New Jersey commentary pushes in the same direction. Jackson Lewis and Littler both read California's 2025 AI employment regulations to mean that employers may have to accommodate AI-enabled barriers where the system measures traits like dexterity, reaction time, tone of voice, or facial expression. Littler and Ogletree read New Jersey's 2025 guidance similarly: an automated system can create accommodation exposure when it blocks disability or religious accommodation rather than merely screening for bias in the abstract.
Seyfarth's treatment of the Department of Labor's 2024 promising practices lands in the same place from a different angle. AI systems are expected to be accessible and to leave room for accommodation requests. Across the firms, there is very little daylight on the main issue. The disagreement is mostly at the edges: which requests are sincere, which burdens are substantial, and whether a given AI workflow is genuinely central to the job or just the current management preference.
The important shift is from optional tool to employment term. Public memos from Shopify and Box matter less because they are law than because they show how the facts are changing: AI use described as a fundamental expectation, a staffing gate, and a redesign of daily work. Once the record looks like that, an accommodation dispute stops being about experimentation with a new tool and starts looking like any other dispute over a required method, review metric, or condition of employment.
This is where the essential-function question becomes real. A company may have a stronger story when the role is itself about supervising model outputs, operating inside a shared AI workflow, or maintaining a specific AI-enabled process. The story is weaker when the essential function is still the underlying legal analysis, coding, drafting, selling, or project management, and AI is mainly the preferred path to that output. The ADA lets employers hold output and production standards constant. It does not automatically treat every preferred method as untouchable.
Perhaps yes where the role is genuinely built around operating inside a named AI workflow, and the written description and practice record say so. Perhaps not where the real essential function is still the underlying work product and AI is only the preferred route to it.
Sources for this answer
Primary law
A.2 42 U.S.C. section 12111(10)Supports the cited proposition. (42 U.S.C. section 12111(10))
significant difficulty or expense
See 42 U.S.C. section 12111(10).
Case law
A.4 Groff v. DeJoy, 600 U.S. 447 (2023)PDFUnder Title VII, an employer must demonstrate that a requested religious accommodation would result in substantial increased costs in relation to the conduct of its particular business to establish an undue hardship defense, rather than merely showing a de minimis cost.
We hold that showing “more than a de minimis cost,” as that phrase is used in common parlance, does not suffice to establish “undue hardship” under Title VII.
See Groff v. DeJoy, 600 U.S. 447 (2023).
Primary law
A.1 42 U.S.C. section 12112(b)(5)(A)Supports the cited proposition. (42 U.S.C. section 12112(b)(5)(A))
not making reasonable accommodations to the known physical or mental limitations
See 42 U.S.C. section 12112(b)(5)(A).
Primary law
A.9 29 C.F.R. section 1630.2(o)(3)Supports the cited proposition. (29 C.F.R. section 1630.2(o)(3))
informal, interactive process
See 29 C.F.R. section 1630.2(o)(3).
Primary law
A.3 42 U.S.C. section 2000e(j)Supports the cited proposition. (42 U.S.C. section 2000e(j))
all aspects of religious observance and practice, as well as belief
See 42 U.S.C. section 2000e(j).
Primary law
A.5 California Government Code section 12940(n)Supports the cited proposition. (California Government Code section 12940(n))
timely, good faith, interactive process
See California Government Code section 12940(n).
Primary law
A.6 New York Executive Law section 296Supports the cited proposition. (New York Executive Law section 296)
violate or forego
See New York Executive Law section 296.
Commentary
A.7 New York City Administrative Code section 8-107Supports the cited proposition. (New York City Administrative Code section 8-107)
cooperative dialogue
See New York City Administrative Code section 8-107.
Agency guidance
A.8 New Jersey Division on Civil Rights, Guidance on Algorithmic Discrimination and the New Jersey Law Against DiscriminationPDFSupports the cited proposition. (New Jersey Division on Civil Rights, Guidance on Algorithmic Discrimination and the New Jersey Law Against Discrimination)
precludes or impedes
See New Jersey Division on Civil Rights, Guidance on Algorithmic Discrimination and the New Jersey Law Against Discrimination.
Primary law
A.10 EEOC, Employment Discrimination and AI for WorkersPDFFederal employment discrimination laws apply to the use of artificial intelligence in the workplace, including requirements for reasonable accommodations and prohibitions against discriminatory practices.
Federal employment discrimination laws protect you when AI systems are used to discriminate against you on the basis of your race, color, religion, sex (including gender, sexual orientation, and pregnancy), national origin, age (40 or older), disability, or genetic information.
See EEOC, Employment Discrimination and AI for Workers.
Primary law
A.11 EEOC, Artificial Intelligence and the ADAThe EEOC provides guidance on how the Americans with Disabilities Act applies to the use of software, algorithms, and artificial intelligence in employment decision-making processes.
The Americans with Disabilities Act and the Use of Software, Algorithms, and Artificial Intelligence to Assess Job Applicants and Employees
See EEOC, Artificial Intelligence and the ADA.
Primary law
A.12 EEOC, Visual Disabilities in the Workplace and the Americans with Disabilitie...The Americans with Disabilities Act prohibits discrimination against qualified individuals with visual disabilities, mandates reasonable accommodations for such individuals absent undue hardship, and restricts employer inquiries into medical conditions during the hiring and employment process.
An employer may exclude an individual with a vision impairment from a job for safety reasons only when the individual poses a direct threat. A “direct threat” is a significant risk of substantial harm to the health or safety of the individual or others that cannot be eliminated or reduced through reasonable accommodation.
See EEOC, Visual Disabilities in the Workplace and the Americans with Disabilities Act.
Primary law
A.13 DOJ, Algorithms, Artificial Intelligence, and Disability Discrimination in Hi...Under the Americans with Disabilities Act, employers are prohibited from using hiring technologies that result in unlawful discrimination or unfairly screen out qualified individuals with disabilities, and they must provide reasonable accommodations during the hiring process unless doing so constitutes an undue hardship.
An employer who chooses to use a hiring technology must ensure that its use does not cause unlawful discrimination on the basis of disability.
See DOJ, Algorithms, Artificial Intelligence, and Disability Discrimination in Hiring.
Primary law
A.14 California Government Code section 12926California Government Code section 12926 provides the statutory definitions for key terms used in the Fair Employment and Housing Act, including essential functions, disabilities, supervisors, and undue hardship.
“Essential functions” means the fundamental job duties of the employment position the individual with a disability holds or desires.
See California Government Code section 12926.
Primary law
A.15 NYC Commission on Human Rights, Title 8 Civil RightsThe New York City Human Rights Law prohibits discrimination in employment, public accommodations, and housing based on protected characteristics, and further protects individuals from retaliation and interference with their rights under the statute.
It shall be an unlawful discriminatory practice for any person who is the owner, franchisor, franchisee, lessor, lessee, proprietor, manager, superintendent, agent or employee of any place or provider of public accommodation: 1. Because of any person's actual or perceived race, creed, color, national origin, age, gender, disability, marital status, partnership status, sexual orientation, uniformed service, height, weight, or immigration or citizenship status, directly or indirectly: (a) To refuse, withhold from or deny to such person the full and equal enjoyment, on equal terms and conditions, of any of the accommodations, advantages, services, facilities or privileges of the place or provider of public accommodation
See NYC Commission on Human Rights, Title 8 Civil Rights.
Law-firm commentary
A.16 Littler commentaryThe EEOC's guidance on artificial intelligence in the workplace emphasizes that employers remain liable for ADA compliance, including reasonable accommodation and screening requirements, even when utilizing third-party software vendors.
Noting that employers are responsible for ADA-violating outcomes even when a software tool is created or used by a third-party vendor or agent, the Commission provides examples of so-called “Promising Practices” that employers can engage in to demonstrate good-faith efforts to meet ADA requirements.
See Littler, EEOC Issues Guidance on Artificial Intelligence and the Americans with Disabilities Act.
Law-firm commentary
A.17 Jackson Lewis commentaryThe EEOC and DOJ have issued guidance regarding the use of artificial intelligence and algorithmic decision-making tools in the workplace, emphasizing that while these documents do not create new legal obligations, they clarify how existing federal civil rights laws, including the ADA, apply to these technologies.
The EEOC’s TAD applies the Americans with Disabilities Act (ADA), including regulations and existing guidance, where technology intersects with workplace legal issues.
See Jackson Lewis, EEOC, DOJ Release Expectations on Employers' Use of Technology (AI) in Employment Decisions.
Law-firm commentary
A.18 Ogletree Deakins commentaryEmployers face significant legal liability under existing anti-discrimination frameworks when using automated HR tools, necessitating proactive measures such as privileged algorithmic audits to mitigate disparate impact risks.
Using automated technology to make workforce decisions presents significant legal risks under existing anti-discrimination laws, such as Title VII, the ADEA, and the ADA, because bias in algorithms can lead to allegations of discrimination.
See Ogletree Deakins, The Intersection of Artificial Intelligence and Employment Law.
Law-firm commentary
A.19 Ogletree Deakins commentaryEmployers are legally required under Title VII and similar state laws to provide reasonable accommodations for an employee's sincerely held religious beliefs unless doing so imposes an undue hardship, defined by the Supreme Court as a substantial burden.
Federal and state laws require employers to provide reasonable accommodations for an employee’s religious beliefs, unless it would impose an undue hardship.
See Ogletree Deakins, The Mark of the Bot: When Employees Raise Religious Objections to Workplace AI Usage.
Primary law
A.20 Jackson Lewis, California's New AI Regulations Take Effect Oct. 1. Here's You...California's new regulations prohibit employers from using automated decision systems or selection criteria that result in discrimination based on protected categories under the Fair Employment and Housing Act.
The regulations prohibit employers from using ADS or selection criteria that discriminate against applicants or employees based on protected categories defined under the Fair Employment and Housing Act (FEHA).
See Jackson Lewis, California's New AI Regulations Take Effect Oct. 1. Here's Your Compliance Checklist.
Primary law
A.21 Littler, California Approves Landmark AI Employment RegulationsEffective October 1, 2025, new California regulations under the Fair Employment and Housing Act impose specific compliance requirements and evidentiary standards for employers utilizing automated decision-making systems in employment-related processes.
Revisions to Title 2 of the California Code of Regulations will govern the use of AI-based tools in California starting October 1, 2025.
See Littler, California Approves Landmark AI Employment Regulations.
Law-firm commentary
A.22 Littler commentaryThe New Jersey Division of Civil Rights has issued guidance clarifying that the New Jersey Law Against Discrimination prohibits algorithmic discrimination in employment, including claims based on disparate treatment, disparate impact, and failure to accommodate.
The Guidance clarifies that the New Jersey Law Against Discrimination (NJLAD) prohibits “algorithmic discrimination,” that is, discrimination resulting from a covered entity’s use of automated decision-making tools.
See Littler, AI in the Garden State: New Guidance on Algorithmic Discrimination and New Jersey Law.
Law-firm commentary
A.23 Ogletree Deakins commentaryUnder the New Jersey Law Against Discrimination, employers remain fully liable for discriminatory outcomes resulting from the use of automated decision-making tools, regardless of whether the technology is managed by a third-party vendor.
the guidance reinforces that employers are fully responsible for the AI technology they utilize and may not delegate their compliance responsibilities to third parties.
See Ogletree Deakins, New Jersey Division on Civil Rights Issues New Guidance on Algorithmic Discrimination.
Law-firm commentary
A.24 Seyfarth Shaw commentaryWhile the Department of Labor's OFCCP guidance on artificial intelligence is not a binding standard, it clarifies that existing nondiscrimination and reasonable accommodation obligations apply to AI tools and warns that employers remain responsible for compliance even when using third-party vendors.
OFCCP unambiguously warns that federal contractors cannot delegate or avoid their nondiscrimination and affirmative action obligations by using third-party AI products.
See Seyfarth Shaw, Department of Labor Issues Comprehensive Artificial Intelligence Promising Practices Designed to Avoid Bias.
Commentary
A.25 The Verge, Shopify CEO says no new hires without proof AI can't do the jobShopify has implemented a policy requiring employees to demonstrate that tasks cannot be completed using AI before requesting additional headcount, while establishing AI proficiency as a core performance expectation.
Before asking for more Headcount and resources, teams must demonstrate why they cannot get what they want done using AI.
See The Verge, Shopify CEO says no new hires without proof AI can't do the job.
Commentary
A.26 Box, AI-First Transformation: Box's Principles, Strategy, and Execution FrameworkEffective enterprise AI transformation requires a governance framework that balances centralized strategic guardrails with functional ownership to ensure scalable execution.
Box's AI executive sponsorship is led by Olivia Nottebohm, the company’s COO, Ravi Malick, the CIO, and Jessica Swank, Chief People Officer, to represent business, IT and people aspects — all of which are critical.
See Box, AI-First Transformation: Box's Principles, Strategy, and Execution Framework.
Primary law
A.27 EEOC, Enforcement Guidance on Reasonable Accommodation and Undue Hardship und...Under the Americans with Disabilities Act, employers are required to provide reasonable accommodations to qualified individuals with disabilities, unless doing so would impose an undue hardship, and this obligation is typically fulfilled through an informal, interactive process.
Title I of the Americans with Disabilities Act of 1990 (the "ADA")(1) requires an employer(2) to provide reasonable accommodation to qualified individuals with disabilities who are employees or applicants for employment, unless to do so would cause undue hardship.
See EEOC, Enforcement Guidance on Reasonable Accommodation and Undue Hardship under the ADA.
How far can religious objections to mandatory AI use go?
They can go farther than minor inconvenience, but only for sincere religious conflicts rather than secular objections to new technology. After Groff, the employer needs a concrete undue-hardship analysis tied to its actual business.
Title VII is less AI-specific but no less relevant. The statute says religion includes “all aspects of religious observance and practice, as well as belief” unless the employer cannot reasonably accommodate without undue hardship. After Groff, the old more than de minimis shorthand no longer does the work; the burden has to rise to substantial increased costs in the context of the particular business. The pre-Groff regulation still helps on the shape of possible alternatives, including voluntary substitutes, schedule changes, and transfer, but not on hardship threshold. So an AI mandate challenged on religious grounds is not decided by mild workflow friction or a generalized preference for uniformity.
Religious-objection disputes may be where first impression shows up fastest. Title VII does not protect a generalized ethical dislike of AI, a secular professionalism argument, or a preference not to use new software. But after Groff, it also does not let an employer stop at minor friction. The real fight is likely to be over sincerity, whether the objection is actually religious, and whether the requested exception changes the business in a substantial way or merely complicates a preferred workflow.
We think farther than the old de minimis shorthand suggested, because the burden now has to be substantial in the context of the actual business. But Title VII still does not protect objections that are political, economic, or merely personal rather than religious.
Sources for this answer
Case law
B.2 Groff v. DeJoy, 600 U.S. 447 (2023)PDFUnder Title VII, an employer must demonstrate that a requested religious accommodation would result in substantial increased costs in relation to the conduct of its particular business to establish an undue hardship defense, rather than merely showing a de minimis cost.
We hold that showing “more than a de minimis cost,” as that phrase is used in common parlance, does not suffice to establish “undue hardship” under Title VII.
See Groff v. DeJoy, 600 U.S. 447 (2023).
Primary law
B.1 42 U.S.C. section 2000e(j)Supports the cited proposition. (42 U.S.C. section 2000e(j))
all aspects of religious observance and practice, as well as belief
See 42 U.S.C. section 2000e(j).
Primary law
B.3 29 C.F.R. section 1605.2Under Title VII, employers and labor organizations are required to reasonably accommodate the religious practices of employees unless they can demonstrate that doing so would result in undue hardship on the conduct of their business.
Section 701(j) makes it an unlawful employment practice under section 703(a)(1) for an employer to fail to reasonably accommodate the religious practices of an employee or prospective employee, unless the employer demonstrates that accommodation would result in undue hardship on the conduct of its business.
See 29 C.F.R. section 1605.2.
Primary law
B.4 EEOC, Religious DiscriminationUnder Title VII, employers are prohibited from discriminating against employees based on religion and must provide reasonable accommodations for religious beliefs and practices unless doing so imposes a substantial burden on the employer's business operations.
undue hardship is shown when a burden is substantial in the overall context of an employer’s business
See EEOC, Religious Discrimination.
Law-firm commentary
B.6 Ogletree Deakins commentaryEmployers are legally required under Title VII and similar state laws to provide reasonable accommodations for an employee's sincerely held religious beliefs unless doing so imposes an undue hardship, defined by the Supreme Court as a substantial burden.
Federal and state laws require employers to provide reasonable accommodations for an employee’s religious beliefs, unless it would impose an undue hardship.
See Ogletree Deakins, The Mark of the Bot: When Employees Raise Religious Objections to Workplace AI Usage.
Primary law
B.5 EEOC, Questions and Answers: Religious Discrimination in the WorkplaceTitle VII of the Civil Rights Act of 1964 prohibits employment discrimination based on religion and requires employers to provide reasonable accommodations for sincerely held religious beliefs, practices, or observances unless doing so would impose an undue hardship.
Title VII requires an employer, once on notice that a religious accommodation is needed, to reasonably accommodate an employee whose sincerely held religious belief, practice, or observance conflicts with a work requirement, unless doing so would pose an undue hardship.
See EEOC, Questions and Answers: Religious Discrimination in the Workplace.
What accommodations work when employees cannot use mandatory AI tools?
Common options include accessible settings, alternate tools, different input methods, more time, training, human review, or removing the employee from an AI-use metric. The employer can still preserve essential functions and production standards.
The harder cases may come from instrumentation rather than from the chatbot prompt box. A worker whose accommodation already includes extra break time, slower input, assistive devices, or alternative input modes can look deficient to an AI productivity system that was never configured for those facts. New Jersey's guidance makes this explicit. So companies that turn AI usage into a KPI, utilization score, or performance-review factor inherit accommodation risk at the measurement layer as well as at the tool layer.
Perhaps an accessible version of the same tool, a different tool, different input or output modes, more time or training, a human-reviewed alternative, or removal from an AI-usage metric while keeping the substantive output standard. The counterargument is familiar too: accommodation does not erase essential functions or reduce production standards, and reassignment remains a last resort under the ADA.
Sources for this answer
Primary law
C.3 42 U.S.C. section 12111(10)Supports the cited proposition. (42 U.S.C. section 12111(10))
significant difficulty or expense
See 42 U.S.C. section 12111(10).
Primary law
C.4 42 U.S.C. section 12112(b)(5)(A)Supports the cited proposition. (42 U.S.C. section 12112(b)(5)(A))
not making reasonable accommodations to the known physical or mental limitations
See 42 U.S.C. section 12112(b)(5)(A).
Primary law
C.5 29 C.F.R. section 1630.2(o)(3)Supports the cited proposition. (29 C.F.R. section 1630.2(o)(3))
informal, interactive process
See 29 C.F.R. section 1630.2(o)(3).
Agency guidance
C.1 New Jersey Division on Civil Rights, Guidance on Algorithmic Discrimination and the New Jersey Law Against DiscriminationPDFSupports the cited proposition. (New Jersey Division on Civil Rights, Guidance on Algorithmic Discrimination and the New Jersey Law Against Discrimination)
precludes or impedes
See New Jersey Division on Civil Rights, Guidance on Algorithmic Discrimination and the New Jersey Law Against Discrimination.
Primary law
C.2 EEOC, Employment Discrimination and AI for WorkersPDFFederal employment discrimination laws apply to the use of artificial intelligence in the workplace, including requirements for reasonable accommodations and prohibitions against discriminatory practices.
Federal employment discrimination laws protect you when AI systems are used to discriminate against you on the basis of your race, color, religion, sex (including gender, sexual orientation, and pregnancy), national origin, age (40 or older), disability, or genetic information.
See EEOC, Employment Discrimination and AI for Workers.
Primary law
C.6 EEOC, Artificial Intelligence and the ADAThe EEOC provides guidance on how the Americans with Disabilities Act applies to the use of software, algorithms, and artificial intelligence in employment decision-making processes.
The Americans with Disabilities Act and the Use of Software, Algorithms, and Artificial Intelligence to Assess Job Applicants and Employees
See EEOC, Artificial Intelligence and the ADA.
How should employers review suspicious mandatory AI accommodation requests?
They can ask targeted questions about disability-related need or religious sincerity, but they should still run the ordinary accommodation process. Treating a doubtful request as insubordination too quickly creates avoidable process risk.
The documented record changes the downside more than slogans do. When the file shows that AI use was identified as essential before the dispute, the employer tested accessible configurations or alternative workflows, requested only limited supporting material, and analyzed burden in concrete business terms, the dispute looks like an accommodation process honestly run. When the file shows only a broad AI-first norm, a vendor chosen without attention to accessibility, and a refusal to consider another effective workflow, the same policy looks much more brittle. The ADA separately narrows certain damages where the employer can show “good faith efforts, in consultation with the person with the disability” to identify and make an equally effective accommodation.
The ADA permits limited documentation about disability and need, and Title VII permits inquiry into sincerity. But the source set points toward the same conclusion on both sides: even a doubtful request still tends to trigger the ordinary accommodation process rather than immediate treatment as insubordination.
Sources for this answer
Primary law
D.3 29 C.F.R. section 1630.2(o)(3)Supports the cited proposition. (29 C.F.R. section 1630.2(o)(3))
informal, interactive process
See 29 C.F.R. section 1630.2(o)(3).
Primary law
D.1 42 U.S.C. section 1981a(a)(3)Supports the cited proposition. (42 U.S.C. section 1981a(a)(3))
good faith efforts, in consultation with the person with the disability
See 42 U.S.C. section 1981a(a)(3).
Primary law
D.2 EEOC, Enforcement Guidance on Reasonable Accommodation and Undue Hardship und...Under the Americans with Disabilities Act, employers are required to provide reasonable accommodations to qualified individuals with disabilities, unless doing so would impose an undue hardship, and this obligation is typically fulfilled through an informal, interactive process.
Title I of the Americans with Disabilities Act of 1990 (the "ADA")(1) requires an employer(2) to provide reasonable accommodation to qualified individuals with disabilities who are employees or applicants for employment, unless to do so would cause undue hardship.
See EEOC, Enforcement Guidance on Reasonable Accommodation and Undue Hardship under the ADA.
Law-firm commentary
D.5 Ogletree Deakins commentaryEmployers are legally required under Title VII and similar state laws to provide reasonable accommodations for an employee's sincerely held religious beliefs unless doing so imposes an undue hardship, defined by the Supreme Court as a substantial burden.
Federal and state laws require employers to provide reasonable accommodations for an employee’s religious beliefs, unless it would impose an undue hardship.
See Ogletree Deakins, The Mark of the Bot: When Employees Raise Religious Objections to Workplace AI Usage.
Primary law
D.4 EEOC, Questions and Answers: Religious Discrimination in the WorkplaceTitle VII of the Civil Rights Act of 1964 prohibits employment discrimination based on religion and requires employers to provide reasonable accommodations for sincerely held religious beliefs, practices, or observances unless doing so would impose an undue hardship.
Title VII requires an employer, once on notice that a religious accommodation is needed, to reasonably accommodate an employee whose sincerely held religious belief, practice, or observance conflicts with a work requirement, unless doing so would pose an undue hardship.
See EEOC, Questions and Answers: Religious Discrimination in the Workplace.
Can an AI tool itself be a workplace accommodation?
Yes, if the tool's accessibility features help the employee perform the essential work. The same tool can also create risk if it breaks assistive technology, misreads accommodated performance, or leaves no accessible alternative.
Mandatory AI use is not automatically anti-accommodation. Some AI products can expand access. Microsoft publishes screen-reader guidance for Copilot in Word, Outlook, and PowerPoint. Google publishes Workspace accessibility materials describing screen-reader support, keyboard shortcuts, braille-display compatibility, and voice typing. That cuts in both directions. It weakens the idea that every disability-based objection deserves a full opt-out, but it also makes vendor choice harder to treat as neutral. If comparable products have accessible pathways and the chosen workflow does not, the accessibility gap becomes part of the employer's facts.
Perhaps yes when the tool's voice, reading, summarization, or keyboard features are the reason the employee can perform essential functions at all. The opposite possibility is that the same tool becomes the problem once it breaks assistive technology, misreads accommodated performance, or is locked into a mandatory workflow that has no accessible alternative.
Sources for this answer
Agency guidance
E.6 New Jersey Division on Civil Rights, Guidance on Algorithmic Discrimination and the New Jersey Law Against DiscriminationPDFSupports the cited proposition. (New Jersey Division on Civil Rights, Guidance on Algorithmic Discrimination and the New Jersey Law Against Discrimination)
precludes or impedes
See New Jersey Division on Civil Rights, Guidance on Algorithmic Discrimination and the New Jersey Law Against Discrimination.
Vendor documentation
E.1 Microsoft Support, Use Copilot in Word with a screen readerMicrosoft provides specific guidance and technical support for users with disabilities to utilize Copilot features in Microsoft Word via screen readers and keyboard navigation.
Use Copilot in Microsoft Word with just your keyboard and a screen reader to draft new content, rewrite or summarize text, generate ideas, and ask questions about your document.
See Microsoft Support, Use Copilot in Word with a screen reader.
Vendor documentation
E.2 Microsoft Support, Use Copilot in Outlook with a screen readerMicrosoft provides dedicated technical support and accessibility assistance for users with disabilities through its Disability Answer Desk.
Microsoft wants to provide the best possible experience for all our customers. If you have a disability or questions related to accessibility, please contact the Microsoft Disability Answer Desk for technical assistance.
See Microsoft Support, Use Copilot in Outlook with a screen reader.
Vendor documentation
E.3 Microsoft Support, Basic tasks using a screen reader with Copilot in PowerPointMicrosoft provides specific guidance and technical support resources to ensure that users with disabilities can effectively utilize Copilot in PowerPoint with assistive technologies.
This article guides you through basic tasks using Copilot in PowerPoint with your keyboard and a screen reader.
See Microsoft Support, Basic tasks using a screen reader with Copilot in PowerPoint.
Vendor documentation
E.4 Google Accessibility, Google Workspace for diverse learnersGoogle Workspace for Education integrates accessibility features across its suite of tools to support diverse learning needs and foster inclusive educational environments.
We create Google for Education products with accessibility in mind, to help every student learn, be inspired, and achieve their full potential.
See Google Accessibility, Google Workspace for diverse learners.
Vendor documentation
E.5 Google Accessibility Help, Google Workspace admin guide to accessibilityGoogle provides accessibility conformance documentation and administrative controls to assist organizations in meeting accessibility standards for their users.
To make it easier for companies, educational institutions, and government agencies to comply with accessibility standards, we provide transparent information about how our products currently work for people with disabilities.
See Google Accessibility Help, Google Workspace admin guide to accessibility.