New Federal Religious Expression and Accommodations Guidance May Impact Private Employers
In July 2025, the U.S. Office of Personnel Management (OPM) issued two important memos regarding religious accommodations and religious expression in federal workplaces. Although these memos apply only to federal agencies, they increase the likelihood that the U.S. Equal Employment Opportunity Commission (EEOC) will adopt similar guidance for private employers in the future. Quick Hits In mid-July 2025, OPM issued a memo that emphasizes federal agencies’ obligations to provide religious accommodations and identifies types of religious accommodations agencies should consider. Two weeks later, OPM issued a memo that expands religious expression in federal workplaces. The OPM memos align with recent executive orders and guidance from the Trump administration related to religious freedoms, as well as EEOC enforcement priorities, and may foreshadow further guidance and directives applicable to private sector workplaces. Introduction The First Amendment of the U.S. Constitution prohibits the...