Pharmacists holding a vaccine vial and needle with gloves.

The Equal Employment Opportunity Commission (EEOC) just released an updated COVID-19 technical assistance that includes clarification on religious exceptions to an employer’s COVID-19 vaccination policies. This is especially timely given that the Occupational Safety and Health Administration (OSHA) just sent its drafted rule on mandatory vaccinations to the White House for review.

This will affect employers with at least 100 employees who will need to be in compliance with vaccine mandates (mandatory vaccinations or weekly testing) by December 8. 2021. (Federal employees will need to be in compliance by November 22, 2021 and contractors onsite at Federal facilities have additional requirements. See Executive Order 14042 for more information). Technical assistance from EEOC clarifies that while Title VII of the Civil Rights Act “requires employers to consider requests for exemption “due to a sincerely held religious belief, practice, or observation,” that it does not apply to “social, political, economic views, or personal preferences” and that employers that “demonstrate ‘undue hardship’ are not required to accommodate an employee’s request for a religious accommodation.

(The EEOC clarifies that this technical assistance only provides guidance to the EEO laws and does not address other federal, state, or local laws.)

Do you have a process for employees that request an exception/exemption? What consistent process are you using to review requests for accommodation? If you haven’t yet set up a process and would like to obtain guidance, contact Southwestern Human Resources Consulting today at

Magdalena Vigil-Tullar

Written by | Magdalena Vigil-Tullar


Phone: 505-270-7494 | Email:

PO Box 14274 | Albuquerque, NM 87191

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