Overview

• The Office of Personnel Management guidance, effective across federal agencies, directs agencies to permit personal religious expression unless it poses a substantial hardship under the Groff v. DeJoy standard.
• Protected practices include displaying religious symbols, wearing faith-based attire, engaging in prayer or religious discussions, and supervisor-led faith conversations in work areas, subject to content-neutral time, place and manner rules.
• Agencies must engage in a good-faith interactive process to accommodate requests and are encouraged to use telework as a low-cost solution for religious observances.
• The memo is seen as a blueprint for private employers, with the EEOC expected to align its own guidance and extend similar protections to the private sector.
• Legal experts warn that broader faith-based speech could trigger workplace disputes and require employers to carefully balance religious expression rights with non-discrimination obligations under Title VII.