OPM Issues Memos on Religious Accommodation and Expression in Fed

If you’re a federal employee, you’ve probably noticed that the rules around
religious accommodation and religious expression at work have gotten a lot
more detailed lately. The U.S. Office of Personnel Management (OPM) has
issued a pair of government-wide memoranda that put religious liberty
front and center in the federal workplace. For many employees of faith,
this feels like long-awaited clarity. For supervisors and HR, it’s a
giant neon sign that says: “You really need to understand this.”

In this article, we’ll unpack what these OPM memos actually say, how
they fit into existing law like Title VII of the Civil Rights Act, and
what they mean in day-to-day situationsfrom flexible schedules to
telework to prayer groups on your lunch break. We’ll also walk through
some real-world style scenarios so you can see how these rules might play
out in practice.

What Exactly Did OPM Do?

OPM’s recent actions come in the form of two key memoranda to the heads
of federal departments and agencies:

• A memo on “Reasonable Accommodations for Religious Purposes”,
  which lays out how agencies must handle requests from employees whose
  religious beliefs conflict with work rules or schedules.
• A memo on “Protecting Religious Expression in the Federal Workplace”,
  which focuses on how employees can express their faith at workthrough
  prayer, religious items, conversations, and voluntary gatherings
  without running afoul of anti-discrimination rules.

Both documents emphasize the same big idea: the federal workplace should
be a welcoming place for employees of faith, and agencies must take
religious accommodation and religious expression seriously. At the same
time, they stress that employees of all beliefsincluding those who are
not religiousare protected from discrimination and harassment.

The Legal Backdrop: Title VII, the First Amendment, and Groff

To understand these memos, you need the legal backdrop. The core federal
rule here is Title VII of the Civil Rights Act of 1964, which
prohibits discrimination in employment based on religion and requires
employers to provide reasonable religious accommodations unless doing so
would cause an undue hardship on the conduct of the employer’s business.

Historically, “undue hardship” was interpreted pretty loosely in many
courtsoften meaning the employer could say “no” if accommodating
someone’s religious practice cost more than a very small amount of
money or effort. That changed with the Supreme Court’s 2023 decision in
Groff v. DeJoy, which held that employers must now show that granting a
requested religious accommodation would result in
substantial increased costs in relation to the conduct of the business,
not just a minor inconvenience.

OPM’s accommodation memo explicitly incorporates this more demanding
standard. In plain language, that means agencies can’t brush off
religious accommodation requests because they’re inconvenient. They must
take them seriously, engage in a real dialogue with the employee, and
only deny them when the burden is truly significant.

On top of that, the First Amendment protects individuals from
government restrictions on religious exercise and expression, and federal
statutes like the Religious Freedom Restoration Act (RFRA) and various
civil-rights laws reinforce those protections. The OPM memos are
designed to align day-to-day federal HR practice with this legal
framework.

Key Takeaways from the Religious Accommodation Memo

1. Agencies Must Use a “Generous” Approach

OPM’s accommodation memo directs agencies to take a generous
approach to religious accommodation requests. Supervisors and HR
professionals are told, in effect, “If there’s a reasonable way to say
yes, try to say yes.”

That doesn’t mean every single request must be granted. But it does mean
agencies should start from a presumption of accommodation and only fall
back on “undue hardship” when they can show that the requested solution
would create substantial difficulty or cost in the context of the
agency’s work.

2. The Interactive Process Is Not Optional

When an employee asks for a religious accommodationwhether it’s about
scheduling, dress, grooming, fasting, or religious holidaysthe memo
requires agencies to engage in a good-faith interactive process.

That means:

• Talking with the employee about their religious need.
• Exploring different ways to accommodate it (not just one rigid option).
• Considering multiple or “hybrid” solutionslike combining telework,
  flexible hours, and leave.
• Documenting the steps taken and the reasons for any decision.

Practically speaking, this process looks similar to how agencies handle
disability accommodations, but the underlying legal standard is
different. The key message is that agencies should collaborate with
employees, not simply issue a quick yes or no.

3. Examples of Reasonable Religious Accommodations

The memo provides examples of accommodations agencies should be prepared
to consider. These include:

• Flexible work schedules so employees can observe Sabbath, prayer
  times, or religious holidays.
• Telework as an accommodationfor example, when commuting or
  in-office hours conflict with religious observance.
• Use of leave (annual leave, compensatory time, leave without pay)
  to attend religious services or observances.
• Dress and grooming accommodations, such as hijabs, yarmulkes,
  turbans, beards, or modest clothing, so long as safety or security
  isn’t compromised.
• Breaks for prayer or religious practices, where they can be
  integrated into the workday without significant disruption.

None of these are automatic, and details must be worked out based on the
specific job and workplace. But the message is clear: agencies should be
willing to adjust rules and schedules when it’s feasible.

Key Takeaways from the Religious Expression Memo

1. Personal Religious Expression Gets Robust Protection

The religious expression memo zeroes in on what federal employees may
do at work when it comes to their faith. Under this guidance, employees
generally may:

• Display personal religious items in their workspacesuch as a
  Bible, Qur’an, cross, crucifix, mezuzah, prayer beads, or inspirational
  versesjust as coworkers may display family photos, sports team swag,
  or motivational quotes.
• Engage in religious conversations with coworkers, as long as
  the discussion is voluntary, respectful, and stops if a coworker
  signals discomfort or asks to end the conversation.
• Organize or join voluntary prayer or study groups during
  non-duty time, like lunch or before/after shifts, using available
  spaces on the same basis as other non-work groups.
• Express faith in some public-facing interactionsfor example,
  asking a visitor if they’d like prayerso long as participation is
  clearly voluntary, not tied to government services, and not coercive.

The memo emphasizes that religious expression should be treated at least
as favorably as comparable nonreligious expression. In other words, if
it’s okay to display a poster for your favorite band, it should generally
be okay to display a religious verse at your desk.

2. Expression Has Limits: No Harassment, No Coercion

Of course, the memo doesn’t give anyone a free pass to pressure others.
Federal employees are not allowed to:

• Harass coworkers, contractors, or the public based on religion or lack
  of religion.
• Tie religious participationprayer, services, or a particular beliefto
  job benefits, favorable assignments, or evaluations.
• Persist in religious discussions after someone has clearly expressed
  that they’re not interested.

Managers have an added responsibility: they must be especially careful
not to use their authority in ways that could feel coercive. An
invitation to a voluntary Bible study from a peer is one thing; the same
invite from your direct supervisor during your performance review is
something else entirely.

3. Protecting EveryoneReligious and Nonreligious

Crucially, the memos underscore that protections extend to all
employees: those who practice a minority faith, those in majority
traditions, and those who are atheist, agnostic, or simply not religious.
No one may be excluded, penalized, or mocked because of their beliefs or
lack thereof.

The goal is a workplace where religious expression is permitted but not
imposeda “you can share your beliefs, but you can’t shove them down
anyone’s throat” kind of balance.

What This Means in Practice for Federal Employees

For Employees of Faith

If you’re a federal employee with religious obligationsdaily prayers,
dietary restrictions, Sabbath observance, holy days, or modest dress
requirementsthese memos give you clearer assurance that:

• You may request accommodations for scheduling, dress, and other
  aspects of your job.
• Your agency must engage in a real conversation with you and look for
  workable solutions, not just say “no” because it’s easier.
• You may express your faith through personal items, respectful
  conversations, and voluntary gatherings.
• You are protected from retaliation for requesting accommodation or
  expressing your religious beliefs in a lawful, non-harassing way.

A best practice for employees is to communicate clearly and early:
explain your religious need, propose possible solutions, and be open to
compromise. The memos don’t guarantee a perfect outcome, but they do
give you a stronger starting point.

For Employees Who Are Not Religious (or Differently Religious)

If you’re not religiousor you hold different beliefs than your
coworkersyou might worry that the new guidance will make your workplace
feel more tense. The memos try to address that by reinforcing rules
against discrimination and harassment.

You do not have to:

• Join prayer groups or religious events.
• Listen to religious conversations that make you uncomfortable.
• Accept proselytizing that crosses the line from “sharing” to
  “pressuring.”

You do have the right to report harassment or discrimination if
religious expression turns into pressure, hostility, or exclusion. In a
healthy workplace, religious and nonreligious employees should both feel
free to be honest about their boundaries.

For Supervisors and HR Professionals

If you supervise federal employees, these memos are your new homework.
Some practical steps include:

• Update policies and training to reflect the more protective
  standard for religious accommodations and the robust protection for
  religious expression.
• Standardize the interactive processcreate clear forms,
  checklists, and documentation procedures so requests are handled
  consistently.
• Train managers on what counts as harassment or coercion and how to
  navigate tricky situations, especially where power dynamics are
  involved.
• Assess operational impact carefully before claiming “undue
  hardship.” Under the new standard, “this is mildly annoying” no longer
  cuts it.

Getting this wrong can lead to grievances, EEO complaints, and lawsuits.
Getting it right can improve morale and retention, particularly among
employees who previously felt they had to hide core parts of their
identity at work.

Gray Areas and Emerging Questions

As with any major policy shift, the OPM memos raise practical questions.
A few of the most challenging include:

• How much disruption counts as “substantial”? Agencies will have
  to decide how many scheduling changes, shift swaps, or telework
  arrangements truly cross the “undue hardship” line under the new
  standard.
• Where is the line between expression and endorsement? Employees
  may express personal faith; the agency as an institution must remain
  neutral. Public-facing roles will need clear guidance on how to avoid
  giving the impression that the government itself is favoring a
  particular religion.
• What happens when religious accommodations clash with other rights?
  For example, requests that intersect with LGBTQ+ inclusion, gender
  identity, or other protected categories may require especially careful,
  case-by-case consideration.
• How do remote and hybrid workplaces fit in? As telework and
  hybrid schedules continue, agencies will have to think through how
  religious observance interacts with return-to-office policies and
  virtual collaboration.

Courts, the EEOC, and agency EEO offices will continue to shape how
these issues are resolved. The OPM memos are a major signal, not the
last word.

Real-Life Experiences Under the New OPM Memos

Policies and legal standards are important, but they really come alive in
the everyday experiences of federal employees. Here are three composite
scenariosdrawn from common fact patternsthat illustrate how the OPM
guidance on religious accommodation and expression might work in real
life.

Case 1: The Sabbath-Observing Analyst

Lena is an analyst at a federal agency and a member of a faith tradition
that observes Sabbath from Friday evening to Saturday evening. Her team
recently shifted to weekend coverage during peak season, and her
supervisor scheduled her for several Saturday shifts.

Under the new OPM accommodation memo, Lena submits a written request
explaining that she cannot work during Sabbath for religious reasons and
proposes practical solutions: working later on weekdays, taking Sunday
shifts, and covering high-priority tasks other team members dislike.

Instead of flatly denying the request, HR and her supervisor meet with
her to discuss options. They review workload data, identify a colleague
willing to swap shifts, and adjust the weekend schedule. While not every
shift can be covered perfectly, the agency determines that the changes
don’t create substantial costs or major operational disruption. Lena
continues to meet performance expectations, and the team is able to plan
around her Sabbath observance.

Before Groff and the OPM memo, this might have been dismissed as “too
inconvenient.” Now, it’s a textbook example of the kind of creative,
good-faith problem-solving agencies are expected to try.

Case 2: The Coworker Who Feels Pressured

Daniel doesn’t identify with any religion. He shares an office with two
coworkers who are enthusiastic about their faith and often discuss
religious topics. At first, the conversations are casual and
interesting. Over time, though, Daniel begins to feel like he’s being
targetedhis coworkers repeatedly invite him to prayer groups and
suggest that he’d be “happier if he believed.”

Under the religious expression memo, Daniel’s coworkers are allowed to
talk about their beliefs, but only as long as the conversations are
voluntary and respectful. Once Daniel makes it clear that he’s
uncomfortable, continuing to push those discussions can cross the line
into harassment.

Daniel talks with his supervisor, who consults HR. The agency doesn’t
tell the religious coworkers that they can’t express their faith at all,
but it does make clear that they must stop directing religious pressure
at Daniel once he has said no. Everyone receives a reminder that respect
goes both ways: religious expression is protected, and so is the right
not to be pressured about religion at work.

Case 3: The Manager Trying to Do the Right Thing

Priya is a mid-level manager with a diverse teamMuslim, Jewish,
Christian, Hindu, and nonreligious employees all working together. After
the OPM memos come out, she realizes she’s nervous about getting things
wrong: she wants to support religious expression without playing
favorites or creating resentment.

Working with her agency’s EEO office, Priya holds a short, optional team
briefing. She explains that:

• People can request religious accommodations through HR or EEO, and the
  agency is committed to a fair process.
• Employees may express their beliefs in appropriate ways, but no one is
  required to participate in religious activities.
• Harassment and coercion are off-limits, regardless of the belief
  system involved.

She also quietly reviews her team’s scheduling patterns to make sure
religious observance isn’t being unintentionally penalized. Over time,
employees feel more comfortable raising concerns early, before they turn
into conflicts. The memos don’t magically eliminate tension, but they
give Priya a clearer roadmap for handling it.

Taken together, experiences like these show that the OPM memos are not
just about high-level constitutional principles. They’re about when you
can ask for a schedule change, what you can put on your desk, how you
talk to coworkers, and how supervisors respond when those things clash.

Conclusion

The OPM memos on religious accommodation and religious expression in the
federal workplace mark a significant shift toward a more explicit,
more generous approach to protecting religious liberty for federal
employees. They build on the Supreme Court’s clarified “undue hardship”
standard, long-standing Title VII protections, and constitutional
principles to create a framework where employees can bring their faith
to workwithout sidelining coworkers who believe differently or not at
all.

For employees, the message is: you can speak up about your religious
needs and expressions, and the law is increasingly clear that those
concerns deserve a serious, respectful response. For managers and HR,
the message is: you can’t treat religious accommodation as a minor,
optional courtesy anymore; you need processes, training, and thoughtful
judgment.

In the end, these memos are trying to do something both simple and
difficult: help build federal workplaces where people can do their jobs
well, keep their consciences intact, and treat one another with genuine
respect. That’s not just a legal challengeit’s a cultural one. But
with clear rules, good communication, and a bit of humility on all
sides, it’s a goal that’s well within reach.