Quick Hits
- Employers may need to provide religious accommodations to Muslim workers during the month of Ramadan.
- Ramadan is expected to begin on February 18, 2026 (following confirmation of the crescent moon on February 17).
- Ramadan is predicted to end on March 19, 2026 (again, depending on the lunar cycle).
- Eid al-Fitr marks the end of Ramadan with a festival.
Observant Muslims do not eat or drink water in the daylight hours during Ramadan. In some cases, Muslims who are ill, pregnant, or breastfeeding may be exempted from the obligation to fast during the day. It is common practice to eat a meal just before dawn (about ninety minutes before sunrise) and right at sunset during Ramadan. Along with the five daily prayer sessions typically required throughout the year, two additional prayers are recommended during Ramadan, an evening prayer (called “Taraweeh”) and a late night, early morning prayer (called “Qiyam”).
Employers can consider flexible work hours and/or telework to accommodate Muslim employees’ religious fasting needs. The exact timing of the daily fast—from dawn until sunset—varies slightly from day-to-day, and will also vary based on geographic location, so employers may want to speak with observant employees to determine their exact timings for the fast. This year, daylight savings also falls during Ramadan, which will also shift the timings for the fast based on the employee’s specific time zone.
Employers may also want to consider providing quiet, private spaces where observant employees can pray, break their fast, and also wash for prayer, called wudu, which is a mandatory ablution performed before prayer. Some employees may also request time off to celebrate Eid-al-Fitr, the holiday that celebrates the end of Ramadan.
Employees in physically demanding jobs may need certain accommodations, such as rest breaks, while they are fasting, depending on their medical conditions, age, and other factors. And, importantly, as is the situation with most religious beliefs, practices, and membership, not all Muslim employees have the exact same accommodation needs or desires. Practicing a religious faith often involves personal and varying nuances and beliefs that differ among individuals. Having a conversation with each employee who has requested an accommodation is helpful to understand their specific situation and request, and such tailored discussions meet the legal requirement for employers to engage in an “interactive process” regarding any religious accommodation requests.
Legal Obligations
Employers are familiar with Title VII of the Civil Rights Act of 1964’s prohibition against harassing or discriminating against workers based on their religion. But Title VII further requires employers to affirmatively make reasonable accommodations when an employee’s religious beliefs conflict with a work requirement or when the requested assistance better allows the employee to perform his or her job functions. The accommodation requirement can be avoided only if the employee’s request would impose an undue burden on the employer. The undue burden defense must be demonstrated by actual evidence and is a high bar for an employer to meet. In 2023, the Supreme Court of the United States confirmed and held that employers must prove substantial increased costs in relation to the conduct of their businesses in order to qualify for the undue hardship defense. Such burdens can be either financial or nonmonetary (or both) in nature, including significant disruptions to operations, efficiency, scheduling, or safety, so long as those impacts are shown to translate into real burdens on the business rather than mere coworker dislike or bias.
In addition to the federal law, many states have laws that similarly prohibit religious discrimination in the workplace and require reasonable accommodations.
Next Steps
Employers can consider ways to recognize Ramadan and provide education about it in their internal newsletters or social events. Keep in mind, however, that not all Muslims observe Ramadan—or otherwise practice their religion—in the same way.
To avoid violations of state and federal laws, employers may wish to review their written policies, practices, and employee training to prevent harassment and discrimination based on religion.
Employers must provide accommodations for employees’ religious beliefs and practices, unless the accommodation would cause a substantial burden on business operations.
The Ogletree Deakins Client Portal includes state and federal law summaries for Religious Accommodation and Protected Characteristics. For more information on the Client Portal or a Client Portal subscription, please reach out to clientportal@ogletree.com.
Ogletree Deakins’ Employment Law Practice Group and Leaves of Absence/Reasonable Accommodation Practice Group will continue to monitor developments and will provide updates on the Employment Law and Leaves of Absence blogs as new information becomes available.
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